Privacy Policy
We’re here to provide you with tools and information that are designed to help you make the most of your financial health and well-being. Our privacy policy (the "Privacy Policy") describes the information AboveBoard Financial, Inc. ("AboveBoard," "aboveboardfinancial.com," "we," "us" or "our") collects when you register for, use, access or otherwise interact with any of our applications, products or services (collectively, the "Services"), why we collect it, how we use and share the information that we collect and receive, and the choices we offer.
In addition, please review our Terms of Use, which governs your use of our Services.
If you have questions or complaints regarding our privacy policy or practices, please contact us at info@aboveboardfinancial.com.
1. What Information Do We Collect?
Information You Provide to Us
When you register for an account with AboveBoard or use our Services, we may ask you to provide us with certain information such as: (1) information that could reasonably be used to identify you personally, such as your name, address, email address, date of birth, Social Security number, driver’s license number or phone number ("Personal Information"); and (2) other information about things like your income, gender or household. We may collect Personal Information or other information directly from you through various other forms and places throughout the Services, including “Contact Us" forms, or when you otherwise interact with us in order to provide or enhance our Services. We may combine non-personal information with Personal Information, but we will treat the combined information as Personal Information as long as it is combined.
The Services are operated in the United States and intended for users located in the United States.
The Services are not intended for anyone under the age of 18. We do not knowingly collect any Personal Information from children younger than the age of 13. We will delete any Personal Information collected that we determine to be from a user younger than the age 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personal Information or other information to us, please contact us at info@aboveboardfinancial.com via email or write to us at: AboveBoard Financial, Inc. Attention: Legal Department, 112 West 34th St, New York, NY 10120
Information We Collect As You Access And Use The Services
In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically collect certain information telling us how you access or interact with the Services ("Usage Information"). For an explanation of the technical terms we use below, see our Glossary. The Usage Information we may collect includes:
- Device and browser information. We automatically receive and record information that your browser sends when you are using our Services. This may include information such as your IP address or other Device Identifier, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your Device.
- Log information. When you use our Services, we may use certain technologies and methods for collecting Usage Information about how you interact with our Services. For example, we may collect Usage Information through cookies, Flash cookies, web beacons or embedded scripts.
- Location information. AboveBoard will not collect your specific location information without your consent. However, we may ask your consent to using location-enabled services on your Device so that we can collect, share and process information about your specific location to enhance our Services and offers to you, using things like GPS or Wi-Fi access point information. If at any point you no longer wish to allow us to use location-enabled services on your Device, you may disable this feature through your Device settings. We may also use information like your IP address or other Device Identifiers for approximate location information, like your city or state.
- Information Collected by Mobile Application. Some of our Services may be provided through an application on your mobile, tablet computer, or similar device ("Mobile Application"). Our Mobile Application may collect the same types of information described above, including Personal Information or other information that you provide (e.g. name, age, gender, address), or Usage Information that is automatically collected and stored. We may also collect and use technical data and related information, including but not limited to, preferred language, phone number or other unique Device Identifiers assigned to your mobile device, technical information about your mobile device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications. We may associate your unique Device Identifier or Mobile Application Usage Information with any Personal Information you provide, but we will treat the combined information as Personal Information as long as it is combined.
Information You Provide About A Third Party
If you choose to use our referral program to tell a friend about our Services, we will ask you for your friend's name and email address. We will send your friend an email inviting him or her to visit the site. AboveBoard stores the information you provide for the sole purpose of sending this email and tracking the success of our referral program. The information you provide will not be used for any other marketing purpose unless your friend signs up for an account or we otherwise obtain consent from that person. Please be aware that when you use any send-to-a-friend functionality through our Services, your name and e-mail address may be included in the communication sent to your friend.
Your friend may contact us at info@aboveboardfinancial.com to request that we remove this information from our database.
Information Third Parties Collect
AboveBoard may post links to third party web sites which are governed by their own terms and are not subject to this Privacy Policy. We do not exercise control over these third party sites and they may place their own cookies or other files on your Device, collect data, web site usage information and your Device Identifier, or solicit Personal Information from you. We are not responsible for the privacy practices of any third party. We encourage you to note when you leave our Services and to read the privacy policies and terms of service of all third party web sites or applications before submitting any Personal Information to third parties.
In addition, our Services may include social media features, such as the Facebook Like button and widgets, the “Share This” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing the feature.
2. How Do We Use The Information We Collect?
We use the information we collect to provide, maintain, protect, optimize and improve our Services, and to enhance our user experience. For instance, we may use the information we collect in the following ways: to perform mathematical calculations, to serve content that we believe might be of interest to you, to suggest professionals who you might wish to consider working with.
Usage Information.
We use Usage Information for general purposes: to enhance or otherwise improve the Services, to customize our content and the offers for financial products and services you see, to develop new services, conduct research, and provide anonymous or aggregated reporting internally and to our business partners. We do not store your Personal Information in cookies or log files on your Device, but identifiers in such cookies or log files may be tied to your Personal Information in our systems.
Special Offers and Updates.
We use information we collect in providing the Services, including Personal Information, to match you with offers for financial products and services. Generally, we will display these offers when you access our web or mobile Services, but we will occasionally send you information on products, services, special deals, or promotions, by email or other electronic messaging. Out of respect for your privacy, we present the option not to receive these types of email or electronic messaging communications by logging into your account and visiting the "My Profile" page or by following the unsubscribe instructions included in each email.
Service-related Announcements.
We will send you service-related announcements. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these non-promotional communications. If you do not wish to receive them, you have the option to terminate your account.
Push Notifications.
If you use our Mobile Applications, we may send you push notifications from time-to-time via our Mobile Application in order to provide or alert you to service-related announcements or information on products, services, special deals, or promotions. If you do not wish to receive these types of communications, you may turn them off in your mobile Device settings.
Customer Service.
When you first register for the Services, we may send you an introductory email welcoming you to AboveBoard. We may also communicate with you via email or other means in response to your inquiries and to manage your account. As described above in “Information You Provide About A Third Party,” we may also use information you provide about others to send invitation e-mails as part of our referral program.
Administrative and Legal Reasons.
We may access, use, preserve, transfer and disclose your information (including Personal Information): (i) to satisfy any applicable law, regulation, subpoena, governmental request or legal process if in our good faith opinion such action is required or permitted by law; (ii) to enforce the Terms of Use, including investigation of potential violations thereof; (iii) to protect the safety, integrity, rights, property or security of our Services or equipment or those of any third party; or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP addresses or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and law enforcement agencies, including disclosing such information to third parties, all in our discretion. Any such access, use, preservation, transfer or disclosure may be carried out without notice to you.
3. How Is Your Information Shared?
AboveBoard does not share, sell or rent your Personal Information to third parties for any purpose except in the following circumstances:
With Your Consent.
We will share your Personal Information with parties outside of AboveBoard when we have your consent. For example, if you wish to interview or hire a professional and want to share some or all of the information you already provided to AboveBoard (in order to avoid duplicating your own efforts), you may have the choice to submit selected information to that professional.
When You Choose to Provide Information to Third Parties.
As part of the Services, you may be presented with opportunities for additional financial products or services that may require submitting information to unaffiliated third parties. For example, you may be asked to respond to offers provided by our marketing partners or presented with co-branded services we provide in association with third parties such as our marketing partners, business partners, or sponsors. These opportunities vary from day to day, but we will identify the relevant third party and in general, if you are interested in a particular offer or co-branded service, you will be taken to a third party site to complete the transaction or asked to submit information to the third party through a form on our site. When you are asked to provide information to a third party in connection with such offers or co-branded services, you may be providing your information to both us and the third party. We will treat information we collect in connection with a particular offer or co-branded service in accordance with this Privacy Policy but we are not responsible for the privacy practices of such third parties. For more information, see "Information Third Parties Collect."
When You Disclose Information Publicly.
The Services may permit you to submit ideas, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"), that is publicly viewable (such as the public portions of your user profile or comments you post on our publicly accessible blog). We or others may reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed). Third parties may have access to this User Content and may have the ability to share it further with third parties across the Internet. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. AboveBoard does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. This Privacy Policy does not apply to any information that you disclose publicly or share with others, whether through the Services or otherwise.
To request removal of your Personal Information from User Content, contact us at info@aboveboardfinancial.com. In some cases, we may not be able to remove your Personal Information from such User Content, in which case we will let you know if we are unable to do so and why.
When Third Parties Provide Services on Our Behalf.
We may use third party service providers or vendors to support or perform certain aspects of the Services on our or your behalf, such as hosting the Services, designing or operating the Services’ features, tracking the Services’ analytics, providing data used, directly or indirectly, in connection with the Services, marketing the Services, enabling AboveBoard to contact you with offers or performing other administrative services. We may provide these third party service providers or vendors with access to user information, including Personal Information, in connection with the services they are performing for you or for us. In connection with our Services, these third party service providers or vendors may also set and access their own cookies, web beacons and embedded scripts on your Device, and they may otherwise collect or have access to information about you.
For Sweepstakes, Contests and Promotions.
We may offer sweepstakes, contests, and other promotions (each a "Promotion") through the Services or through social media or other channels. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.
As Part of a Business Transfer.
We may share your information, including your Personal Information, and Usage Information with any parent, subsidiary or affiliate entity for the purposes disclosed in this Privacy Policy. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services; or (ii) in connection with any merger, acquisition, consolidation, restructuring, the sale of the majority of our outstanding stock, the sale of all or substantially all of our assets, or other corporate changes. In such cases, if there are any material changes in the use of your Personal Information as a result of such business transfer, as well as any choices you may have regarding your Personal Information, you will be notified via a notice to the primary email address specified in your marketing preferences or by placing a prominent notice on our site.
Administrative and Legal Reasons.
See "How Do We Use The Information Collected - Administrative and Legal Reasons".
4. Cookies and Online Tracking
Advertising Service Providers
We may work with third-party advertising networks, marketing partners, publishers and other entities ("Advertising Service Providers") to perform analytics and advertise our products and services on websites not affiliated with us. In connection with these advertising services, we or our Advertising Service Providers, like Google Analytics (discussed below) may use cookies, web beacons, and similar technologies to collect behavioral information about how you use our site or other websites in order to perform tracking and marketing analytics or serve advertisements that are more likely to be of interest to you ("Interest-Based Advertisements"). Our Advertising Service Providers may permit you to opt-out of all or some Interest-Based Advertisements on designated websites..
Disclosure Regarding Google Analytics Advertising Features
In addition to services from other Advertising Service Providers, we utilize the following Google Analytics Advertising Features as part of our marketing analytics and advertising: Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations and Google Analytics Demographics and Interest Reporting and may use other services provided by Google Analytics from time to time. Google provides users an opportunity to opt-out of the Google Analytics Features through Google’s Ads Settings and their web browser opt-out plugin. For additional information on opting out of interest-based ads by Google, visit here.
Do Not Track Signals
At this time, AboveBoard does not respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser. However, you may change the privacy preferences in your browser to prevent or limit the use of cookies or similar technologies. Be aware that Flash cookies operate differently than other browser cookies and various browsers may offer their own management tools for removing Flash cookies. To manage Flash cookies, please click here. Please note that blocking cookies, Flash cookies or similar technologies may affect your browsing experience on many sites and may prevent your ability to use certain AboveBoard Services, including many of the personalized features we provide for our members.
5. How Do I Access and Change My Personal Information or Change My Communications Preferences?
Accuracy of Your Personal Information
You are responsible for maintaining the accuracy of the information you submit to us. You can access and make changes to certain Personal Information you submit at any time by logging in with your registered e-mail address and password and making the change.
Communications Preferences
You can elect not to receive newsletters or alert emails (you can also do this by following the "unsubscribe" instructions included in each email).
6. Other Important Information About The Services
Security Practices Policy Statement
AboveBoard maintains physical, electronic, administrative and procedural safeguards to protect the confidentiality of Personal Information.
If you have any questions about security on our Services, you can send an email to us at info@aboveboardfinancial.com.
Terminating Your Account
If you wish to terminate your account with us, please contact us at info@aboveboardfinancial.com. We will disable your account, which will be inactive and not accessible to anyone other than AboveBoard authorized personnel. Moreover, once your account is terminated, you will not receive any further communications from AboveBoard. Except to the extent necessary for legal or regulatory recordkeeping purposes, your data will be anonymized after a period of two years and then may be held by us indefinitely. It may take an additional limited period of time for our automated backup systems to process the anonymized accounts.
Your California Privacy Rights
California’s "Shine the Light" law, California Civil Code § 1798.83, requires certain businesses to respond to requests from California customers (those who have an established business relationship with us) asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. We do not share customer information with third parties for their direct marketing purposes, and California’s Shine the Light law therefore does not apply to AboveBoard.
Changes to Our Privacy Policy
We reserve the right to change this Privacy Policy at any time without notice to you. If there are any material changes in the way we treat Personal Information, AboveBoard will notify you by sending a notice to the primary email address specified for your account or by placing a prominent notice on our site prior to the change becoming effective. AboveBoard will also promptly post any such policy changes to this page. Any changes will be effective immediately upon the posting of the revised Privacy Policy.
More Information
For additional information, or if you have questions regarding this policy or privacy practices at AboveBoard, please submit your questions or comments directly to info@aboveboardfinancial.com via email or write to us at: AboveBoard, 112 West 34th St, New York, NY 10120
Last Updated: June 14, 2017
Glossary of Technical Terms:
Cookies. A cookie is a data file we may place on a Device when you access the Services. Cookies may be used for purposes like identifying you, remembering your preferences, and tracking your visits to our web pages. If you choose to disable cookies on your Device, some features of the Services may not function properly. We do not store Personal Information on cookies. However, some of our business partners may also use cookies on our site. We do not have access or control over these cookies.
Device. The computer or other device you used to access the Services.
Device Identifier. An alphanumeric identifier that is automatically assigned to your Device that our computers use to identify your Device.
Embedded Scripts. We may use embedded scripts or similar methods when you access our Services. An embedded script is programming code that collects information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our server or that of a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Flash cookie. A Flash cookie is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device.
Web beacons. Web beacons are small, invisible graphic images or other web programming code we may place on web or mobile pages, or other parts of the Services (also known as "1x1 GIFs" or "clear GIFs"). We may use web beacons or similar technologies for a number of purposes, such as counting users of the Services, monitoring how users navigate the Services, determining whether emails we sent were actually opened or counting views of particular articles or links. In contrast to cookies, which may be stored on your Device’s hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence.