Privacy Policy

Last updated: April 15, 2024

Your privacy is important to us. This Privacy Policy (“Policy”) explains how Human Interest Inc. Human Interest Advisors LLC and Human Interest Personal LLC (collectively referred to as “Human Interest”, “we” or “us”) collect, share, use, and protect information when you interact with us through any websites, applications, promotions, products, or services we offer (collectively, “Services”). By visiting our websites and using any of those Services, you agree to this Policy.

As you review our policy, here are a few general principles to keep in mind:

  • We collect information to serve current, prospective, and former retirement plan sponsors (“Customers”) and retirement plan participants (“Participants”), and to support and grow our business. We do not sell or share your personal information to third parties in exchange for money or other valuable consideration. Personal information is information collected or maintained for business purposes by which an individual can be identified.

  • Our online Services are intended for a U.S. audience. 

  • Our online services are not intended for children under age 16. We do not knowingly collect information from children under age 16. 

  • If you are a U.S. consumer and have a financial product or service with us, we will collect information from or about you in accordance with this policy and our U.S. Consumer Privacy Notice.

  • Depending on applicable state law, including California, you may be entitled to additional data privacy rights and privileges.

Certain provisions of this policy may or may not apply to you depending on how you interact with us. For example, the information we collect may depend on whether you are a Customer, Participant, or a website visitor. We may update this Policy from time to time. We encourage you to review our Policy periodically to stay informed about our data protection practices and how you can help protect your privacy.

1. Information we collect

We collect personal information to provide our Services, including to maintain user accounts, to process transactions, to respond to inquiries, to develop and offer Services, to operate and grow our business, and to fulfill legal and regulatory requirements. What we collect depends on how you interact with us and the information you share with us. 

Information we collect from you or a Customer may include:

  • Account information. When you maintain an account with us as a user, we collect contact and identifying information about you, such as your name, address, phone number, mailing address, email, social security number, date of birth, employment information, income information, tax information, and device information (e.g., to receive multi-factor authentication). The information you provide may include your drivers’ license, social security number, and geolocation information.

  • Financial information. In order to process transactions for your account, we may collect financial information, including bank or financial account numbers and/or balance and past transactions with us or our partners and vendors.

  • Information about your employees and vendors. We may collect information about your employees and vendors, including the categories of account information identified above, information from and regarding your vendors (e.g., payroll vendors) and payment instructions.

  • Audio and Visual Information. We may collect video or voice recordings of you for quality assurance purposes when you communicate with our customer service team. We may also display live or prerecorded videos or similar audio-visual materials (“Videos”). We may collect personal information with respect to you requesting access to, and/or accessing, such Videos, and we may disclose such personal information to third parties, including to our third-party service providers through the use of cookies. The provision of Videos on our Site is not an admission by the Company, and it shall not otherwise be interpreted, in any form or manner, to mean that the Company is a “video tape service provider” for purposes of the Video Privacy Protection Act (“VPPA”) or that the Company is otherwise subject to the VPPA.  By requesting access to or otherwise accessing our Videos, you acknowledge and agree that Human Interest may, through the use of cookies and similar online tracking technologies, collect personal information with respect to you requesting access to, or accessing, Videos, and such personal information may include (i) identifiers that can be used to recognize you or the device you use to access our website, overtime and across different services, such as a device identifier, IP address, mobile ad identifiers, and similar data, (ii) the Videos you accessed or to which you requested access, and the nature, scope, and duration of such access, and (iii) identifiers associated with your social media account, or similar online accounts. We may, in our sole discretion, disclose personal information that we collect from you with respect to you requesting access to, or accessing, Videos to our partners, affiliates, and service providers, such as social media partners, to assist with the operability and functionality of our websites, to help us improve our websites, products, and services, and to facilitate or assist with our marketing and advertising campaigns. You acknowledge and agree that you may prevent us from collecting and disclosing personal information from you with respect to you requesting access to, or accessing, Videos by changing settings in your web browser. Exercising this option may prevent the deployment of cookies and similar online tracking technologies that are used to collect, process, and disclose your personal information in connection with the Videos you are requesting access to or otherwise accessing. 

  • Marketing. We may collect information you provide voluntarily in connection with participating in marketing, including when you participate in events, promotions, surveys, and referrals.

