Privacy Statement
Effective Date: October 23, 2021
1. Introduction.
DriveWealth, LLC and its affiliates (collectively, “DriveWealth,” “we,” “us,” or “our”) are committed to protecting the information and privacy of individuals utilizing our site and our services. We are the controller of the personal data collected and are responsible for the processing of your personal data submitted on our site.
This Privacy Statement (“Policy”) explains how we collect, use, and safeguard information that you may provide to us via this website and other domains owned and operated by DriveWealth. It is important that you read this Policy together with other disclosures or notices that we may provide to you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and is not intended to override them.
Please note that your request for a representative of DriveWealth to contact you, your reply to one of our marketing emails, or your communications sent to us do not create a confidential or fiduciary relationship. Do not send any information which you may consider to be confidential unless and until the appropriately authorized representatives of our companies have agreed in writing, to a confidentiality agreement. Information which you provide to us prior to such confidentiality agreement may not be protectable from disclosure and may not be subject to confidentiality provisions.
This Policy is intended for firm level communications and does not apply to the information we collect about the end retail users of our introducing broker and advisor partners (“Introducing Partners”) who work with DriveWealth. If you are an end retail user of one of our Introducing Partners, please refer to our Privacy Policy.
By using our website, submitting a request to contact, signing up for additional information about DriveWealth, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understood the practices contained in this Policy. This Policy may be revised from time to time, so please ensure that you check this Policy periodically to remain fully informed.
2. Our Data Practices
DriveWealth will collect personal and professional information from you. What data we collect depends on the specific circumstances:
· Professional information you provide to DriveWealth. We collect the information that you provide directly to us, such as information that you provide when you request a representative from DriveWealth to contact you, your firm’s profile, signing up for DriveWealth emails, support requests, compliance questionnaires, and other information you may communicate to us.
· Information we receive when you use our services. If your company chooses to work with DriveWealth under a formal agreement, then we will collect information on you in relation to the services, such as your contact details, authorized users, login credentials, banking/financial information, log files which may include identifiers and electronic network activity information, and approximate location.
· Information automatically created. DriveWealth may use various technologies and analytics tools to automatically collect identifiers and electronic network activity information when you use DriveWealth’s site and services. We utilize commonly-used logging and analytics tools, including Google Analytics, to collect information about your device, the network used to access the website, and information about your use of the website (such as how you navigate and move around the website). Please refer below for our Cookie Policy.
· Information collected from other sources. We may also collect information about you from other sources, such as information provided from other members of your company and from vendors to help us provide services to you. This could include other personal and professional identifiers and information about your company.
3. How We Use Your Information
DriveWealth will use your information we collect for the following business, operational, and commercial purposes:
· To Contact You. If you indicated that you would like a representative from DriveWealth to contact your firm, then we will use the information that you provided to us to contact you.
· Marketing Uses. If you indicated that you would like to receive information about DriveWealth and subscribe to our marketing emails then we will use your data for marketing purposes, which may include: providing information tailored to your inquiry or request; communicating with you about products, services, offers, and events that may be offered or sponsored by DriveWealth its affiliates, or partners; helping to personalize your experience, and providing you with other information that we think may be of interest to you.
· Operational Uses. To operate, improve, and develop our services; to monitor and analyze trends, usage, and activities in connection with our services, to respond to your comments, questions, inquiries and service requests; to communicate technical notices, updates, security alerts, and administrative messages; to verify your identity and other members of your company; to facilitate billing, account record-keeping; and to comply with applicable law, such as for tax reporting purposes.
4. Legal Bases for Processing Your Information.
We process your information and personal data for, or based on, one or more of the following legal bases:
· To enter into and perform under agreement(s) between you and us;
· To comply with your instructions and applicable law;
· As is necessary for our legitimate interests which are not overridden by your data protection interests or other rights;
· To comply with applicable law, our legal obligations, and our regulatory requirements;
· In certain other circumstances based on your consent.
5. Sharing Information.
From time to time the above processes and provision of DriveWealth’s services may require DriveWealth to share your information with third parties, including service providers, affiliates, regulatory agencies, and other partners. This occurs in the following circumstances: we share your information with our affiliate(s) who have a need to know the information for provision of the services; we share your information when you ask us to do so; we share your information with service providers, partners, contractors, or vendors in connection with the services they perform for us and as is necessary to provide and improve the services that we provide to you; we share your information in connection with a change in ownership or control of all or part of our business (such as merger, acquisition, or reorganization); we share your information if we believe that your actions are inconsistent with our agreements or policies, or to protect the rights, privacy, safety or property of DriveWealth and other users of DriveWealth’s services; and we share your information with other third parties where we reasonably believe it is required, or is necessary to comply with, applicable law or regulatory requirement, including but not limited to in response to a subpoena or other investigative or regulatory request or demand or to exercise our legal rights and defend against legal claims. We may also share information in order to prevent suspected illegal activity or other activity that threatens safety of our business, users, employees, or others, or to otherwise enforce agreements or policies.
