Family Retirement Services operates the https://frsinvestmentadvisors.com website, which provides the SERVICE.

1.0 About this Privacy Policy; Other Terms

FRS Investment Advisors, LLC(“the Company,” “We,” “Our,” or “Us”). The following additional terms, policies, and rules are expressly incorporated herein and form a binding part of this Agreement as if reproduced fully herein:

This Privacy Policy, and its associated notices and disclosures, are incorporated into, and are subject to, Our Global Terms of Use. Unless otherwise defined in this Policy, all capitalized terms have the meaning given in the Global Terms of Use.

Your data security is extremely important to Us. We take significant technical and organizational measures to protect the personal information (“Personal Information”) of Our visitors, Users, and Subscribers (“You,” or “Your”). Accordingly, We provide this privacy policy (“Privacy Policy,” or “Policy”) to inform You about Our data practices, the kinds of information that We collect, and how We intend to use and share (collectively, “Process”) that information. This Privacy Policy applies to Personal Information that is Processed by the Company in the course of Our business, including via Your use of the Services. The Company and Our employees are expected to protect Your data and adhere to this Privacy Policy.

Your use of the Services and any Personal Information that You provide through the Services are subject at all times to this Privacy Policy, the Global Terms of Use and any regional disclosures relevant to the place where You access the Services. Customers in California should refer to Section 8.2 of this Policy. Customers in the greater European Economic Area (EEA+) should refer to Section 8.3 of this Policy.

BY ACCESSING, BROWSING, OR USING ANY OF THE SERVICES THAT WE PROVIDE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY, AND THAT YOU EXPRESSLY CONSENT TO THE PROCESSING DESCRIBED IN THIS POLICY. IF YOU CHOOSE TO MAKE ANY OF YOUR PERSONAL INFORMATION OR OTHER INFORMATION PUBLICLY AVAILABLE VIA THE SERVICES, YOU ACKNOWLEDGE THAT YOU DO SO AT YOUR OWN RISK.

2.0 Personal Information We Collect and How We Use It

Our privacy practices and the Personal Information that We collect directly from You or from third-party service providers (a “Third Party” or “Third Parties”) depend on Your relationship with Us and any applicable laws and regulations. In this section, We describe some of the ways that We collect and use Personal Information and the legal bases for doing so. We endeavor to collect only the limited amount of information that is relevant for the purposes of Processing as described in this Policy and its related policies as noted in Section 1.0.

2.1 How We Collect Personal Information

The data that We collect from or about You may include Personal Information, such as Your name, email address, user name, Internet Protocol (“IP”) address. Some of the ways that We Process Your Personal Information may include:

• Processing Personal Information from You when You visit or engage with Sites, Apps, Services, surveys, business or marketing events, and any occasion when We deliver programs and Services to You;
• providing opportunities for You to sign up to receive specific information or Services wherein We may ask for Your contact information (e.g. name and email address) so that We can fulfill Your request;
• Processing certain technical information, including, but not limited to, navigational data, the name of the domain and host from which You access the Internet, the browser software You use and Your operating system, and the date and time You access the Services, in order to provide improved Services administration, to improve the quality of Your experience when interacting with the Services, and to display interest-based ads for products and services that might be of interest to You; and/or
• Processing credit card and other financial information related to payments for commercial goods and Services that We provide to You at Your request.

2.2 Information We Collect from Third-Party Sources

We may Process supplemental information about You from Third Parties in order to verify the information that You have provided to Us and to enhance Our ability to provide You with customer support and information about Our businesses, products and Services. We may also occasionally offer optional Service features by means of a Third Party application or service. We may receive information about You from these Third Parties if You choose to accept such offers.