  • Device Information. We collect information about devices when you use our Services. The device information may include IP addresses, hardware models, operating system information, unique device identifiers and other technical information, browser and storage tokens, web beacons, geolocation, and third-party cookies and similar technologies (e.g., web beacons, pixels). 

  • Information from third parties. We may collect information about you from other individuals and entities such as payroll providers, financial advisors, referral sources and programs, and Customers. For example, you may express an interest to a third party in enrolling in a retirement plan for your company, and that party may share information with us so you can learn more about our Services. We may also receive information about you when you use social networks, for example, when you “Like” a post on Facebook or follow us on X or LinkedIn. Cybersecurity and anti-fraud providers may provide information about you for fraud detection and security purposes. We may also collect information about current and prospective customers from publicly or commercially available services, including lead generation services, providers of customer and lead data, and marketing partners. 

Customers may choose to use our Services to process some of their company’s data, including personal information. The information we receive from customers enables us to provide Services to Participants. We process this information through our Services on our customers’ behalf. Our privacy practices governing the processing of such data will be in accordance with this policy and our agreements with customers. 

If you have any questions or concerns about how such information is handled, you should contact the person or entity who has contracted with us to use our retirement Services to process your data.

2. How we collect personal information

Depending on how you interact with us and the Services you receive from us, your personal information may be collected from the following sources:

  • From you or your representative when you provide us with information when you use our site, including when you create an online account on the site, purchase or use our Services, interact with customer support, provide information about your financial planning or retirement goals, complete applications or forms for products or Services, or otherwise communicate with us.

  • From you, your employer, or plan sponsor when sharing information with us for recordkeeping and/or employee benefits advisory Services (for example, payroll information).

  • From a third-party referral source who indicates you may be interested in our Services.

  • From you when you engage in transactional activity in your account that is recorded (for example, trading history and balances).

  • From you when you contact us or interact with Human Interest (for example, when you talk to our customer service team over the phone or electronically or when you enter information into our website).

  • We may obtain information from other third-party sources (for example, to verify your identity and to better understand your product and service needs). We may obtain personal information from your (or your employer’s) payroll provider, if Human Interest has an active integration with that payroll provider.

  • Other sources may provide information to us with the consent of you or your representative (for example, if you roll over an account from another institution to Human Interest).

  • Automatically when you visit our site or interact with our Services, for example, through cookies, pixels, and similar technologies, and by logging activity on the Services.

3. How we use personal information

Human Interest uses the information we collect for purposes of:

  • Providing our Services to you;

  • Analyzing and improving the performance of our Services;

  • Keeping you informed of other possible products and/or Services that may be available to you from Human Interest;

  • Completing surveys and/or research questionnaires related to your opinion of current or potential future Services that may be offered;

  • Providing you with customized site content, targeted offers, and advertising on the Services or on other websites, mobile applications, social media, or online Services;

  • Measuring ad quality and responses, and for internal business analysis or other business purpose; 

  • Directing communications and target offers to people whose interests or characteristics are similar to yours;

  • Using or creating aggregate information that doesn’t identify you and cannot reasonably be used to identify you for analytical, demographic, and other purposes;

  • Protecting the security and integrity of the site and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hacks and other unauthorized users; and

  • Other purposes disclosed at the time you provide your information or otherwise with your consent.

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Services, as well as information collected offline, across other computers or devices that you may use, and from third party sources (including payroll providers). We may de-identify or anonymize personal information we collect for business and marketing purposes. We may also use information about you as required or permitted by law, including for compliance with laws and regulations.

4. How we share personal information

We do not share or sell personal information to unaffiliated third parties in exchange for payment or monetary benefits. Personal information collected may be shared for purposes such as:

  • Affiliates. We may share your information between Human Interest affiliates and subsidiaries (e.g., Human Interest Inc., Human Interest Advisors LLC, Human Interest Personal, LLC) for business, operational, promotional and marketing purposes, as permitted by law. As our Services expand, we may add additional corporate affiliates with whom information may be shared.

  • Select Third Parties. If you indicate an interest in using a product, service, or offering that is administered by a third party, we may share information with that party connection with your interest.

  • Managing retirement plans. We may share your information as necessary to manage our Services, including retirement plan services, with Customer representatives and with their third party administrators, advisors, service providers (including payroll providers), and other third parties engaged by Customers.

