Privacy Policy

[Last Updated: 3/31/2023]

Your privacy is very important to Asset-Map Holdings, Inc. and its affiliates and subsidiaries (“Asset-Map”, “our”, “we” and/or “us”), and we are committed to safeguarding, preserving, and respecting your privacy rights.  We collect certain types of information about users of our .ME Platform (which is direct to end users) and our Asset-Map Platform (which is used by financial advisors) (collectively, the “Platforms”).  This privacy statement (“Privacy Policy,” “Statement,” or “Policy”) discloses what information we collect, how we use it, and how to correct or change it.  By using our Services—the Platforms and/or our website (the “Site”), www.asset-map.com, (collectively the “Services”)—you consent to our collection and use of your information as described in this Privacy Policy.

For purposes of this Policy, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations.  It does not include data excluded or exempted from those laws and regulations.  Nothing in this Policy will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Asset-Map generally or in any specific context.

Our Services are used at times by third parties such as financial advisors in connection with the services they provide to their clients.  This Policy does not apply to how third parties may collect and process personal information, and you should consult their applicable privacy policies and terms. 

This Policy expressly incorporates any privacy notices we may issue to supplement this Policy, for example, if required by law.  Depending on your residency, a supplemental privacy notice may apply to you.  Unless supplemental notices expressly provide otherwise, in the event of any conflict between this Policy and additional privacy notices this Policy governs. 

Your Consent to This Policy

You should read this Policy carefully.  We recommend printing and retaining a copy for your future reference.  By accessing, browsing, or otherwise using the Services you confirm that you have read, understood, and agreed with this Policy.  If you do not agree to this Policy, you may not use the Services.

This Policy applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Policy together with any other notice we may provide on specific occasions, so that you are fully aware of how and why we are using your personal information. This Policy supplements these other notices and is not intended to override them.

Your use of our Services, and any dispute over privacy, is subject to this Policy, our terms of service for each of our products and our terms of use for the Site are incorporated by reference into this Policy.

If you have any questions or concerns about Asset-Map’s personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

Information We Collect and How We Use It

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties.  We use the data you enter to provide the Services to you and enhance the functionality of the Platforms. We also analyze all of our customer data in aggregate to understand more about the average Asset-Map Platform and .ME Platform users.  Personal information does not include aggregate and anonymized data.  The categories of personal information that we collect and the purposes for which we collect that information are described below.

Categories of Information We Collect

The following list describes the categories of personal information we collect.

·       Account Information.  When an end user or financial advisor creates an account on the Platforms, we will collect certain subscription information about the person creating the account.  This information may include name, company, estimated or actual age, gender, phone number, title, zip code, email address, username, password, and financial information such as account name, location and amount.  We collect this information when you provide it directly to us. 

·       Analytics Information.  We collect certain analytics information automatically as you navigate our Services.  This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails.  For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below.

• Chat Information includes the contents of the conversation.  We collect this information when you engage with the Site’s ChatBot.  If you interact with the ChatBot on the Site we may record the conversation.  Please note that the ChatBot may sometimes be an automated program and not a real person and information relating to your communications may be shared with our service provider.

• Commercial History includes information regarding your subscription information.  We collect this information when you provide it directly to us.

• Communications.  Any messages, email or communications that you send to us may be retained so that we can process your inquiries, respond to your requests or improve the quality of our Services.  We may use your email address and other personal contact information to communicate with you about our Services.

• Contact Information includes name, title, zip code, email address, and phone number. We collect this information when you provide it directly to us such as signing up for newsletters or filling out a form. We may also collect this information from other businesses who provide your business contact information.

• Demographic Information includes name, email address, place of employment, type of employment, industry, household income, race, age, and gender.  We collect this information when you provide it directly to us.

• Financial Information includes financial statements, income, and balances.  The end user or their financial advisor may be able to import these into the Platforms.  This type of information may also include currency type, name, address, phone number, and debit or credit card information.  We may collect this information directly from you or by our third party vendor.

• Job Applications and Employment.  If you apply to a job or are employed or contracted by us, we will collect various pieces of information about you.

• Organization-Related Information includes title, job type, organization name, organization type, and country.  We collect this information when you provide it directly to us.  We may also collect this information from other businesses who provide your business contact information.

