Familial
Privacy Notice
Last Updated and Effective: February 23, 2024
We at Familial LLC (collectively, “Familial”, “us”, “our”, or “we”) are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your personal information, as well as the rights and choices you have with respect to your personal information and how you can contact us to get answers to your questions. This Privacy Notice applies to the personal information we obtain in various contexts, both online and offline, including when you access or use our websites www.wearefamilial.com and its various subdomains), mobile applications, or any other applications or services that link to this Privacy Notice; interact or communicate with us; purchase or use our products, services, or features; engage with us on social media; interact with our advertising or marketing materials; or participate in any of our programs or events. Our “Services”, as used in this Privacy Notice, refer to our website, products, features, and services, including our financial and end of life planning services. Our privacy practices are subject to the applicable laws of the places in which we operate so you may see additional region-specific terms that only apply to customers located in those geographic regions, or as required by applicable laws. For certain products, services, and features, there may be additional notices about our practices and this Privacy Notice supplements any other privacy policies provided or communicated to you. Please read those additional privacy disclosures to understand how they apply to you.
By using our Services, you acknowledge the terms of this Privacy Notice. If you do not understand the terms of this Privacy Notice, please do not use our Services. If you have questions about this Privacy Notice, please contact us before using, or continuing to use, our Services. Our Services may include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of those third parties.
We reserve the right to change our Privacy Notice from time to time by posting the changes here. If we choose to amend this Privacy Notice, we will revise the Last Updated date at the top of this Privacy Notice when we post the updated version. We may also provide you with notice by prominently posting on our website, via email or both, if we make any significant changes to this Privacy Notice. Your use of our Services after we have informed you in one of these ways that we made changes to our Privacy Notice will mean that you have accepted those changes.
1. TYPES OF INFORMATION WE COLLECT
2. HOW WE COLLECT PERSONAL INFORMATION
3. HOW WE USE PERSONAL INFORMATION
4. HOW WE SHARE PERSONAL INFORMATION
5. HOW WE PROTECT PERSONAL INFORMATION
6. DATA TRANSFERS
7. CHILDREN’S PRIVACY
8. YOUR CALIFORNIA PRIVACY RIGHTS
9. YOUR CHOICES AND CONTROLS
10. THIRD PARTY WEBSITE AND APPS
11. CONTACT US
1. TYPES OF INFORMATION WE COLLECT
We collect two basic types of information from you when you provide it to us or when you use or interact with our Services or through our advertising and media across the Internet: personal information and non-personal information.
Personal information includes all information that relates to you or which are opinions about you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may only collect the following, limited types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services, such as your:
o Contact Information. Name, address, email address, phone and fax number, company name, title, and other contact information.
o Device Information. IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type, device identifiers, and information about how you use our Services.
o General Location Data. Information generated from your IP address that permits us to determine your general location, including using third-parties like Google services for this data collection.
o Payment Information. Credit and debit card, bank account, and other financial information necessary to send and receive payments, or third-parties that collect and use this payment information for processing, e.g., Stripe.
o Financial Information. Financial accounts and assets, including balance, provider, account numbers, account login information, and other information as requested to facilitate or complete delivery or to make available and provide ongoing support, maintenance, or other Services related to the Services being purchased.
o Uploaded and Inputted Information. Typed information, audio, video, photographs, and other files or information that you provide us.
o Beneficiary Information. Information relating to your designated beneficiaries, such as name, relationship and contact information.
o Healthcare-related Information. Insurance information and information relating to your personal wishes surrounding healthcare decisions.
o Share Feature Information. Contact names and information used to share your inputs and uploads with individuals that you have designated.
o Account Information. If you create an account, we may store and use your name, email address, zip or postal code and other personal information you may provide with your account. You can modify some of the personal information associated with your account. If you believe that someone has created an unauthorized account, you can request its removal.
o Usage Information. Data you provide from your use of the Services.
o Inferences. Inferences drawn from or created based on any of the information identified in this list, including potential future use for machine learning.
We strive to uphold data minimization principles and only seek to collect personal information from you for the purposes described in this Privacy Notice.
Non-personal information includes information that does not personally identify you or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.
You can always refuse to provide your personal information, but please note that some personal information is necessary to provide our Services.
2. HOW WE COLLECT PERSONAL INFORMATION
We need to collect personal information from you in order to provide you with our Services, as well as to improve your experience. You may provide us with personal information in several ways, including, for example when you:
● Visit our website or use our Services;
● Register or create an account;
● Correspond with us in any way, including through questionnaires, surveys, and job applications;
● Sign up to receive our newsletter or promotional information;
● Ask for customer service, support or other assistance; or
● Interact with us in any other way, online or offline, including through our Services.
Web Beacons & Cookies
Like many websites and apps, we use web beacons and “cookies”, which are small text or image files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions, including how you use a website. We use this information for analytics purposes which allows us to improve your experience. The information we collect through these technologies will also be used to manage your session. Out of these, the files that are categorized as “necessary” are stored on your browser as they are essential for the working of basic functionalities of the website. Disabling these necessary files may result in a website or app not functioning properly.
You can set your browser or device to refuse beacons or cookies or to indicate when they are being sent. If you delete them or if you opt-out, or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.
Online Analytics
We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”) and Feedbucket AB (“Feedbucket”), on our website. Google Analytics and Feedbucket uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google and Feedbucket may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.
Offline Interactions and Other Sources
We also may collect personal information from other sources, such as our partners or third-party service providers, or from our offline interactions with you for the purposes listed in the How We Use Personal Information section below, including to enable us to verify or update information contained in our records and to better customize the Services for you.
