Privacy Notice

1. Who are we?

This privacy notice is issued by RedBlack Software, LLC and intelliflo Advisers Inc. (“we”, “our” or “us”).

RedBlack Software, LLC is a technology company that provides investment management solutions to financial advisors and institutions. We may offer our solutions both on-premises and as software-as-a-service, on the cloud. Our services are based on an open architecture platform and interface with our partners who are major custodians and brokers as well as a wide variety of third-party applications.

intelliflo Advisers Inc., as a leader in digital advice, provides a modern solution for financial institutions to offer goal-based investing to clients. Our service supports home offices, advisors, and end-clients, with an integrated digital advice solution that spans the full advisory lifecycle.
You can find more information about our solutions and services on our website.

2. What is the purpose of this privacy notice?

When we provide our services or otherwise interact with individuals, we collect personal information about them. The definition of personal information may vary under applicable laws, but it typically means information that identifies a particular individual. This privacy notice explains how we collect, use, share and protect your personal information. Please read this privacy notice carefully to understand what we do with your personal information. We may change this privacy notice from time to time and then we will make the updated privacy notice available on our website. The date at the bottom of this page indicates when this privacy notice was last updated. In certain circumstances, we may provide supplemental privacy notices which should be read together with this privacy notice.

By visiting and using our website or services, you are accepting this privacy notice, and consenting to our collection, use, disclosure, protection, and other processing of your information as described in this privacy notice. If you do not agree to this privacy notice, you should not use our website or services.

3. When does this privacy notice not apply?

Information for our customer’s clients

If you access our services as a client of our customer (e.g. your financial advisor or bank), this privacy notice does not apply, and your financial advisor’s or bank’s privacy notice explains how your personal information is used. We will process your personal data only as directed or permitted by our customer. Please contact your financial advisor or bank to obtain a copy of their privacy notice.

Links to other websites

This website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy notice of such websites to understand how your personal information that is collected on that site is used and protected.

4. Whose personal information do we collect?

This privacy notice applies to the following individuals:

• A user of our services (e.g. an employee of our customers)
• A representative of our former, current or prospective customers, partners, or vendors
• A visitor to our website
• A visitor to our premises or facilities
• Any other individual (outside our organisation) with whom we interact (“you”).

If you are a subscriber or registered user of our services, or if you use our services on behalf of a subscriber or registered user (e.g. your employer), then your use of our services are subject to a separate agreement that you have (or that your organization has) entered into with us. The terms of that agreement may prevail over this privacy notice in relation to the processing of your personal information.

5. What personal information do we collect about you, and how?

We may collect and process your name, information about the company you work for, your job title and role, your business contact details (email, mobile number), information about your business relationship with us, your regulatory registration number (if any), information about your use of our services or websites, online identifiers such as social media details (e.g. your twitter handle) and any other information that we ask you to provide or you choose to share with us.

We may collect and process personal information about you in the following ways:

Information that you give us:

• By filling in forms on our website e.g. when you submit your personal details in our “Contact Us” form to ask us to send you information about us, our products and services, or to respond to your requests and questions;
• By providing your information when using our services; or
• By interacting with us by phone, email or by other means.

Information that our services, systems and websites may collect about you:

• Information that allows us to understand how you do, or did, use our services e.g. from log information or database entries that are, or were, triggered by your engagement with our services;
• If you visit our websites, we may also collect certain information about you and your use of our website by using cookies and similar technologies e.g. IP addresses, domain names, the web browser and operating system used to access our website, your location and browsing history, including the pages visited, the time spent on each page, the time and date of each visit. This information is used to measure the use of our site, improve its content and personalise your online experience, but it would typically not identify you without combining this information with other information we may have about you. Please see our cookie policy for more information about how and why we use cookies and similar technologies, and how you can change your cookie settings, and please note our site does not respond to “Do Not Track” requests;
• If you contact us (e.g. vie email or phone), we may log your correspondence with us; and
• If you visit our facilities or premises, your visit may be recorded by our CCTV systems for security reasons.

Information about you that we may collect from other sources:

• From a colleague of yours, or the organisation you work for or represent;
• From publicly available profiles, registers and databases;
• From our affiliates, and our partners e.g. custodians or other third parties who may integrate their services with our solution;
• From other third parties who run industry events where we have been present, and you have registered to attend;
• We may validate the quality of the data we hold, by leveraging third party services such as email verification tools or tools that allow us to understand what social media systems you may use; and
• In some circumstances, from authorities and governmental agencies.