• Social Media Information includes information that you may post when you interact with us on a social media platform.  We collect this information when you provide it directly to us.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.

Purposes for Collection of Information

The following chart identifies the purposes for which we may collect your personal information, as well as information regarding our use and disclosure of that personal information.  Please note that we may not collect each category of information about each user of our Services.

Other Ways We May Collect, Use, or Share Personal Information

We may also reserve the right to collect, use, or share personal information for the following purposes:

• For legal purposes.  We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on the Services.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.  If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.

• Business transactions or mergers.  We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.  Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence.  If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.

• Bankruptcy or insolvency.  In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.

• Information from our partners.  We may collect information from our partners such as market research firms, service providers, and our affiliates, subsidiaries, joint ventures, or other companies under common control.  We may combine that information with other information we collect about you, but we will always use the information as described in this Policy. 

• With your consent. We require opt-in consent for the sharing of any confidential personal information. This consent can include, but is not limited to, when you choose to integrate Asset-Map services with other third party software or services.

• With our service providers.  We may share your data with third parties who perform data services on our behalf (e.g., hosting, maintenance, backup, analysis, etc.).  Any such third parties will be under an obligation to us to maintain the confidentiality of your personal information.

• When you connect with a Platform partner.  You may be provided with offers, products, and services from third-party companies who integrate with our Platforms (“Platform Partner”).  These may include financial institution interfaces.  If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct Asset-Map to share your information, including personal information, to the Platform Partner providing the service or offering.

• With third parties for marketing and other purposes. We may share personal information with third parties so that they can market products, information, campaigns, or services to you, or to other third parties that share the information with other entities that can market products, information, campaigns, or services to you.  To the extent you do not want us to share your personal information with these companies, please contact us as described below in the “Contact Us” section

How We Use Cookies and Other Tracking Technologies

We may send one or more cookies to your computer or other device.  We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services.  This information allows us to understand how you use the Services.

What Are Cookies?

Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website.  When you access our Services, we use cookies and other tracking technologies to:

• Estimate our audience size and usage patterns;

• Store information about your preferences, allowing us to customize our Services according to your individual needs;

• Contact you to provide you with information or services that you request from us;

• Advertise new content, events, and services that relate to your interests;

• Provide you with more personalized content that is most relevant to your interest areas; and

• Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties.  You can manage your cookies preference as described in the ”Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers.

We do not use any cookies, pixels, or other tracking that discloses to any third party information that identifies a person as having viewed specific video materials.

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Services until the end of that particular browsing session.  These cookies, which are called ”session cookies,” expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser.  These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie.  Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies.  If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.

You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.

“Do Not Track” (DNT) Signals

DNT is a privacy preference that you can set in certain web browsers. When you turn on the DNT, the browser may send a signal or other message to web services requesting that they not track you.  Currently, our web servers do not recognize or respond to DNT signals.  Our Site and Platforms may continue to collect information in the manner described in this Privacy Policy.

How We Use the Personal Information

We use personal information we collect about you or that you provide to us in the following ways:

• to present our Site, Platforms, and their contents in a suitable and effective manner for you and your device;

• to contact you to provide you with information, services, or opportunities that you request from us;

• to advertise services or opportunities that we think may be of interest to you;

• to provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;

• to improve our Services by processing the information as part of machine learning and artificial intelligence developments (please note that we do not use EU or UK resident personal information as part of machine learning and artificial intelligence developments);

• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us; and

• to notify you about any additions, upgrades, or changes in our services.

Third-Party Links

This Privacy Policy applies to Asset-Map Services only.  We do not have any control over the websites offered by our partners, or sites that integrate with Asset-Map services such as our Platforms and our Site.  Those sites are governed by their own privacy policies, which you should read before using them. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting their website.

Where Your Personal Information is Held

Asset-Map processes personal information on our servers in the United States of America, and may do so in other countries.  In some cases, we may process personal information outside your own country.  For more information, please refer to the “Cross-Border Transfers of Personal Information” section below.

Information Security

We take appropriate organizational and technical security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.  Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all personal information you provide to us via our interactions.  If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

European Users’ Rights

This section of our Privacy Policy provides certain required information to persons located in the European Union (“EU”), a European Economic Area (“EEA”) member state, United Kingdom (“UK”), or Switzerland, as well as persons whose personal information is processed in or transferred from the EU, EEA, UK, or Switzerland.  Before Asset-Map collects any personal information, as defined by the General Data Protection Regulation (“GDPR”), you are entitled to the information in this section of our Privacy Policy as required by the GDPR. 