2.3 How We Use Your Personal Information

Depending on how You use the Services, We and Our Third Party service providers may also use Your Personal Information in certain other limited ways, including:

• Providing Information and Services that You Requested. We may use the Personal Information about You to provide You with information that You request (such as information about a product or service). We may also use Your Personal Information to deliver specific programs or services to You, including: (a) managing Your account information and settings; (b) responding to Your questions, comments and requests (e.g. customer support requests and legal requests); (c) providing access to certain areas and features; and (d) permitting You to register for, and participate in, online and in-person events.   
• Administrative Purposes. We may use the Personal Information about You for administrative purposes, including, without limitation, to: (a) measure Your interest in Our Sites, Apps, programs or Services; (b) perform internal quality control; (c) verify Your identity; (d) send You communications regarding the Sites, Apps, programs, Services, Your Account(s) and/or Subscription, or any changes to any Company policy, terms, or agreement; (e) process payments; (f) prevent prohibited or illegal activities; and (g) enforce Our Global Terms of Use, this Policy, and other related policies.
• Marketing Products and Services. We may use the Personal Information about You to provide You with materials about offers, products, and Services. We may provide You with these materials by notification via the Services, postal mail, email, or other electronic notification as permitted by applicable laws. We may work with Third Parties to provide You with interest-based ads through the automatic collection of Personal Information (e.g. cookies). You can opt out of marketing communications at any time by clicking the unsubscribe link in any unsolicited communication from Us, or by contacting us through the Privacy Rights Request form.
• Research and Development. We may use Your Personal Information to create non-identifiable anonymous, or pseudonymous, information that We may use, alone or in the aggregate, along with information obtained from other sources, in order to help Us to optimally deliver Our existing products and services or develop new products, processes and services.
• Information Submitted Via the Services. You agree that We are free to use the content of any communications or other information submitted by You via the Sites, Apps, or Services, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services. You understand that We will not release Your name or otherwise publicize the fact that You submitted materials or other information to Us unless: (a) You grant Us permission to do so; (b) We first send notice to You that the materials or other information You submit to a particular part of a site will be published or otherwise used with Your name on it; or (c) We are required to do so by law.
• Surveys. We may occasionally engage Third Parties to conduct voluntary surveys on Our behalf. Responses may be utilized to determine the effectiveness of the Services, the Company’s communications, advertising campaigns, and/or promotional activities. If You participate in a survey, the information given will be used along with that of other study participants. The information collected will be used to help Us to learn more about Your needs and the quality of the products and services that We provide to You. We may occasionally share pseudonymized, anonymized, and/or aggregated data to Third Parties for research and analysis purposes.
• Sharing Content with Friends or Colleagues. We may offer various tools and functionality that will allow You to forward or share certain content. Email addresses that You provide will be used to forward or share the content, and will not be collected or otherwise used by the Company or any other Third Parties for any other purpose.
• Pseudonymous and Anonymous Data. Including as described in Section 2.8, We may use and share Your pseudonymized, anonymized, or aggregated information within the Company or with Third Parties for research, analytics and any other legally permissible purposes.
• Fraud protection. We may use Your Personal Information in order to prevent fraud and to protect the accuracy and integrity of financial transactions made throughout the Services. We may share the Personal Information with Third Parties for such a purpose.
• Other Uses. We may use Personal Information for other purposes for which We have a legitimate interest, such as direct marketing, individual or market research, or any other purpose disclosed to You at the time You provide Personal Information or else with Your consent.

2.4 How We Use the Personal (Human Resource) Information of Employees

The Company collects Personal Information from current, prospective, and former employees, their emergency contacts, and their beneficiaries as necessary (“Human Resources Data”). Certain sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave, are collected only where allowed by law and are used and disclosed only to fulfill legal requirements unless the employee provides consent for such collection or disclosure. We Process Your Human Resources Data only for Our business purposes. Such uses include:

• assessing qualifications for particular jobs and tasks;
• personnel administration, including benefits, communications, activities, and amenities;
• compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
• compliance with applicable statutory and regulatory requirements;
• conducting performance reviews;
• determining eligibility for initial employment, including the verification of references and qualifications;
• grievance management;
• establishing contacts in the event of an emergency;
• internal or external audits of the Company;
• processing of employee expenses and travel charges;
• providing remote helpdesk and IT support services;
• workflow management, assigning, managing and administering projects.

The uses provided are not all-inclusive, and We also may collect similar or related information consistent with local laws and regulations, with notice provided or posted as consistent with applicable laws. To the extent allowed by law, employees can request access to correct, amend, or delete Personal Information by contacting the Company via the contact information in Section 10.

2.5 Direct Mail, Email and Outbound Telemarketing

We may periodically send You information about Us, Our business partners, and/or upcoming special offers and events whenever You provide Us with Personal Information, or whenever We obtain Your Personal Information from Third Parties. You may decline these communications by following the instructions in Section 3.1.

2.6 Cookies, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on Our Sites, Apps, and Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information about You when You access the Services by means of a computer, tablet, mobile phone, or other device (“Device”).

• Cookies are small text files placed in Your Device’s browser to store Your preferences. For information on how to accept or reject cookies (including Third Party cookies) please click the “Cookie Preferences” link in the footer of the Sites. If You do not allow Our Service’s cookies, then the Sites may not work properly.
• A pixel tag (or web beacon) is a piece of code embedded on a Site page that collects information about Your engagement on that page.
• We use Google Analytics to collect information regarding visitor behavior and visitor demographics on some of Our Services. These data are not tied to any Personal Information. For more information about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by Your use of the Services at http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use certain Technologies that are necessary to operate Our Services; that are required to identify irregular Service behavior, prevent fraudulent activity and improve security; or that allow You to access and make use of Our Services.
• Performance Related. We may use certain Technologies to assess the performance of Our Services, including as part of Our analysis of the way You use the Sites and Apps, to determine if You have interacted with Our messaging, to determine whether You have viewed an item or link, or to improve Our Services.
• Functionality Related. We may use certain Technologies to offer You enhanced functionality when accessing or using Our Services. This may include identifying You when You sign into Our sites or keeping track of Your specific preferences, interests, or past items viewed so that We may enhance the presentation of content to You on Our sites.
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to Your interests, on Our Services or on Third Party sites. This includes using technologies to understand the usefulness to You of the advertisements and content that has been delivered to You, such as whether You have clicked on an advertisement.

If You would like to opt-out of the Technologies, You may do so by blocking, deleting, or disabling them as Your browser or device permits. Visit https://optout.networkadvertising.org/ to learn more about opting out of interest-based advertising.

2.7 Mobile Devices and Apps

Our mobile Apps will occasionally collect Personal Information (e.g. the type of mobile device and operating system that You are using, Your App settings, etc.) as You use them. We use this information to provide You with customer support, to improve Our Apps and Services, to develop new Apps and Services, and as otherwise described in this Privacy Policy or in other notices that We may occasionally provide.

2.8 Anonymous, Pseudonymous, and Aggregated Information

We may use Your Personal Information and other information about You to create anonymized, pseudonymized, and/or aggregated (“De-identified”) data. De-identified data designed to prevent anyone from identifying You and is generally not considered to be Personal Information. We may use De-identified data for research, analysis, analytics, and any other legally permissible purposes. We may share De-identified information within the Company and with Third Parties for Our or their purposes.

3.0 How to Opt Out of Certain Uses of Your Personal Information

You may opt out of Our Processing of Your Personal Information by contacting Us. You must provide adequate information necessary for Us to identify You and Your account. We may contact You in order to complete Your request. Complete removal of Your Personal Information will result in the removal of Your ability to access and use the Services.

Before We use Your Personal Information for any new purpose not previously authorized by You, We will provide information regarding the new purpose and give You the opportunity to opt out.

We will endeavor to obtain Your explicit consent (opt-in) in areas where such consent is required by law prior to disclosing Your Personal Information to a Third Party, or Processing Your Personal Information for a purpose other than its original purpose or the purpose subsequently authorized by You.

3.1 Email and Telephone Communications

We place an “Unsubscribe” link within the body of Our unsolicited marketing or informational emails so that You can opt-out of future communications. We may continue to send You emails about Your purchases and transactions, or support-related emails related to pending or previous support tickets that You have filed with Us. You will not be able to opt-out of emails that We are statutorily required to send You (e.g., notification of updates to this Privacy Policy), unless You completely sever Your relationship with Us.

3.2 Human Resources Data

We will use any Personal Information that We receive in connection with the employment relationship only for employment-related purposes as more fully described in section 2.4. If We intend to use this Personal Information for any other purpose, We will provide the employee with an opportunity to opt-out of such uses. 

3.3 The “Do Not Track” Browser Setting

Do Not Track (“DNT”) is a non-standard privacy feature found in certain legacy web browsers. Since most modern browsers offer better security features by default, Our Sites do not recognize, or respond to, legacy DNT signals. Instead, new Users will be prompted to set cookie and privacy preferences.

4.0 Information We Share

We do not sell, share, or otherwise disclose Personal Information about You, except when You allow Us to do so, or as otherwise described in this Privacy Policy. We endeavor to require Third Parties to which We disclose Personal Information to protect it using substantially similar standards to those required by Us (and at least the same level of privacy protection as is required applicable laws), and to notify Us if they make a determination they can no longer meet this obligation.  

4.1 Information We Share with Service Providers

We may share Personal Information with Third Parties that perform certain services on Our behalf including (i) provision of Information Technology (IT) and related services; (ii) provision of information and services You have requested; (iii) payment processing; (iv) fraud prevention; and (v) customer service activities. Payment information will be used and shared only to process Your order and may be stored by a Third Party for purposes of fraud prevention and future orders. We have executed appropriate contracts with the service providers that prohibit them from using or sharing Your Personal Information except as necessary to perform the contracted services on Our behalf or to comply with applicable laws.

4.2 Information We Share with Third Party Features

We may offer features that allow You to access or share content with Third Party social media websites and apps, discussion boards, blogs, wikis, and other Third Party services.. We will only share with the Third Party whatever limited Personal Information is necessary in order to enable the feature You choose for as long as You use the Third Party feature. We will tell You what information the Third Party may receive before You are provided with an option to share it. Please be aware that any information You provide to a Third Party will be subject to that Third Party’s privacy policy. You can opt-out of Third Party features at any time.

If You use a Third Party resource through one of Our Services, We may collect Personal Information so that We can provide You with access to Services offered either by Us or a Third Party; and We may be able to access any information that You make public through the Third Party resource (such as Your username, comments, posts and contacts) and any other information that You permit Us to access. Please carefully consider what Personal Information You share with others when using Third Party resources.

4.3 Information We Share with Business Partners

We may share Personal Information with Our business partners, and affiliates for Our and Our affiliates’ internal business purposes, or to provide You with a product or service that You have requested. We may also provide Personal Information to business partners with whom We may jointly offer products or services, or whose products or services We believe may be of interest to You. In such cases, Our business partner’s name will appear conspicuously along with Ours. We execute appropriate contracts with Our affiliates and business partners in order to maintain the confidentiality and security of any Personal Information they maintain on Our behalf, and to restrict its use to the purpose for which it was provided. 

4.4 Information Disclosed for Our Protection and the Protection of Others

We may disclose information about You: (i) if We are required to do so by law, court order, or another sufficient legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Our policies or contracts; (v) to collect amounts owed to Us; (vi) when We believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if We, in good faith, believe that disclosure is otherwise necessary or advisable. Server log data containing IP addresses may be shared with law enforcement bodies, pursuant to judicial order or subpoena, in order that they may identify users in connection with their investigation of illegal activities. We reserve the right to refuse to share Your Personal Information with any Third Party if We determine that sharing such information could be unlawfully harmful to You.

4.5 Information Disclosed in Connection with Business Transactions

We reserve the right to disclose or transfer Your information in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of Our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, We will endeavor to direct the transferee to use Your Personal Information in a manner that is consistent with this Privacy Policy.

4.6 Cross-border Data Transfers

Personal Information that We send or collect may be stored anywhere in the world, including but not limited to Our servers, the servers of Our affiliates, and the servers of Our service providers in the United States and European Union. By providing information to Us, You consent to the storage of Your Personal Information in these locations.

5.0 Your Privacy Rights

You may confirm whether We are Processing Your Personal Information, request access to Your Personal Information, and ask that We correct, amend, or delete Your Personal Information. Where otherwise permitted by applicable laws, You may use any of the methods set out in this Privacy Policy to request access to, receive (port), restrict Processing, seek rectification or request erasure of the Personal Information about You that We hold. Such requests will be processed in line with Your local laws to the extent possible by this Privacy Policy.

