Fair Capital, Inc. and its affiliates (collectively, “Fair Capital”) are committed to keeping your personal information safe. This Privacy and Security Policy describes how we use personal information, with whom we may share it, how we keep it secure, and your rights relating to your personal information.

How we collect your information

Fair Capital collects your personal information through your interactions with us or from third-party sources. Specifically, we collect your information when:

• You use, purchase, or subscribe to our products or services.
• You interact with us, including when you ask us for support, attend one of our events, or otherwise contact us.
• You visit our sites or use our products.

We may also collect information about you from third parties, including:

• Your employer, organization, or other third party who arranges access to our products and services for you.
• Our partners and other service providers that work with us to provide you with our products or services. For example, with your consent, we may receive your information from your bank or other financial institutions.
• Your financial advisor, who may give us personal information about you when they use our products or services.
• Other publicly available sources.

Personal information we collect

The types of personal information we collect depend on your interactions with us and may include the following:

• Name and contact information: Your first and last name, email address, postal address, phone number, and other contact information.
• Account credentials: Your user ID, password, password hints, and other similar security information used to authenticate your account.
• Demographic information: Your age, sex, geographic location, and preferred language.
• Payment details: Your bank account information, credit card number, and other information used to process payments.
• Financial and portfolio information: Information about your finances, portfolio, and transactions including accounts, assets, liabilities, income, expenses, investment activity, investment experience and goals.
• Custodial information: Custody, brokerage, and advisory information, suitability documents, statements, and other information needed to report or service your accounts.
• Subscription and usage information: Information about the products or services you subscribe to and how you use them, including preferences, browsing history, and help information.
• Device and network information: Information about your device, such as IP address, location, or internet service provider.
• Audio or video information: If you visit a Fair Capital location or participate in a Fair Capital event, Fair Capital may record your image or voice.
• User content: Your files or other information you upload to our products or services.

How we use personal information

How Fair Capital uses your information depends on the product and service that you use and your relationship with us. We use personal information as permitted under applicable law, as you request or consent to, and for the following purposes:

• We may share non-public personal information with non-affiliated third parties (such as financial data aggregators, administrators, brokers, custodians, regulators, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: reporting, processing transactions, and general account maintenance
• Provide products and services, including to verify your identity, personalize the content you receive, create, and administer your account, and send important account and product update information.
• Provide customer service, as well as technical and product support.
• Protect your, our, or third parties' networks, systems, property, or physical safety.
• Comply with requests from regulatory agencies, law enforcement, and other public and government authorities.
• Enforce our contracts, terms, and conditions, or otherwise exercise our legal rights; defend ourselves from claims; and comply with laws and regulations that apply to us or third parties with whom we work.
• Meet our or third parties' audit and compliance requirements.

Marketing Purposes

Fair Capital does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Fair Capital or the client has a formal agreement with the financial institution. Fair Capital will only share information for purposes of reporting or servicing your accounts, not for marketing purposes.

Links to other websites

Where applicable, Fair Capital may provide links to one or more third-party sites within our products or services. This Privacy & Security Policy does not apply to those sites. We encourage you to read any third-party site’s privacy policy before providing any of your personal information to them.

How we protect, store, and transfer your personal information

Fair Capital maintains a comprehensive information security program intended to keep your information safe. We have technical, physical, and organizational measures in place to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. The measures we use are appropriate to the nature, scope, and purpose for which we use the personal information we collect.

Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals have access to the information provided.

We maintain a comprehensive information security program that requires that we use physical, technical, and procedural safeguards intended to keep your information safe.

We use encryption when we store your information (encryption at rest) and when we transfer your information (encryption in transit).

We don’t store your password in open text, so it’s not possible for your advisor or our staff to look up your password to access your Fair Capital or third-party accounts.

If you have additional questions about how we protect your information, please contact us.

Your rights

You have the right to access, control, or delete your personal information that we store or to ask us to stop collecting information from your third-party accounts. You can also ask us to provide the general types of information we collect about our customers, who we collect it from, how we use or share it, and our business purpose for collecting, using, or sharing this information.

If you have an account with us, you can manage your information from within your Fair Capital profile. If you don’t have a profile (for example, your advisor may have given us your personal information in order to provide you services) or if you are otherwise unable to access, control, or delete your information from within your profile, please contact us for help.

We won’t discriminate against our customers who choose to exercise their rights to access, control or delete their personal information. Some of our products and services, however, may require your personal information. If you choose not to provide your personal information, you may not be able to use those products or services.

How does a user deactivate their account?

You can deactivate your Fair Capital account at any time through the Fair Capital application. When you deactivate your Fair Capital account, we’ll delete all of your account information within ninety (90) days, unless you instruct us differently or unless we have another legal reason to retain the information. You may also submit a request to delete your account using the “Feedback” button or contacting us.

