Introduction

Our Site is operated by Voyant, Inc. and its affiliates ("Voyant", "we", "our" or the "Company"). The Site allows financial advisers and clients work together to plan their financial investments ("Service").

Users of the Service may be either a financial adviser who has entered into an agreement with Voyant ("Customer") or clients of a Customer, i.e. individuals seeking financial advice from the Customer, whom the Customer has as permitted by their commercial agreement with Voyant to have access to the Service ("Client User") (collectively Customer and Client User shall be referred to as "Users" or "you").

This Privacy Statement ("Privacy Statement") explains the types of information we may collect from Users or that End Users may provide when visiting the Site and/or using the Services. This Privacy Statement also describes Voyant's practices for collecting, using, maintaining and processing information.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Services you acknowledge you have read and understood this Privacy Statement.

For the purposes of European Economic Area and UK data protection law, ("Data Protection Law"), the data controller is of any personal data uploaded by a Customer or Client User in connection with the Service will be the relevant Customer and/or Client User ("User Personal Data") and Voyant, will in connection with this personal data be the data processor as defined in applicable Data Protection Law. The appropriate data processing contractual terms have been entered into between the Customer and Voyant in connection with the User Personal Data.

Notwithstanding the previous section, Voyant will be data controller of certain information provided by a User directly to Voyant and certain analytical information which Voyant may collect about each User's use of the Site.

By visiting our Site and/or using our Service you acknowledge you have read, understood, and agreed to this Privacy Policy and our Terms of Use. For more information about how we secure your information, please visit our Security Policy. For details on how we use cookies, visit our Cookies Policy. Our Security Policy, Cookies Policy, and Privacy Policy are incorporated into and form part of our Terms of Use.

We may amend or update this Privacy Statement from time to time, by changing the Privacy Statement on the Site and/or by notifying you when you return to the Site, or by email. Any amendments will take effect 7 days after they are published.

Information collected and how it may be used

Data we collect about you from your use of the Site and/or Service
The type of information is non-identifiable and anonymous information ("Non-personal Information"). We are not aware of the identity of the User from which we have collected Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Site and/or Service. Non-personal Information which is being gathered consists of technical information and behavioural information and which may include, the User's Internet protocol (IP) address used to connect your computer to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the User's 'click-stream' on the website, the period of time the User visited the website,), methods used to browse away from a page, and any phone number used to call our customer service number.

Data you give us.
This information is given by Users directly to us and may identify you and any others for whom you provide us with information and may be of a private and/or sensitive nature.
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This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Site, subscribe to our Service, search for products and services, subscribe for Services on our Site, submit a query, and when you report a problem with our Site.

Data we collect about you from Third Parties
This is data we receive about you but which you have not given us directly and will include information we collect about you from your use of other services that we may provide.

You do not have any legal obligation to provide any information to us however, we require certain information in order to provide the Service. If you choose not to provide us with certain information we may not be able to provide you with the Services.

Why do we collect such Information?

Information you give to us
We will use this information to:

• carry out our obligations arising from any contracts entered into between you and us and/or any contracts entered into between a Customer and Client User and to provide you with the information, products and Services that you request from us;
• administer your account with us; including billing;
• provide you with information about services we feel may interest you, if you have given your consent to receiving marketing material from us at the point when we collected the information you gave us;
• notify you about changes to our Service;
• contact you for the purpose of providing you with technical assistance and other related information about the Service;
• reply to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity; and
• ensure in our legitimate interests that content from our Site is presented in the most effective manner for you and for your computer.

Information we collect about you from your use of our Site
‍We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

• to administer our Site under our terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to keep our Site safe and secure;
• to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
• measure consumer interest in our services;
• to allow you to participate in interactive features of our Service, when you choose to do so; and
• to make suggestions and recommendations to you and other Users of our site about Services that may interest you or them.

Cookies & local storage

When you access or use the Service, we may use industry-wide technologies such as "cookies" or similar technologies, which stores certain information on your computer ("Local Storage") and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. The cookies used by the Service are created per session and does not include any information about you, other than your session key (usually removed as your session ends but sometimes can be kept in your device for no more than 6 months) and the ability to login again quickly. Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience with the Service may be limited.

We use Cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights).

We use the following types of Cookies:
Strictly necessary cookies These are cookies that are required for the operation of our Site and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Site.
Analytical/performance cookies They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies These are used to recognise you when you return to our Site. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region). For instance, the Cookie Consent cookie is used to record a user's cookie preferences.
Social media & advertising cookies These cookies record information such as your visit to our Site, the pages you have visited and the links you have clicked. We will use this information to make our advertising and marketing communications more relevant to your interests. We may also work with advertising networks that gather information about the content on websites and apps you visit, your interests, demographic information about you and information on other websites and services you visit and this is used to show you relevant advertising (including in relation to our services) on other online properties.

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

Except for essential cookies, all cookies used on our site will expire after one week.

You can find more information about the individual cookies we use and the purposes for which we use them here: Cookies Policy

Sharing Information gathered through Service and Site with third parties

We may give your information to:

‍Members of our Group
‍Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy.

Third Parties
‍Our selected third parties may include:

• analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual);
• data processors who process your personal data on our behalf and in accordance with our instructions and applicable data protection law.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this Privacy Statement.
• If Voyant or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Voyant, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where do we store your data?

The information you provide through the Site and the Service is hosted and stored on servers in the European Union.We may transfer personal information to members of our group and selected service providers who perform functions on our behalf outside of the European Economic Area (EEA). Where your information is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your information is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this Privacy Statement.

Your Rights in respect of data of which we are a controller

You have the right under certain circumstances:

• To be provided with a copy of any personal information we hold about you;
• To request the rectification or erasure of your personal information held by us;
• To request that we cease processing your data;
• To request that we restrict the processing of your Personal Information (for example, while we verify or investigate your concerns with this information);
• To request that your Personal Data be transferred to a third party;
• To withdraw your consent to the processing of your Personal Information.

You can also exercise the rights listed above at any time by contacting us at support@planwithvoyant.com.If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

Security and storage of information

We take a great care in implementing, enforcing and maintaining the security of the Service, Site and your personal information. Voyant implements, enforces and maintains security policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data and monitor compliance of such policies on an ongoing basis.

Voyant maintains documentation regarding compliance with the requirements of the law, including without limitation documentation of any known breaches and holds reasonable insurance policies in connection with data security.

Voyant aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. Voyant only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Statement.

Questions and contact information