We will make every good faith effort to provide You with access to Your Personal Information, but there may be circumstances under which We are unable to provide access, including but not limited to: (i) where the information contains legal privilege; (ii) would compromise others’ privacy or other legitimate rights; (iii) where the burden or expense of providing access would be disproportionate to the risks to Your privacy. If We determine that access should be restricted in any particular instance, We will provide You with an explanation of why that determination has been made and a contact point for any further inquiries. To protect Your privacy, We will take commercially reasonable steps to verify Your identity before granting access to or making any changes to Your Personal Information.

6.0 Data Retention

We retain the Personal Information that We receive as described in this Privacy Policy for as long as You use Our Services or as necessary to fulfill the purpose(s) for which it was collected, provide Our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce Our agreements, and comply with applicable laws.

7.0 Data Security

While We employ various technical and organizational measures to protect Your Personal Information, We cannot ensure or warrant the security of any information You transmit to Us, and You do so at Your own risk. You are responsible for maintaining the secrecy of Your own passwords. If You have reason to believe that Your passwords and/or Personal Information are no longer secure, please promptly notify Us.

8.0 Other Rights; Important Information

8.1 Information Regarding Minors

Due to the nature of Our business, services and benefits are not marketed to persons less than 13 years of age, and in certain jurisdictions under the age of 18 (collectively “Minor” or “Minors”). If You are a Minor, then You may not use or access the Services at any time or in any manner without authorization. You may not use or access the Services at all if You are less than 13 years of age. We do not knowingly collect or maintain Personal Information from Minors under 13. If We learn that Personal Information of Minors has been collected on or through any of Our Services, then We will take the appropriate steps to delete the information. If You are the parent or legal guardian of a Minor who has joined and/or Subscribed to any of the Services, then please contact Us to have the Minor’s account terminated and information deleted.

8.2 United States Privacy Rights

We comply with all privacy laws within the United States to the extent possible for businesses operating in the State of California. California law entitles California residents to ask Us for a notice describing what categories of Personal Information We collect, from what sources, for what purpose and with whom We share such information. California law also provides California residents with rights to request access to and deletion of certain personal information, to know whether personal information is shared, and to opt out of the “sale” of personal information. To understand how We honor these California rights, to make requests regarding these rights, and to learn more about how California law defines Personal Information, please review the Privacy Notice for California Residents.

8.3 EEA+ Disclosures

We comply with all applicable laws in the European Union and the greater European Economic Area (“EEA+”). Disclosures for the EEA+ region.

8.4 Links to Third-Party Websites

Our Services may contain links to Third Party websites that are not owned or operated by Us. Third Party websites and privacy practices may differ from Ours, and We do not endorse or make any representations about Third Party websites. Any Personal Information You choose to give to unrelated Third Parties is not covered by this Privacy Policy. We encourage You to review all relevant privacy policies before providing Your Personal Information to anyone. Some Third Parties may choose to share their users’ Personal Information with Us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

9.0 Changes to the Privacy Policy

We may occasionally update this Privacy Policy. If We make material changes to this Privacy Policy, We will notify You by email or as otherwise required by applicable laws. We encourage You to review this Privacy Policy periodically to remain informed as to how We are using and protecting Your information and to keep Yourself aware of any changes to the Policy. Changes to this Privacy Policy will take effect immediately. You can determine when We last changed this Policy by referring to the “LAST UPDATED” legend above.  Your use of the Site following changes to this Policy will constitute Your acceptance of those changes; provided, however, any material change to this Policy shall not apply retroactively to any claim or dispute between You and Us in connection with this Policy that arose prior to the “LAST UPDATED” date applicable to that version of this Policy. This Policy may not reflect pending or recent legislation.

10.0 How to Contact Us

We welcome Your questions about Our Privacy Policy and practices by email. We respond to all inquiries within 30 days. If You are a citizen of the EU, UK, or Switzerland, and feel that We are not abiding by the terms of this Privacy Policy, please contact Us at the contact information provided above. If any request remains unresolved, You may contact the national data protection authority for Your EU Member State.