Privacy
Privacy Notice.
Written to be read. Where a clause is genuinely a limitation, it says so rather than being buried.
Clause structure to author
This page must be drafted or reviewed by counsel. The clause set below matches the structure already used across the portfolio so the four sites are consistent.
- Scope and who this notice covers
- Information we collect — from you, from your employer, and automatically
- How we use it, with the legal basis for each purpose
- How we share it — naming Institutional Trust Company, Investor Services, the executing broker, and infrastructure providers
- Employer boundary — what the employer can and cannot see, stated in the notice as well as enforced in the product
- Retention, including how long records survive account closure
- Security, and an honest statement of what it does not guarantee
- International transfers
- Your rights and how to exercise them
- Children
- Changes to this notice
- How to contact us
The clause that matters most here
The employer boundary belongs in the privacy notice, not only in the product. An employee reading this page should be able to see in writing that their employer cannot see their balance, holdings or beneficiaries.
Website analytics and newsletter
This site records first-party usage events — the page viewed, the referring page, and clicks on scheduling links — to understand what visitors find useful. Events are sent to our own form-intake system, are not shared with advertising networks, and no third-party analytics or advertising trackers are used. If you subscribe to our newsletter, your email address is stored in the same first-party system and used only to send the updates you asked for; every message includes a way to opt out, and you can request deletion at any time using the contact details on this page.