Social Media Integration
Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or X (formerly Twitter), and when you do, we may collect additional information from you, including the information listed in the Types of Information We Collect section above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or X’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.
Research and Surveys
From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, focus groups, and other forms of research, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third-party sponsor involved in the survey, we may provide certain personal information to the third-party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules, terms and conditions that are separate from and in addition to this Privacy Notice. By participating in any such surveys, you will become subject to those rules, including but not limited to receiving emails containing survey communications.
3. HOW WE USE PERSONAL INFORMATION
We primarily use personal information to provide, maintain, and improve our Services, but we may also use personal information to do any or all of the following:
● facilitate your interactions and transactions with us, such as requests for support or additional Services;
● respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about our Services);
● administer our relationship with you;
● develop new products, features, and services;
● better understand and address the preferences of our customers;
● provide personalized Services, including personalized experiences, content, and ads;
● share with authorized viewers, specifically designated by the user;
● analyze product performance, maintenance, and operations;
● provide you with, and improve, relevant marketing offers or information from us or relevant third parties;
● ensure our systems and premises are secure;
● develop and manage relationships with our business partners;
● respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
● defend, protect, or enforce our rights or applicable terms of service or to fulfill our legal or contractual obligations;
● manage any dispute and accidents and take legal or other professional advice;
● to prevent fraud or the recurrence of fraud;
● assist in the event of an emergency;
● comply with applicable law or legal directives; or
● any other purpose with your consent.
We may also combine your personal information collected through various sources, including information collected through our Services, and develop a customer profile that will be used for the purposes above.
Typically, we retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. In many situations, we must retain some or all of your personal information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for other legitimate business purposes, such as for auditing, accounting, or tax purposes.
We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose.
4. HOW WE SHARE PERSONAL INFORMATION
We only share personal information in limited circumstances as described in this Privacy Notice. For example, we may share personal information with your financial advisor(s) and individuals you designate, such as a family member. We may also share personal information with our corporate affiliates and subsidiaries as well as our third-party service providers, suppliers, vendors, professional advisors and business partners, which may include IT service providers, financial institutions and payment providers, customer relationship management vendors, social media platforms, other cloud-based solutions providers, lawyers, accountants, auditors and other professional advisors. We contract with such vendors and advisers to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information. We share personal information with these third parties to help us:
● with the uses described in the How We Use Information section above;
● in the operation, management, improvement, research and analysis of our Services;
● with our marketing and promotional projects, such as sending you information about products and services you may like and other promotions (provided you have not unsubscribed from receiving such marketing and promotional information from us); and
● to comply with your directions or any consent you have provided us.
We also share personal information with individuals that you specifically designate as Authorized Viewers (for example, a financial advisor, friend, or family member). You can adjust these sharing permissions in your account. Certain parts of our Services also permit you to export information via email or PDF.
We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:
● responding to a subpoena, court order, or other legal processes;
● defending, protecting, or enforcing our rights;
● assisting in the event of an emergency; and
● complying with applicable law.
In accordance with applicable law, we may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.
We share non-personal information with third parties as reasonably necessary to meet our business needs.
Information You Share Related to Our Services
Please be aware that there are areas of our Services where individuals may voluntarily disclose personal information. This information may be seen and used by others, such as your financial advisor or anyone you have designated to receive access. We encourage everyone to exercise good judgement when using these public areas and sharing personal information.
5. HOW WE PROTECT PERSONAL INFORMATION
We are dedicated to ensuring the security of your personal information. We use physical, electronic, and administrative security measures appropriate to the risks and sensitivity of the personal information we collect. Personal information is maintained on our servers or those of our service providers, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Privacy Notice. We aim to provide secure transmission of your personal information from your devices to our servers. We have processes to store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. While we attempt to protect your personal information in our possession, no method of transmission over the internet or security system is perfect, and we cannot promise that information about you will remain secure in all circumstances. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.
For your convenience, some of our Services allow you to remain logged in so that you do not have to re-enter your password each time you want to access your account. If you choose to remain logged in, you should be aware that anyone with access to your device will be able to access, use, and make changes to your account. Accordingly, we strongly recommend that you take appropriate steps (such as enabling the “Passcode Lock” security feature on your mobile device) to protect against unauthorized access to, and use, of your account, particularly if you choose to remain logged into your account. Please also contact us as soon as possible if you suspect any unauthorized use of your account or password.
6. DATA TRANSFERS
The information we collect may be transferred to, stored, and processed in any country or territory where one or more of our business partners or service providers are based or have facilities which may be a different to your home country. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal information that we transfer in line with this Privacy Notice requiring that our business partners or service providers adhere to this Privacy Notice and the applicable privacy regulations in your home country.
7. CHILDREN’S PRIVACY
Our Services are not for children or those under the age of 18. We do not knowingly collect personal information from children or other persons who are under 18 years of age. Individuals who are children or those under the age of 18 should not attempt to provide us with any personal information. If you think we have received personal information from children or those under the age of 18, please contact us immediately.
8. YOUR CALIFORNIA PRIVACY RIGHTS
We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted by you on our Services. To make any request pursuant to California privacy law, please contact us.
9. YOUR CHOICES AND CONTROLS
Correcting your personal information
You may request that we update or correct the personal information we collect. To submit a request or designate an authorized agent to make a request, please contact us using the information below.
Email Communications / Direct Marketing
You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your email address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these necessary emails, if lawful and appropriate, even if you unsubscribe from our optional marketing communications.
10. THIRD PARTY WEBSITES AND APPS
Our website and Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third-party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.
11. CONTACT US
We welcome requests, questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have requests, questions, concerns, or feedback, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.
Email: support@wearefamilial.com