Privacy Policy

Unlockt ("we," "our," or "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website at financeunlockt.com, use our client portal, mobile applications, or any related services (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please discontinue use of our Services immediately.

1. Information We Collect

1.1 Information You Provide Directly

• Account Information: Name, email address, phone number, mailing address, date of birth, and login credentials when you create an account or contact us.
• Financial Information: Income details, assets, liabilities, investment goals, risk tolerance, tax information, insurance details, retirement planning information, and other financial data you provide through our advisory services or financial roadmap tool.
• Identity Verification: Government-issued identification, Social Security number (or last four digits), and other information required for regulatory compliance and identity verification.
• Communications: Messages, documents, files, and other content shared through our secure client portal, contact forms, email, or other communication channels.
• Electronic Signatures: Signature data, consent records, IP addresses, and timestamps associated with documents you sign electronically through our platform.
• Payment Information: Billing address and payment method details when you engage our services. We do not store complete credit card numbers on our servers; payment processing is handled by third-party processors.

1.2 Information Collected Automatically

• Device and Usage Data: IP address, browser type and version, operating system, device identifiers, referring URLs, pages viewed, links clicked, time spent on pages, and access timestamps.
• Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze usage patterns, and remember your preferences. See Section 7 for more details.
• Log Data: Server logs that record requests made to our servers, including request type, date/time, referring/exit pages, and clickstream data.

1.3 Information from Third Parties

• Authentication Providers: If you sign in using Google or another third-party service, we receive your name, email address, and profile information as permitted by your settings with that provider.
• Financial Data Aggregators: With your authorization, we may receive account balances, transaction history, and other financial data from linked financial institutions.
• Public Records: We may supplement your information with publicly available data for identity verification and regulatory compliance.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Provide Financial Advisory Services: To create personalized financial plans, deliver investment recommendations, and fulfill our fiduciary obligations to you.
• Operate and Improve Our Services: To maintain, troubleshoot, and improve our website, portal, and related tools.
• Communicate with You: To respond to inquiries, send service-related notifications, provide updates about your account, and deliver requested information.
• Personalization: To tailor content, recommendations, and experiences to your financial situation and preferences.
• Security and Fraud Prevention: To protect against unauthorized access, detect suspicious activity, prevent fraud, and enforce our terms.
• Legal and Regulatory Compliance: To comply with applicable financial regulations, tax reporting requirements, anti-money laundering laws, and other legal obligations.
• Analytics: To understand how our Services are used, measure effectiveness, and inform business decisions.
• Marketing (with consent): To send promotional communications about our services, educational content, and market insights. You may opt out at any time.

3. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

We may share your information in the following limited circumstances:

• Your Financial Advisor: Information necessary for your assigned advisor to provide personalized financial guidance.
• Service Providers: Trusted third-party vendors who perform services on our behalf, including cloud hosting (Supabase, Netlify), payment processing, email delivery, analytics, and customer support. These providers are contractually obligated to protect your data and use it only for the purposes we specify.
• Legal Requirements: When required by law, regulation, legal process, or governmental request, including responding to subpoenas, court orders, or regulatory inquiries.
• Protection of Rights: When necessary to enforce our Terms and Conditions, protect our rights, safety, or property, or protect the rights, safety, or property of our users or others.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.
• With Your Consent: We may share your information for other purposes when you provide explicit consent.

4. Data Security

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information, including:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL (256-bit encryption). Data at rest is encrypted using AES-256 encryption.
• Access Controls: Role-based access controls ensure that only authorized personnel can access your information, and only to the extent necessary to perform their duties.
• Authentication: Multi-factor authentication, secure session management, and password hashing protect your account access.
• Monitoring: Continuous monitoring for unauthorized access attempts, security vulnerabilities, and suspicious activity.
• Vendor Security: We evaluate the security practices of all third-party service providers before engaging them and require contractual data protection commitments.

While we take commercially reasonable measures to protect your information, no system is completely secure. In the event of a data breach affecting your personal information, we will notify you in accordance with applicable law.

5. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services and maintain your account;
• Comply with legal, regulatory, and tax reporting obligations (financial records are typically retained for a minimum of 7 years);
• Resolve disputes and enforce our agreements;
• Maintain business records as required by applicable law.

When your information is no longer needed, we securely delete or anonymize it in accordance with our data retention policies.

6. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information, subject to legal retention requirements.
• Portability: Request your data in a commonly used, machine-readable format.
• Opt-Out of Marketing: Unsubscribe from marketing emails at any time by clicking the "unsubscribe" link or contacting us.
• Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time.
• Do Not Sell: We do not sell personal information. If applicable laws grant you the right to opt out of sales, you may exercise this right by contacting us.

To exercise any of these rights, contact us at admin@financeunlockt.com. We will respond within 30 days (or as required by applicable law).

7. Cookies and Tracking Technologies

We use the following types of cookies:

• Essential Cookies: Required for our Services to function properly (authentication, security, session management). These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website so we can improve the experience.
• Preference Cookies: Remember your settings and preferences (such as theme selection).

You can control cookies through your browser settings. Disabling certain cookies may limit your ability to use some features of our Services.

We do not currently respond to Do Not Track (DNT) browser signals, as there is no industry-wide standard for compliance.

8. Third-Party Links

Our Services may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through our platform.

9. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected information from a child under 18, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us immediately.

10. State-Specific Disclosures

California Residents (CCPA/CPRA)

If you are a California resident, you have the right to: (a) know what personal information we collect and how it is used; (b) request deletion of your personal information; (c) opt out of the sale or sharing of your personal information (we do not sell your data); and (d) non-discrimination for exercising your rights. To make a request, contact us at admin@financeunlockt.com.

Other U.S. States

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have additional rights. Contact us to exercise any rights available to you under your state's applicable privacy law.

11. Financial Industry Regulations

As a financial advisory service, we comply with applicable regulations including the Gramm-Leach-Bliley Act (GLBA) and Regulation S-P regarding the privacy of consumer financial information. Our information-sharing practices are consistent with these requirements.

12. International Users

Our Services are operated from the United States. If you access our Services from outside the United States, your information will be transferred to and processed in the United States. By using our Services, you consent to this transfer and processing.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this page and, where appropriate, by providing additional notice (such as email notification or a prominent notice on our website). Your continued use of our Services after changes become effective constitutes acceptance of the updated policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: admin@financeunlockt.com
• Website: financeunlockt.com