6. How do we use your personal information?

We may collect and use your personal information to:

• Perform and administer our agreement with you or your organisation, and maintain the relationship or otherwise interact with you for day-to-day business purposes e.g. to provide you with support for the service;
• Provide you with updates and training to help you get the best out of our services;
• Respond to any questions or queries you may have for us;
• Better understand your use of our services and the US financial advice sector to allow us to develop products and services that best serve our customers and the market;
• Sending you newsletters or other information about us, our products and services and US financial advice sector;
• Log and monitor calls and electronic communications for record keeping, security, quality, staff training and other business purposes;
• Manage our and our affiliates’ business operations, and for other internal administrative and legitimate business purposes, including to promote, market, distribute and provide our and our affiliates’ products and services to you or your organization;
• Inform you about our or our affiliates’ products and services, conferences, events, publications or anything else that you have requested or we think may be of interest to you or your organisation, and subject to applicable laws, this information may be provided to you by mail, phone, email, text message, social media or in the form of other digital advertisement and where you receive marketing via email or text message from us, we will tell you in that message how to unsubscribe;
• Conduct business analysis and market research relevant to our or our affiliates’ businesses;
• Test, develop and improve our or our affiliates’ products, services and IT-infrastructure, including our websites or systems;
• Ensure network and information security, and investigate, detect and prevent fraud and other crime;
• Protect our and our affiliates’ interests, including establishing, exercising and defending legal rights and claims; and
• In some circumstances, to comply with our legal obligations and requests from authorities.

We may also use your personal information in connection with corporate transactions or restructurings.

Any information collected about you from our website, your use of our services or otherwise, can be associated with other identifying information we have about you e.g. from other sources, and we may derive inferences based on that information.

We may aggregate and/or de-identify information about your use of our website and services for our business purposes e.g. product development and improvement activities, or to create business intelligence reports about the use of our services.

7. Who do we share your personal information with?

We do not sell your personal information, and we have not done so preceding the date of this privacy notice.

We may disclose your personal information, for the purposes set out in this privacy notice, to

• A colleague of yours, or other staff within the organisation you work for or represent;
• Our affiliates, our or their vendors, information technology service providers, data analysis and web hosting companies or other third parties who support us or them e.g. in providing services to you, conducting marketing and CRM activities, and in managing business operations;
• Our partners who integrate their services with our solution;
• Our agents, distributors, auditors and consultants; and
• In some circumstances, the police, courts, governmental agencies and authorities, where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with laws or legal processes, support an investigation or to protect our rights and interests.

We may also disclose your personal data in connection with any proposed purchase, merger or acquisition of any part of our or our affiliates’ business e.g. to a potential buyer and their professional advisers.

8. How do we protect your personal information?

We have implemented technical and organisational security measures to seek to protect your information transmitted through, or stored in, our website or services, against unauthorised access, or use. Your personal information resides behind a firewall, which is designed to restrict access to authorized personnel. However, no data transmission over the Internet can be guaranteed to be totally secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security the information you transmit to us or from our website or services.

If you are a user of our services, you are responsible for maintaining the secrecy of your user credentials. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us.

9. How long do we retain your personal information for?

We will retain your personal data for a time manner that is consistent with the purposes for which we have collected such information. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal, and regulatory obligations, internal data retention policies and our legitimate business interests.

10. Your rights in relation to your personal information under the California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws”, provide California consumers with specific rights regarding their personal information. If you are a user of our website or our services, and reside in California, this section of the Privacy Policy explains how you may exercise your privacy rights granted under the California Consumer Privacy Laws.

In most cases, we act as a “service provider” (as defined under CCPA) and process your (and your organisation’s clients’) personal information on behalf of your organisation which discloses such personal information to us for the purposes of our services under a separate agreement. That agreement may prevail over this privacy notice in relation to the processing of your personal information.

Under the California Consumer Privacy Laws, you have the following rights:

• Right to know. You have the right to know what categories and specific pieces of personal information we collect about you; the categories of sources from which we collect personal information; our business or commercial purpose for the collection, use, and sharing of your personal information; and any categories of third parties with whom we share your information.
• Right to delete. You have the right to request that we delete the personal information that we collect about you (unless it is necessary for us to retain your personal information for legitimate business purposes as specified by law).
• Right to opt out. You have the right to opt out of the sale or sharing of personal information. If we sell any of your personal information, you have the right, at any time, to tell us not to sell your personal information. At the time this Privacy Policy was last updated, we do not sell any personal information. You also have the right to request that we do not share your personal information.
• Right to correct. You have the right to request the correction of any personal information we maintain about you.
• Right to limit use or disclosure of sensitive personal information (“SPI”). You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.
• Right to non-discrimination. If you exercise any of your privacy rights, we will not discriminate against you. We do not discriminate for exercising any of these rights.

If you wish to exercise your rights and make a request related to your personal information, we need to verify your identity. To do so, you may be required to supply a valid means of identification as a security precaution or we may request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.

If it is necessary to collect additional information from you, we use the information only for verification purposes and delete it as soon as practicable after complying the request. For requests related to particularly sensitive personal information, we may require additional proof of identification. If you make a request through an authorized agent, we require written proof that the agent is authorized to act on your behalf.

If you have a question about or wish to exercise your rights, you can contact us as set out in the section “Contact Us” below.
If you are a non-US visitor, depending on which country you access the website from and the product and service we offer to you, you may have similar or additional rights in relation to your personal information. In this case, please contact us for more information about your rights.

11. Additional California Privacy Right

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year.

We do not distribute your personal information to outside parties without your consent for their direct marketing purposes.

How to contact us

Should you have any questions about this privacy notice, please contact us at: [email protected]