You are entitled by law to access, correct, amend, or delete personal information about you that we hold.  A summary listing these rights appears below.  Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

To exercise these rights, please contact us using the information below in the “Contact Us” section.  For your protection, we may need to verify your identity before responding to your request.  In the event that we refuse a request, we will provide you a reason as to why.

Asking us to access your personal information

You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this notice.  You also have the right to ask us for copies of your personal information.  When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.

Asking us to rectify your personal information

You have the right to ask us to rectify information you think is inaccurate.  You also have the right to ask us to complete information you think is incomplete.

Asking us to delete your personal information

You have the right to ask us to erase your personal information if:

• We no longer need it for the purposes for which we collected it;

• We have been using it with no valid legal basis;

• We are obligated to erase it to comply with a legal obligation to which we are subject;

• We need your consent to use the information and you withdraw consent; or

• You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute.  Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities.  We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.

If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Asking us to restrict our use of your personal information

You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:

• You contest the accuracy of the information that we hold about you, while we verify its accuracy;

• We have used your information unlawfully, but you request us to restrict its use instead of erasing it;

• We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or

• You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

The right to transfer your personal information to another service provider

You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability).  This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.

The right to withdraw consent 

If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.

The right to lodge a complaint with a supervisory authority 

If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here:  EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).

Rights related to automated decision-making 

To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

Right to object to processing

You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).  If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims.  You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below. 

Legal Bases for Processing Your Personal Information

Asset-Map collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request.  We will only process your personal information when we have a lawful basis for doing so.  If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information.  The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.

• Consent.  We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications.  You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal. 

  • Children’s Consent. We do not knowingly process data of EU, EEA, UK, or Swiss residents under the age of 16 without reasonably verified parental consent.

• Our Legitimate Interests.  We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests.  For example, our legitimate interests include but are not limited to when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services.  Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.

• To Perform a Contract.  We may process your personal information to administer and fulfill contractual obligations to you.  We will also collect and process your personal information as necessary for the performance of a contract to which you are a party.

• To Enable Us to Comply With a Legal Obligation.  We may process your personal information to comply with legal obligations to which we are subject.  This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.

• Necessary for the Exercise or Defense of Legal Claims.  If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland.  If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.

Cross-Border Transfers of Personal Information

Personal information that you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States and the South African Republic.  Neither the United States nor the South African Republic has an adequacy decision.  The GDPR permits such transfer when necessary for the performance of a contract between you and Asset-Map, if Asset-Map obtains your explicit consent to such transfer, or if it is Asset-Map’s legitimate interest to transfer the personal information.  The laws in the United States and the South African Republic may not be as protective of your privacy as those in your location.  If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard such as binding corporate rules, standard data protection clauses, or your consent. 

To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below.

Retention of Your Personal Information

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided.  We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.

Third-Party Links

Asset-Map’s Services may contain links to third-party websites.  When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within.  It is important to note that this Statement only applies to Asset-Map’s Services.  We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites.  We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

Where Your Personal Information is Held

We process personal information on our servers in the United States of America, and may do so in other countries.  If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States. 

Children’s Privacy

Protecting the privacy of the very young is especially important.  Our Services are not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18.  In the event that we learn that we have collected personal information from a child under age 18 without verification or parental consent, we will immediately delete that information.  If you believe that we might have any information from or about a child under 18, please contact us using the information provided in the “Contact Us” section below.

Changes to This Privacy Policy

This Statement may change from time to time.  If we need to change this Statement at some point in the future, we will post any changes on this page.  If we make a significant or material change to this Statement we will notify you via email.  You should check these terms when you use the Site.  Your continued use of the Site constitutes acceptance of the most current version of this Statement.

Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared.  If at any time you would like to unsubscribe from receiving future emails, you can email us at: support@asset-map.com as well as follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.  Please note, however, that we may still need to contact you regarding other matters.

Contact Us

If you have any questions about our Privacy Policy, please contact us by email at support@asset-map.com.

Our office’s location is:

225 Arch Street

First Floor

Philadelphia, PA 19106

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