  • Service Providers. We may share your information with accounting, legal, security and fraud prevention compliance, recordkeeping, banking, advertising, technology, or custodial partners and other similar service providers (“Service Providers”) as needed for those providers to carry out their work for us. Our service providers are required to implement reasonable privacy and information protection controls.

  • Legal Matters; Safety and Security. We may access and disclose your information to respond to legal process, including subpoenas and other lawful demands for information; in connection with an investigation on matters related to public safety, as permitted by law; or otherwise as required by law. We may disclose your information to protect the security of our Services. We also may disclose your information if we believe that there has been a violation of our terms of service, any other legal document or contract related to our Services, or the rights of us or any third party. We may make disclosures as described herein as we, in our sole discretion, believe to be necessary or appropriate to ensure the security of our Services or to respond to claims and legal process.

  • Sale or Transfer of Business or Assets. We may sell or purchase assets during the normal course of our business. If another entity acquires us or seeks to acquire all or part of our business, or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.

  • Aggregate or Anonymous Non-Personal Information. We may also share aggregate, anonymous, or de-identified non-personal information with third parties.

  • Other. We also may share your information as disclosed to you at the time of collection, with your consent, or at your request.

5. Your digital privacy

When you use our websites and online Services or communicate with us electronically, we or our service providers may automatically collect technical and navigational location information such as device type, browser type, IP address, pages visited, and time spent. We use this information to maintain the security of your session, to facilitate site navigation, to improve design and functionality of our digital offerings, and to personalize your experience.

Cookies and similar technologies

Human Interest and our service providers may use cookies and similar technologies (“cookies”) to operate our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor’s device. Cookies help us collect information about users of our digital offerings, including the date and time of visits, pages viewed, amount of time spent, or general information about the device used for access. Cookies may also be used for security purposes and to personalize your experience. Other types of tracking technologies (i.e., web beacons, pixels, clear gifs, and other similar technologies) work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our sites. Accordingly, Cookies and Other Tracking Technologies allow our Sites to recognize your device and track your activities and preferences, thereby allowing you to navigate between pages efficiently and to generally improve the user experience.

Non-Cookie Technologies. We may deploy on our website certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs.  These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see https://thenai.org/wp-content/uploads/2021/07/NAI_BeyondCookies_NL.pdf. 

Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies, it may negatively impact your experience as you interact with us online, as some features and Services may not work properly.

To understand your choices for receiving and opting out of targeted advertising provided on the Services or across other websites and online Services, please review the information below:

  • To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info. 

  • To opt out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit http://optout.networkadvertising.org.

  • To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices. 

  • If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available https://tools.google.com/dlpage/gaoptout/.

  • On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

We permit website visitors to automatically exercise their right to opt-out of this sale or sharing of this personal information through the use of the Global Privacy Control signal without having to make individualized opt-out requests. If you've enabled the GPC signal in your browser, we will honor your request to opt-out of this sale or sharing of personal information as communicated via the GPC signal. These opt-outs are specific to the device or browser you’re using. You'll need to opt out again if you visit our applicable websites from a different device or browser, change your browser settings, or clear your cookies. We recognize GPC signals in a frictionless manner, meaning we do not charge you a fee, do not change your experience, and do not display any content (e.g., a pop up) in response to your opt-out preference signal. For more information, visit www.globalprivacycontrol.org.

Note that even if you exercise the choices described above, you may continue to see advertising from us, but it will not be customized based on the personal information that you have opted out of sharing.

6. Unsubscribe from our emails

You can unsubscribe from marketing emails from us.  Any marketing email from us will have an “unsubscribe” link in the email footer. You can also send an email from the address that you wish to unsubscribe, to [email protected].

7. Links to other websites

Our site may contain links to affiliates and other websites. Human Interest does not claim nor accept responsibility for any privacy policies, practices and/or procedures of other such websites. We encourage you to be aware of links that lead to other websites and to read their privacy statements to understand how they collect and use personal information.

For Participants using our Individual Retirement Account Platform, Human Interest has engaged a third party (“IRA Portal Provider”) to administer the web portal for individual retirement accounts (the “IRA Portal”).  The IRA Portal Provider has a terms of service and separate privacy policy, which apply to your use of the IRA Portal.  By accessing the IRA Portal, you acknowledge and agree to comply with the IRA Portal Provider’s terms of service and privacy policy in connection with your use of the IRA Portal.