California residents

The California Consumer Privacy Act requires that we list the categories of our customers’ personal information that we’ve sold or disclosed for business purposes in the last twelve (12) months.

• Sales: In the last twelve (12) months, we haven’t sold our customers’ information.
• Disclosures: In the last twelve (12) months, we’ve only disclosed customer information as directed by our customers. We’ve disclosed personal identifiers (for example, name and account information) and commercial information (for example, transaction or investment-related information) to financial service providers and to customers and their agents directly.

Security Framework

Fair Capital has created a high-security environment designed to ensure the privacy and security of its clients and their data. To assure this security, Fair Capital employs several different technologies including:

• Network security
• Application security
• Encryption

The Fair Capital Service encrypts all personal user information whenever it is transmitted or stored.

Production systems are housed at a site that provides security, redundant power, redundant high-speed Internet connections, system monitoring and management, comprehensive backup, and disaster recovery.

The following sections provide a further level of detail regarding the Fair Capital Service security processes.

Physical Security

The Fair Capital Service servers and database of user information are physically protected at a highly secure site. This site is protected from outside access by a series of firewalls and a comprehensive suite of security products. The physical premises are internally monitored twenty- four hours a day by security personnel. Only a very limited number of authorized personnel are granted access to the data center, and only after successfully passing multiple forms of personal identification and access authorization verification.

Network Security

The Fair Capital Service data gathering technology requires limited, well-defined access to and from the Internet. Inbound access is only permitted to the web servers, which are physically separate from the other components, and open ports are limited to HTTP (80) and HTTPS (443).

he Fair Capital Service uses only state-of-the-art equipment from proven, mainstream vendors to provide secure hardware environments. Additional network-level security includes anti-spoofing, secure DNS, and anti-virus via 24x7 monitoring. Log rotation is also in place to allow access to past events. Remote access is limited via VPN and two-tiered login.

Data Encryption

All sensitive data is transmitted and stored encrypted, even when communication is between components of the service itself. Values that need to be decrypted for use are encrypted using a strong two-way encryption algorithm. Values that do not need to be decrypted are encrypted using a strong one-way encryption algorithm and cannot be decrypted. Decryption keys are maintained in a password-protected key store. The key store is not accessible from the machine(s) on which the database resides, nor is the key store present on any database back-up (where the data remains encrypted).

Financial Data Access Roles

A hierarchy of roles and permissions defines who can access what financial data from within the service. Roles include Advisor, Aggregator, Client, Consultant, and Administrator. These roles and permissions may be used not only to control who may edit information, but also to control who may see any of a client’s personal information (account numbers, etc.).

Data Safeguards

Fair Capital maintains data safeguards against the destruction, loss, or alteration of, or unauthorized disclosure of or access to client’s data in its possession, including while in transport.

Cookies and similar technologies

We use cookies to know whether you’re logged in to our site, recognize the products and services you subscribe to, remember your preferred site language, location, and other preferences, and show you advertisements relevant to your interests. We use session cookies (which last until you close your browser) and persistent cookies (which last until you or your browser deletes them). These cookies fall into two broad categories: “essential cookies,” which originate from us and are necessary for us to provide you with our services, and “non-essential cookies,” which typically originate from third parties and are not required for you to use our services.

We use essential cookies for the following purposes:

• Authentication—We use cookies to allow you to sign into our services and stay signed in throughout one or multiple site visits.
• Subscription—We use cookies to recognize that you’ve bought our Premium service and make sure you’re able to view the content and tools that you’ve paid for.
• Site language—We have many sites across the world, and we use a cookie to make sure you see our site in a language commonly used in your country.

We use non-essential cookies for the following purposes:

• Analytics—Our third-party partners use cookies to provide us with analytics services. These partners, including Google Analytics, use cookies to help us understand how our customers use our sites.

Most browsers (Edge, Chrome, or Safari for example) allow you to choose whether to accept cookies through your browser settings.

Some of our products and services depend on cookies. If you disable these essential cookies through your browser, you may not be able to use a specific product, service, or feature of that product or service, and you may have to provide us with information that cookies would otherwise remember, including information about your identity and preferences.

About children’s privacy

Fair Capital does not separately identify or collect any information that is specific to children.

How we revise this statement

Our business frequently changes, and we may need to update this statement to reflect those changes. When we make changes to this Privacy & Security Policy, we’ll revise the “last updated” date at the top of this page. If we make material changes to this statement, we’ll notify you directly as required by law.

Contact us

If you have a concern, complaint, or question about how we handle your personal information, please contact us by using our web form, call us at +1 (415) 952-6699, or write us at the following mailing address: