WealthEngine

WealthEngine, Inc. (“WealthEngine”) is committed to the privacy principals set forth between the European Union and the United States with respect to Personal Information (as defined below).  We value our relationship between our clients and certify that we follow the Safe Harbor Privacy Principles regarding Personal Information transferred from European Economic Area (“EEA”), European Union (“EU”) and Switzerland to the United States (“US”). WealthEngine’s practices fostering compliance with Safe Harbor Privacy Principles is set forth below, in this Notice (“Notice”).

“Personal Information” for the purposes of this policy shall mean information that (i) is transferred from EEA, EU and Switzerland to the US, (ii) is recorded in any form, (iii) that is information collected such as name, email address, postal address and telephone number, and (iv) could be linked to an individual.  This Personal Information is for the intended use of our clients only.

Safe Harbor Privacy Principles

WealthEngine’s practices regarding the Safe Harbor Privacy Principles, as set for by the US Department of Commerce and the European Commission, satisfy the requirement under European Union law that adequate protection be given to Personal Information transferred from EEA, EU and Switzerland to the US.

Notice

WealthEngine will notify individual subjects about the purpose(s) for WealthEngine’s collection and use of the individual subject’s Personal Information.  Individuals may contact WealthEngine’s Chief Security Officer using the contact information provided below with any inquiries or complaints, or to request information about the types of third parties (other than third-party processors) that WealthEngine discloses the Personal Information, and the choices and means WealthEngine offers for limiting use and disclosure of Personal Information.

Choice

WealthEngine may share Personal Information with third-party processors.  WealthEngine allows individual subjects from the EEA, EU and Switzerland to opt-out of sharing of Personal Information. Please direct requests to privacy@wealthengine.com if you would like to opt-out. WealthEngine will process opt-out requests in a reasonable period of time.  WealthEngine does not use Personal Information for purposes incompatible with the purpose(s) for which the information was originally collected without notifying the relevant individual subjects of such uses and offering an opportunity to opt-out. However, WealthEngine my disclose Personal Information if required by law.  WealthEngine does not collect sensitive information such as Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual.

Onward Transfer

WealthEngine may transfer Personal Information to a third-party processor we have retained to perform services.  WealthEngine will ensure that the third-party processor, if not subject to the Safe Harbor Privacy Principles, will provide at least the same level of protection of Personal Information as required by the Safe Harbor Privacy Principles.  WealthEngine will take commercially reasonable steps to prevent the misuse or disclosure of Personal Information.

Access

Individual subjects are given access to their Personal Information held by WealthEngine and are able to correct, amend, or delete that information where it is inaccurate, except (i) where the burden or expenses of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, (ii) where the rights of persons other than the individual would be violated, or (iii) as otherwise permitted by the Safe Harbor Principles.  Individual subjects seeking to access their Personal Information held by WealthEngine should contact our Chief Security Officer by using the contact information below.

Security

WealthEngine takes reasonable precautions to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Data Integrity

The Personal Information WealthEngine collects is relevant for the purpose(s) of the information’s intended use. WealthEngine takes reasonable steps to ensure that such Personal Information is reliable for its intended use, accurate, complete, and current.

Enforcement

WealthEngine conducts audits of its relevant privacy practices to ensure adherence to this Notice.  WealthEngine will investigate and attempt to resolve complaints and disputes regarding processing and disclosure of Personal Information in accordance with the principles contained in this Notice. For complaints resolved internally, WealthEngine’s remedy will be reasonable, and sufficient corrective action to resolve the complaint, including correcting any Personal Information, using Personal Information consistent with the Safe Harbor Principles, reversing or correcting the effects of noncompliance, and assuring that future processing of Personal Information will be in conformity with the Safe Harbor Privacy Principles. Complaints that cannot be resolved between WealthEngine will be handled by the American Arbitration Association.

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to WealthEngine’s Chief Security Officer using the contact information provided below.

Contact Information

Please address any questions or concerns regarding our Safe Harbor Privacy Notice or our practices regarding Personal Information to:

Chief Security Officer
WealthEngine, Inc.
4330 East West Highway, Suite 950
Bethesda, MD 20814

Or

privacy@wealthengine.com

Changes to the Policy

This Notice may be amended from time to time, consistent with the requirements of the Safe Harbor Privacy Principles. Changes to this Notice will be posted to this web site.

This Safe Harbor Privacy Notice was last updated and posted on January 17, 2012.