BRIDGEWORTH WEALTH MANAGEMENT
PRIVACY NOTICE REGARDING CLIENT PRIVACY AS REQUIRED BY REGULATION S-P & REGULATION S-AM
At Bridgeworth, LLC (“Bridgeworth”), maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Bridgeworth and any of its affiliates and subsidiaries.
Effective Date: October 21st, 2022
- Policy Applicability
- Collection of Personal Information
- Information You Voluntarily Submit to Us
- Automatic Data Collection
- Use of Personal Information
- Disclosure of Personal Information
- Retention of Personal Information
- Sale of Personal Information
- Consumer Rights Regarding Personal Information
- Additional Opt-Out Options
- Specific State and other Jurisdictional Rights Regarding Personal Information
- European Union (“EU”) General Data Protection Regulation (“GPDR”)
- Other States
- Security of Personal Information
- Regulatory Information and Miscellaneous
- Contact Information Regarding Privacy
1. Policy Applicability.
This Policy applies to information we collect, process, or transfer:
- On this Website.
- In email, text, and other communications between you and Company.
- On our mobile app.
- When you interact with our advertising and applications on Company or third-party websites and services.
- Offline or through any other means, including interaction with one of our employees or any third party on behalf of Company.
- During the ordering, payment, and shipping process through this Website.
It does not apply to information collected by:
- Any third party (excluding affiliates and subsidiaries) website, application, or content (including advertising) that may link to or be accessible from or through our Website(s).
2. Collection of Personal Information
We collect two types of information: (1) personally identifiable information and (2) non-personally identifiable information. The sources of information we collect, process, or transfer on or through our Website or within our Company may include:
- Information that you provide by submitting messages or other communications to us or to other users of our Website or third parties on our Website (“User Contributions”). This includes information provided at the time of purchasing or considering our products and/or services, giving feedback, when you enter a contest or promotion sponsored by us, or when you report a problem with our Website. (See Section 2a. below). Please be aware that your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of our Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by other users or third-party persons.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Transaction details that you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Your interactions on our Website(s), such as search history or browser activity, in addition to user contributions, through automatic data collection (see below).
- Information received about you from other third-party or affiliate sources, such as updated delivery and address information from carriers, to ease the delivery process.
- Any other information collected.
a. Information You Voluntarily Submit to Us
Certain information that we collect comes directly from you when you voluntarily submit it to us as a client or interested potential client. This includes information you may email us, provide over the phone or through an account application, or send us through the “Contact Us” link on our Website, as well as an additional page to input user contact information. Such information may include:
- Contact information such as name, username or alias, address, date of birth, social security number, telephone number, or email address;
- Demographic information such as profession and age range,
- Financial information such as income, investable assets, financial goals, needs or concerns;
- Information about your transactions with us, our affiliates, or others;
- History or employment status;
- Information received (with your consent) from credit or service bureaus or other third parties, such as your credit and credit history.
b. Automatic Data Collection
Our Website also uses automatic data collection technologies to collect certain information about your interaction with our products and/or services, Website content, your operating system, browsing actions, patterns (i.e., traffic and location data), and your Internet Protocol address. Other examples of information we may collect includes:
- Device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures;
- IP address, location data, usage data, device type, operating system, browser type;
- Time Zone Settings;
- Content downloads, streams, and playback details; and
- Full Uniform Resource Locator (“URL”) clickstream to, through, and from our Website, including products and/or services and content searched for and viewed, page response times, length of visits on webpages, download errors, and page interaction information such as scrolling and clicking.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. We do this because it helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to enhance search time and fix user interface issues quicker, among other benefits.
The technologies we use for this automatic data collection may include, but are not limited to:
- Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain Website content and verifying system and server security.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Conducting research and diagnostics to improve our Website’s products and other content.
- Preventing fraudulent activity.
- Improving our Website and your personal information security.
- Tracking your specified preferences, such as whether you want to see internet-based ads.
- Knowing the items in your cart when checking out.
- Understanding and delivering content, including ads, tailored to your relevant interest on our Website and third-party websites.
- Measuring and analyzing the performance of our products and/or services.
- Performing additional advertising as specified below.
We also use website usage data, first-party cookies, Google Analytics header code, and third-party cookies such as Facebook Pixel and LookAlike Audience, LinkedIN Tracking code, and Microsoft advertising code. These tools allow our marketing team and associated partners to conduct website traffic analysis and to conduct targeted advertising to inform potential customers of our products and/or services. Third-party cookies are permitted to collect user behavior such as pages viewed, website events/actions, and form completions. Information is collected through Google Tag Manager, which stores tracking codes for a seamless Website(s) experience. To inform yourself about these third-party services and manage any opt-out rights associated with them, please visit their privacy policies and opt-out procedures, where available, at the links provided in the chart below:
|Facebook Lookalike Audience (Meta)|
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Meta Platforms, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of this Website or engagement with relevant content across the Facebook apps and services. On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt-out of Facebook’s use of Trackers for ads personalization by visiting this opt-out page.
|Facebook Lead Ads (Meta)|
|Facebook Custom Audience (Meta)|
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Facebook advertising network. Users can opt-out of Facebook’s use of Trackers for ad personalization by visiting this opt-out page.
|Facebook Remarketing (Meta)|
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Facebook advertising network.
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities, and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
|Google Ad Manager|
Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner unless otherwise specified in this document, has no direct relationship with. In order to understand Google’s use of Data, consult Google’s partner policy. This service uses the “DoubleClick” Cookie, which tracks the use of this Website and User behavior concerning ads, products, and services offered. Users may decide to disable all the DoubleClick Cookies by going to Google Ad Settings.
|Google Ads Conversion Tracking|
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Website.
|Google Ads Remarketing|
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. In order to understand Google’s use of Data, consult Google’s partner policy. Users can opt-out of Google’s use of Trackers for ad personalization by visiting Google’s Ads Settings.
|Google Analytics Demographics and Interests Reports|
|Google Analytics Advertising Reporting Features|
Google Optimize is an A/B testing service provided by Google LLC (“Google”). Google may use Personal Data to contextualize and personalize the ads of its own advertising network. This type of service also allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
|Google Tag Manager|
Google Tag Manager is a tag management service provided by Google LLC. This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
LinkedIn Ads is an advertising service provided by LinkedIn Corporation.
|LinkedIn Conversion Tracking (LinkedIn Insight Tag)|
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Website. Users may opt-out of behavioral targeting features through their device settings, their LinkedIn account settings, or by visiting the AdChoices opt-out page.
|LinkedIn Website Retargeting|
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Website with the LinkedIn advertising network.
|Microsoft Universal Event Tracking (UET)|
Microsoft Universal Event Tracking (UET) is a tool that tracks what customers are doing after they click on our ad. By creating a EUT Tag and placing it across our website, Microsoft Advertising will collect data that allows us to track conversion goals and target audiences with remarketing lists.
|Tracker; Usage Data||You can opt-out of personalized ads either through your Windows settings or through the Microsoft Ad settings page.|
3. Personal Information
We use information that we collect about you or that you provide to us, including any personal information, in the following ways:
- To present our Website, products, and/or services and related content to you.
- To provide you with information, products, and/or services that you request from us.
- To accomplish any other purpose for which you provide your information.
- Enforcing our obligations and rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to any products and/or services we offer, our Website, and this Policy.
- Other purposes.
- For any other purpose with your consent.
We may also use your information to contact you about our own or third parties’ goods/services that may be of interest to you. If you do not want us to use your information in this way, please opt-out of this feature by contacting our data privacy department.
Further, we may use the information that we have collected to show advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or interact with an advertisement, the advertiser may assume that you meet its target criteria.
4. Disclosure of Personal Information
We may disclose aggregated, unidentifiable information about you without restriction. We may disclose personal information that we collect or you provide as described:
- To service providers, contractors, and other third parties used to support our business and who are contractually bound to keep personal information confidential and use it only for the defined purposes.
- To third parties to market their products and/or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the defined purposes.
- To a successor in the event of a merger, sale of substantially all our assets (which includes personal information), divestiture, restructuring, reorganization, or dissolution.
- To accomplish the purpose for which you request. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your name to the recipients.
- To comply with any government agency or court order, subpoena, or legal requirements.
- For any other purpose with your consent.
- If we determine disclosure is necessary or appropriate to protect the rights, property, or safety of our business, our customers, or the public. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. Retention of Personal Information
We will retain your Personal Information as long as it is needed for our business purposes and in accordance with applicable law. In determining this, we will be considerate of the amount, nature, and sensitivity of the Personal Information, the potential risk of harm to the Personal Information, and whether our purposes can be achieved through other means.
6. Sale of Personal Information
7. Consumer Rights Regarding Personal Information
We endeavor to give you the right to choose regarding the personal information you provide to us. Therefore, we have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. Our Website(s) are not designed to respond to “do not track” requests from browsers. You can set your browser to refuse all or some cookies. If you decline cookies, then please note that some parts of our Website may not function properly.
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for targeted advertisements or promotional purposes, you can opt out by sending your request to our data privacy department.
- Promotional Offers and Advertisements from our Company. If you do not wish to have your personal information used by our Company to promote and/or advertise our own products and/or services, you can opt out by contacting our data privacy department.
We do not control third parties collection or use of your information to serve interest-based advertising. To opt-out of third parties advertisements and other promotional offers, then you must contact the third parties directly.
You may also contact our privacy department to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information without verifying your identity. We may not complete a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
a. Additional Opt-Out Options
All users and visitors to our website have the option to discontinue receiving communications from us by way of email or newsletters. In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
b. Specific State and Other Jurisdictional Rights Regarding Personal Information
i. European Union (“EU”) General Data Protection Regulation (“GPDR”)
The EU’s GDPR applies to business entities, even with no presence in the EU/EEA, that may “offer goods or services to” or “monitor the behavior of” EU citizens located within the EU/EAA.
Based on our current information activities, we do not believe that the GDPR is applicable to us. Nonetheless, if you are a European citizen with questions or concerns about our collection, use, or disclosure of personal information, please contact us at [email protected].
The California Protection Act (“CCPA”) (as amended by the California Privacy Rights Act (“CPRA”) requires disclosure of the categories of personal information collected over the past 12 months. The categories of personal information that we have collected – as described by the CCPA – include:
- Identifiers, including name, email address, and IP address.
- Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)) and overlaps with other categories listed here.
- Demographics, such as your age, gender, or where you have provided such information to our Company voluntarily. This category includes data that may qualify as protected classification under other California and federal laws.
- Commercial Information, including purchases and engagement with our products and/or services.
- Geolocation data provided through location enables services such as Wi-Fi and GPS.
- Inferences, including information about your interest, preferences, and favorites.
California residents are entitled to opt out of the “sale” of their data at any time. As stated above, we do not sell personal information to third parties.
California’s “Shine the Light” law permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. As previously discussed, we do not disclose personal information to third parties for their direct marketing purposes.
iii. Other States
Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah, have additional personal information rights and choices described below:
Residents of Colorado, Connecticut, Virginia, or Utah have the right, subject to certain exceptions, to:
- Confirm whether we process their personal information
- Request access to certain personal information
- Request deletion of certain personal information
- Restrict the use of sensitive personal information
- Request copies of personal information in a data-portable format
- Opt out of certain targeted advertising, sales, or automated decision-making using personal information
Residents of Colorado, Connecticut, and Virginia have the additional right to:
- Correct inaccuracies in their personal information, taking into account the nature of the information’s processing purpose.
As mentioned before, none of these state laws currently apply to Bridgeworth. Nonetheless, if you have questions or concerns about our collection, use, or disclosure of your personal information, please contact us at [email protected].
8. Security of Personal Information
We have implemented security measures to protect your personal information from unauthorized access, data breaches, and accidental loss. Any payment transactions will be encrypted using commercial-grade technology.
We urge you to be careful about giving out information in public areas of the Website like reviews, comments, or other publicly facing User Contributions. The information you share in public areas of our Website may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Even though we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any of our Website’s privacy settings or security measures.
9. Regulatory Information and Miscellaneous
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity, and a simple method to opt-out of receiving the marketing solicitations; and (3) the consumer has not opted out. Bridgeworth, LLC does not receive information regarding marketing eligibility from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have developed an ITPP to adequately identify and detect to prevent, and mitigate identity theft.
10. Contact Information Regarding Privacy
For inquiries related to this Policy or our collection, use, or disclosure of your personal information, please contact our legal department at:
Bridgeworth Wealth Management
Attn: Ms. Monica Stoudemire, Chief Compliance Officer
101 25th Street North, Suite 100
Birmingham, AL 35203