8. Beacon Bot live chat and web forms

Human Interest’s Beacon Bot uses technology to help with frequently asked questions and to enhance your digital experience. It is designed to be anticipatory and responsive based on the information you provide and other information on file with us. We do not guarantee the accuracy of the responses or alignment of its suggestions with your intended purpose. 

The Beacon Bot is not designed to recommend the purchase or sale of specific securities or digital assets. While it may offer educational information, it does not have the capability to discern what investment choices would be suitable for your personal situation. Any information you provide to the Beacon Bot, as well as all search information entered, may be retained, accessible to Human Interest personnel, and used and shared consistent with our Privacy Policy. Specifically, information you communicate through our Beacon Bot and our web forms is shared with service providers we use to support our technology, and by communicating with our Beacon Bot or completing web forms, you consent to the sharing of this information and monitoring of the communications by third parties. You should not provide the Beacon Bot with account or other confidential information.

9. Your Privacy Rights

Depending on applicable law, you may be entitled the following data privacy rights and privileges:

  • Right to Know. You may have the right to know about what personal information Human Interest collects and processes about you, including the types and categories of personal information we collect and process, the sources of such personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to file complaints and inquiries. 

  • Access Rights. You may have the right to ask us whether we process any of your personal information and, if so, receive access to such personal information. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right.

  • Rectification. You may have the right to have your personal information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include the provision of a supplementary statement.

  • Deletion. You may have the right to have your personal information deleted, which means the deletion of your personal information by us. However, your right to deletion is subject to statutory limits and prerequisites (e.g., where your personal information is no longer necessary in relation to the initial purposes for which it was processed, your personal information was processed unlawfully).

  • Restriction of Processing. You may have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your personal information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal information is contested, but we need time to verify the inaccuracy (if any) of your personal information.

  • Data Portability. You may have the right to request we provide you with your personal information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.

  • Automated Decision Making. You may have the right to object to having us use your personal information to conduct automated decisionmaking. However, Human Interest does not engage in any activity that subjects our customers, website users, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significant results, impacting them.

  • Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal information. However, this will not impact our legal basis to process such personal information prior to the withdrawal of your consent.

  • Do Not Share/Targeted Advertising Rights. You may have the right to opt out from having us disclose your personal information to third parties for targeted advertising purposes. This is sometimes referred to as the right to opt-out of the “sharing” of personal information for cross-contextual behavioral advertising purposes. To prevent your personal information from being used in these circumstances, please enable the Global Privacy Control or email us at [email protected]. 

  • Do Not Sell My Personal Information. You may have the right to opt out from having us sell your personal information to third parties for profit or for monetary or other valuable consideration. However, Human Interest does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information. 

We will facilitate your exercise of the rights that apply to you in accordance with applicable law. If you have questions about your rights or wish to exercise your rights, you can contact us in accordance with the “How to Contact Us” section listed below.

10. Privacy Appeals; Complaints

In certain jurisdictions, you may have the right to appeal a decision Human Interest has made with respect to your privacy request. To submit a privacy rights decision appeal, please email in accordance with the “How to Contact Us” section listed below with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. 

Depending on applicable law, you may have the right to submit a complaint to a data protection authority responsible for overseeing our compliance with data protection law in your jurisdiction. Please see a list of potentially applicable regulatory authorities:

We would, however, appreciate the opportunity to address your concerns, so please feel free to contact us regarding any complaint you may have. We will not discriminate against individuals for exercising their data privacy rights or filing a privacy complaint. 

11. Social Media/Platform Data Rights

We may engage with you on various social media platforms (e.g., Facebook, Twitter, TikTok LinkedIn, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Since certain social media platforms also may automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The sites include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button, and the like) or interactive mini-programs that run on the sites . These features may collect your IP address and which website page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the sites. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

12. California Privacy Notice

The information in this section is provided for purposes related to the California Consumer Privacy Act (“CCPA”), as amended. It applies solely to personal information subject to the CCPA. Information that we collect and maintain to provide financial services is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and not covered by the CCPA.

