Last Modified: October 15, 2020

Types of Information We Collect

TrueNorth Wealth (the “Company”, “us” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.truenorthwealth.com/ (the “Website”), when you create an account with us to use the Website, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy is part of the Terms of Use applicable to the use of our Website. Please review this policy together with the Terms of Use, to understand all of your rights and obligations, and how we operate our Website.

This policy applies to information we collect:

On the Website.
In email, text, and other electronic messages between you and the Website.
Through mobile and desktop applications, if any, that you download from the Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Through any other means associated with or relating to the Website.

This policy does not apply to information collected by:

us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to the terms of this privacy policy.

This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to us or on or through the Website.

We do not knowingly collect personal information from children under the age of thirteen (13). If you are under thirteen (13), do not use or provide any information on this Website or on or through any of its features or register on the Website (if such feature is available), make any purchases through the Website (if such feature is available), use any of the interactive or public comment features of this Website (if such feature is available) or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under thirteen (13) years of age without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under the age of thirteen (13), please contact us at info@truenorthwealth.com.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Website, including information:

by which you may be personally identified, such as name, mailing address, e-mail address, telephone number, or any other information the Website collects that is defined as personally identifiable, private information, personal information or personal data pursuant to applicable law (collectively, “personal information”);
that is about you but individually does not identify you, such as the geographic location from which you accessed the Website; and
about your internet connection, the equipment you use to access our Website, your browsing history, and usage details.

We may collect this information:

Directly from you when you provide it to us;
Automatically as you navigate through the Website. Information collected automatically may include usage details and browsing patterns, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.

Information We Collect About You

The information we collect on or about you may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, creating an account (if such a feature is available), or requesting further services or information from us.
Information you provide to us or we acquire from your network or computing device when you report a problem with our Website and as we troubleshoot and work on the problem you reported.
Records and copies of your correspondence (including email addresses), if you contact us.
Any comments and information you provide to us when you use the “Contact” feature of our Website.
Your responses to surveys that we might ask you to complete.
Details of transactions you carry out on or through our Website.
Your search queries on the Website.
Information that our business partners collect about you, such as services you have signed up to receive, or products you have purchased, in each case which are related to our business.
Information you provide when you contact our customer service agents, if available.
Any other information you provide to us, or we collect throughout your usage of or access to our Website, which we collect for a business purpose.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and mobile applications (if any are made available), we may use automatic data collection technologies to collect certain information about you, your equipment, your technology providers, and your activities, including:

Details of your visits to our Website, including traffic data, browsing patterns, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer or mobile device and about your internet connection, including your IP address, mobile device identifier, your operating system, browser type, and the name of your mobile carrier.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
Analyze our services and products and perform market research.

When you visit or leave our Website by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.

We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we may use to show you local information on our mobile applications and for fraud prevention and security purposes. Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honor your settings.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Note that while you can set your browser to not allow cookies, we may not be able to honor that request, and may track your activity and collect information about you and your online activities even when the browser is set to “do not track”,
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 and you may not be able to shut down our collection of and use of information through this technology.
Web Beacons, Pixels and Tags. Pages of our Website and our e-mails 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 or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Log Files. These track actions occurring on our Website, and which help us collect your IP address, browser type, Internet service provider, the webpages from which you came or to which you go before and after visiting our Website, and the date and time of your visits.

Google Analytics

We use Google Analytics, a service provided by Google, Inc. (“Google”) for various purposes, including potentially to analyze traffic on our Website, to grow our business, to improve and develop our Services, to monitor and analyze use of our Services, to aid our technical administration, to increase the functionality and user-friendliness of our Services, and to verify that users have the authorization needed for us to process their request. Google may collect your IP address, and other information (although typically not your name), and utilizes the data collected to track and examine the use of our Website, and to prepare reports for us based on your activities online, among other uses. As part of Google Analytics, Google tracks many variables, including what website you visited prior to coming to our Website, how long you stay on a particular page, and your geographic location. Please be aware that Google uses the data it collects from our Website for its own purposes. Please visit Google’s privacy policy to understand how Google uses the information it collects: https://policies.google.com/privacy?hl=en-US.

You may be able to opt out of the use of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

Behavioral Advertising

To support and enhance our Services, we may serve advertisements, and may also allow third parties advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category, may be based on anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on third party services. We do not provide personal information to any ad networks for use outside of the Services.

To increase the effectiveness of ad delivery, we may deliver web beacons from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

Do Not Track

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly. Our Website does not respond to NDT settings at this time.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Third-Party Use of Cookies and Other Tracking Technologies

We may use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account and/or the Website.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, if needed.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website, if any.
To develop and create our products and services.
For behavioral tracking.
For any other purpose as needed for our business.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
To contact you about our own and third-parties’ goods and services that we think may be of interest to you.
To enable us to display advertisements to our advertisers’ target audiences.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and assist us in providing services and offering our products.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
To third parties to market their products or services to you.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To enforce or apply the Terms of Use, including this Privacy Policy, and any other agreements between us, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your California Privacy Rights

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

Note that, as stated in the ‘Information We Collect Through Automatic Data Collection Technologies’ Section above, we may use cookies and other tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

Please also see the “Do Not Track” Section above for information on how our Website responds to your browser’s “do not track” settings.

Data Security

We have implemented measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted through or collected through the use of our Website. Any transmission of personal information is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account. We may also post a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: info@truenorthwealth.com.