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DriveWealth may also collect, use, and share aggregated and anonymized information for any purpose permitted under applicable law.
We do not sell your information to third-parties.
6. Protecting Your Information
Information and data security are important to DriveWealth. We deploy reasonable, appropriate, and industry standard physical, technical, and organizational safeguards to protect our systems and to protect the integrity of your information. While we use measures designed to protect your information, we cannot guarantee that our safeguards will be completely secure, effective, or sufficient. You should also be aware that transmission of data via the internet is not always secure and we cannot warrant that information that you transmit to us through the internet is or will be secure.
7. Retention of Your Information
DriveWealth retains your information for no longer than is necessary to achieve the purposes for which it was collected, and as is necessary to provide the processing activities described above, unless a longer retention period is required for regulatory purposes or under applicable law, and to the extent that we reasonably deem necessary to protect the right, property, and safety of our users and other third parties. In the event that you request to be removed from our communications list, DriveWealth will retain and use your information for the sole purpose of ensuring that you are included on our suppression list.
8. Your Choices.
Depending on your jurisdiction, you may have certain rights under applicable law regarding the information on you that we process, which may include the right to request access or deletion of your information.
In certain jurisdictions, including the EEA and UK, and subject to certain limitations and exceptions, you may have the right to: (i) know how we process your personal data; (ii) request access to or rectification of your personal data; (iii) object to, or request that we restrict, the processing of your personal data; (iv) request that we delete your personal data; (v) request that we provide the personal data you provided to us in a structured, commonly used and machine-readable format, for transmission to another controller; (vi) revoke consent at any time where our processing is based on your consent; and (vii) lodge a complaint with your local supervisory authority (if you’re in the EEA or UK, please see this page for contact details).
If you are a resident of California, subject to limitations and exceptions provided by law, you have the right to: (i) request access to the categories and specific pieces of personal information collected about you in the last twelve months (including personal information disclosed for business purposes); (ii) request deletion of your personal information; (iii) opt-out of any sales of your personal information if a business is engaged in selling your information; and (iv) not be discriminated against for exercising these rights.
You have the right to choose how we communicate with you and how we process certain of your information. You may exercise these rights, to the extent they apply to you, by contacting us at privacy@drivewealth.com In connection with such request we may request certain information from you in order to reasonably authenticate the request and/or to clarify the scope of your request.
9. Opting Out of Communications.
You may opt-out of certain communications depending on the nature of the communication.
· Marketing Communications. You may opt out of receiving marketing communications from us at any time by following the following opt-out link or other unsubscribe instructions provided in any email message received by you.
· Service-Related Communications. If your company works under a formal relationship with DriveWealth, we may still send you other types of non-marketing related communications, about your account and our ongoing business relationship, irrespective of your decision to opt out, and subject to limitations and exceptions provided by law or regulation.
· Cookies. Please consult our Cookie Policy for additional information.
10. Other Important Information.
· Intended Use. This website and use of DriveWealth’s services are intended to be on a company level basis. By accessing the site and providing your information, you represent that you are appropriately authorized to conduct business on behalf of your company.
· Third Party Websites and Services. DriveWealth may reference or provide links to third-party websites and services, which may or may not be affiliated with DriveWealth. When you access these third-party services, you leave our website, and we are not responsible for, and do not control, the content, security, or privacy practices employed by such third-party. You should consult such third-party’s terms of use, privacy policy, and other documentation to ensure you understand how your information is collected and processed. Use of such third-party sites and services is entirely at your own risk.
· Change of Control. In the event all or substantially all of the assets of DriveWealth are acquired, whether through merger, acquisition, or other corporate reorganization event, the information that we have from you via our website or via the services that we provide to you and your company may be among the assets transferred as part of the reorganization.
11. Changes to this Privacy Policy.
DriveWealth may amend this Policy periodically by posting a revised version in its disclosure library and updating the Effective Date. The updated version will be effective as of the updated “Effective Date.” DriveWealth will provide you with reasonable notice if there are material changes to our Policy. Your continued use of our Services after the Effective Date constitutes your acknowledgment and consent to any changes to our Policy.
12. Contact.
If you have any questions regarding the content of this Privacy Policy, or believe that we have not protected your Personal Data in accordance with this Privacy Policy and wish to file a complaint, please contact DriveWealth’s Data Protection officer at privacy@drivewealth.com. We may request that you provide us additional information regarding your concerns so that we can adequately investigate and address your issue. Note that any additional information we request, and communications with you, may be retained as part of our records; all records will be kept confidential to the extent permitted by applicable law and regulation and any Personal Data will be maintained in accordance with this Privacy Policy. European Customers may also contact the Danish Data Protection Agency for privacy related complaints.