Categories of personal information we may collect about you

Throughout our Privacy Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we share it. Under the CCPA, we also provide you with the “categories” of personal information we collect and discuss for business purposes, as defined by applicable law. Those categories of personal information are: identifiers (such as your name, address, and email address), commercial information (such as transaction data), financial information (such as financial account information), internet or other network or device activity (such as IP addresses); sensory information (such as when you call our customer service line); professional or employment-related information; legally protected classifications (such as gender and race/ethnicity); inference data about you; and other information that identifies or can be reasonably associated with you. The categories of sensitive personal information are: account log-in information, financial account information, password or other credentials allowing access to your account, Social Security number, and racial and ethnic origin. 

We collected this information in the past 12 months directly from users of our services, from service providers, and from third parties that supplement other personal information we collect, such as parties that provide information about your interests and demographics.

We and our service providers collect and disclose the above categories of personal information for the purposes described in the “How we use personal information” section above, including to provide, analyze, and improve the Services; to personalize content on the site; to inform you of other products or Services that may interest you; and to protect the Services, users, and Human Interest against security threats, fraud, and similar risks.

Finally, in the last 12 months, we disclosed for business purposes the following categories of information from California consumers: identifiers, online activity information, financial information, and commercial information. We disclosed each of these categories of personal information to service providers and affiliates. 

CCPA Exemptions

Please note that certain personal information collected or maintained by Human Interest is excluded from coverage under the CCPA. For example, information that is collected, processed, sold, or disclosed pursuant to the GLBA and implementing regulations, or pursuant to the California Information Privacy Act. Furthermore, under the CCPA, there are a number of situations where a covered business may decline a CCPA request to delete information and may continue to maintain the information. It may be appropriate for Human Interest to retain your personal information if reasonably necessary to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of the covered business’s ongoing business relationship with the consumer, or otherwise perform a contract between Human Interest and the consumer

  • Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes

  • Identify and repair errors that impair existing intended functionality

  • Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided by law

  • To enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer's relationship with the business and compatible with the context in which the consumer provided the information

  • Comply with a legal obligation

Selling and sharing of personal information

Human Interest does not sell or share your personal information in exchange for payment or for any other compensation. 

As stated above, we use third-party cookies and similar technologies for analytics and advertising purposes. We engage third-party service providers, including marketing and advertising providers and social media platforms to personalize your browsing experience on our websites, to provide certain targeted advertising services for us, and to help us measure the effectiveness of our websites and online advertising. We and our providers collect information about website activity, including cookies and similar data stored on or collected from your browser or device. In some cases, our providers may combine this information collected on our websites with information about your activity on other, unaffiliated websites or social media platforms to deliver ads to you when you are visiting other websites or platforms. This sharing of your information with certain third parties via cookies and similar methods, and our providers’ use of certain cookies, may be considered “sharing” of personal information for cross-contextual behavioral advertising under the CCPA. As explained above, you may opt out of this sharing frictionlessly by enabling the Global Privacy Control in browsers you use to visit our website or by emailing us at [email protected].  

Shine the Light

Under California Civil Code Section 1798.83 (also known as the “Shine the Light” law), Human Interest customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties. To make such a request, please submit a request via the methods described in the “How to contact us” section below.

13. Security

Human Interest takes physical, administrative, and technical steps to safeguard the information we collect from and about our customers who use the Services. No one can guarantee that security measures will be effective against all security threats. We encourage users to use unique login credentials on our site and to enable multi-factor authentication.

14. Children under the age of 16

Human Interest does not knowingly collect, sell, or share personally identifiable information from children under the age of 16. If it is determined that such information has been inadvertently collected on anyone under the age of 16, we take immediate steps to delete the information.

15. Retention of personal information

We maintain personal information for as long as reasonably necessary to fulfill the legitimate business purposes for which the information was collected, to meet our legal obligations, or protect or defend our legal rights. 

16. Changes to the Privacy Policy

Human Interest reserves the right to update and/or change the terms of our Privacy Policy to reflect changes in our practices. We will post notice of changes to our Privacy Policy on site (https://humaninterest.com). If we make changes that are material, we will notify you and, where required by applicable law, obtain your consent.

17. How to contact us

If you have any questions or concerns regarding the Privacy Policy related to our website, please feel free to contact us at the following email or telephone number: