PathWise Privacy Policy

Facts

What Does PathWise Do with Your Personal Information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect can include:

• Social Security number OR taxpayer identification number        
• Assets and Liabilities
• Name, address, and phone number(s)                                            
• Income and expenses
• E-Mail Addresses                                                                                 
• Investment activity
• Account information (including other institutions)                       
• Investment experience and goals
• When you are no longer our customer, we will continue to hold your information and share it as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons why financial companies can share their customers’ personal information, the reasons PathWise chooses to share personal information and whether you can limit this sharing.

Who We Are

Who is providing this notice?

PathWise

1211 Newell Avenue, Suite 130, Walnut Creek CA 94596

925-939-5607 

www.pathwise.co

What We Do

How does PathWise protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that we believe comply with federal law. These measures include computer safeguards and secured files and buildings. Our online environment uses security technologies, including layered security and access controls over personal information. For further information, please call us at 925-939-5607

How does PathWise collect my personal information?

We collect your personal information, for example, when you:

• Open an account                                          
• Enter into an investment advisory account
• Apply for insurance                                     
• Tell us about your investment or retirement portfolio
• Seek advice about your investments

We may also collect your personal information from others such as credit bureaus, affiliates or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

State Specific Regulation – California

In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. We may share for purposes of providing services to you or to maintain our business but not for marketing purposes.

What happens when I limit sharing for an account, I hold jointly with someone else?

Your choices will apply to everyone on your account.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and non-financial companies. Our affiliates include companies with a PathWise name; financial companies such as Schwab, non-financial companies and others.

Non-Affiliates

Companies not related by common ownership or control. They can be financial and non-financial companies. Non-affiliates we may share information with include an independent representative’s new brokerage or an investment advisory firm.

Joint Marketing

A formal agreement between non-affiliates financial companies that together market financial products or services to you. This may include banks, credit unions or other financial institutions with which we have a joint marketing agreement

Third Parties

Third Parties we share for providing services that you have not entered into a contract with.

• Compliance Services                   
• Secure File-Sharing Providers      
• Planning Tools       
• Electronic Signatures 
• Document Delivery Providers   
• Portfolio Management Vendors 
• Contact Relationship Management Providers
• Investment Risk services            
• Archiving Services                           
• Computer Backup Services
• Signatures/Fax Services               
• Accounting Software                     
• Office Management Services