This Empower Personal Dashboard Privacy Policy (the “Privacy Policy”) describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information in your use of the Empower Dashboard. Empower Personal Wealth, LLC (“Empower”, “we”, “us” or “our”) is a Delaware corporation and a wholly owned subsidiary of Empower Annuity Insurance Company of America. Together with our Terms of Use, this Privacy Policy governs your use of the Empower Personal Dashboard. Please note that this Privacy Policy pertains only to your use of the Dashboard; Empower maintains a separate policy applicable to its other services and products that may be viewed at: Empower Privacy policy.
Empower is committed to the protection of our Visitors, Users, Cash Customers and Advisory Clients (also referred to as “you” or “your”) privacy. We understand that keeping your information secure and confidential is critical to earning and keeping your trust.
How to Use this Empower Personal Dashboard Privacy Policy
This Privacy Policy governs your use of the Empower Personal Dashboard and describes how we collect and use your Personal Information and how we address other privacy matters & such as deletion of your Personal Information upon request and opting-out of marketing communications. We also describe methods for contacting Empower, if you have privacy questions, comments or feedback.
The information that we collect, and how we use it, depends on your relationship with us and as your relationship evolves with us. This Privacy Policy is organized based on those different types of relationships – Visitors, Users, Cash Customers and Advisory Clients.
- Visitors - Individuals who visit our public website without logging into an account or using our services
- Users - Individuals who establish an account with us or otherwise use our services offerings, including our financial dashboard software
- Cash Customers - Individuals who open a Empower Cash account
- Advisory Clients - Individuals who become clients of our Wealth Management and financial advisory services and establish an Empower managed investment account
You may fall into more than one category concurrently depending on your relationship with us. For example, a Cash Customer may also be a Visitor before they log into their Empower dashboard, wherein they will also be a User.
How We Collect & Use Your Information
“Personal Information” means your personally-identifiable information such as your name, email or mailing address, phone number, account credentials (User id and passwords), social security number, government ID numbers and other information that can be used to identify you personally.
We also collect and use other information that we obtain from your activities using our services. This includes information that you do not explicitly provide to us, but which may be implicitly provided to us as part of such activities. More information on this is provided below under the Visitors use case.
The following describes in further detail the information we collect at various stages of our relationship with you.
Visitors
When you visit any of our websites, including our blog, or download our apps, we consider you a Visitor. This section describes our privacy practices related to this use case.
What do we collect?
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Why do we collect it?
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Can you limit?
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First-Party Cookies
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- To recognize you when you make a return visit and deliver overall a consistent experience
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Most modern browsers allow you to delete or limit cookies.
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Third-Party Tags and Cookies
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- To measure our marketing effectiveness
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Most modern browsers allow you to delete or limit cookies, including third-party cookies; however, you may not be able to limit marketing tags entirely unless you do not visit our sites.
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Internet Protocol (IP) Address
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- As part of the basic function of the internet
- To measure who is visiting us and where they are from
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The only way to avoid this is not visiting our sites.
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Browser Metadata Such as browser type, version, your operating system, system language, etc.
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- As part of the basic function of the internet
- To ensure we maintain a positive website experience for most used browsers
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Browsers communicate this automatically however some third-party extensions may allow you to limit this.
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Survey Responses Such as retirement goals, opinions on market trends and contact information
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- Collect information about our products and services
- Gain insights into financial trends and opinions and conduct anonymized and aggregated research on these trends
- Provide aggregated survey results and promotional offers
- To market our products and services to you
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Yes, answering survey questions is always optional.
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Users
When you register, create a User Account on our Dashboard and begin using our services, we consider you a User. This section describes our privacy practices related to this use case. Keep in mind Users are also considered Visitors, so this section describes information that we collect in addition to what was described for Visitors.
What do we collect?
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Why do we collect it?
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Can you limit?
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Email and Password
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- To establish your account and allow you secure access to it
- Email you about service updates, maintenance activities, security notifications, weekly summaries and other account related information
- Email you about service and/or product offerings, surveys and other marketing promotions
- Allow our Support team to contact you if needed
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No, that is required to have a functioning account.
You can opt out of marketing emails, see the Opt-Out section.
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Phone Number
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- To secure your account with our Multi-Factor Authentication
- To contact you via phone or text message to recommend services and/or product offerings
- Allow our Support or Security team to contact you if needed, at your request
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No, we require this for security purposes. You can, however, request to be placed on our Do Not Call list. See the Opt-Out section.
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[Optional] Financial Planning Information
Includes information you provide about your financial planning goals, such as your age, income, retirement age, retirement plan information, risk tolerance, family information and other demographic or related information. This also includes any other information you provide within your User Account, such as the address of any property you own and the value of any manually entered accounts.
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- Provide you our free retirement planner service and design your personalized retirement plan
- Provide you our free Investment Checkup service and perform an analysis of your investments (or other product features)
- If qualified, provide you with a free financial consultation with one of our investment advisors
- Recommend Empower products and services that may be of interest to you
- Customize your User experience
- Conduct and publish anonymized aggregated research on personal finance trends
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Yes, those are optional services which you are free to use or not use.
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[Optional] Financial Account Information
For third-party financial accounts you link - this includes your account credentials, passwords, security questions, transactions, balances, assets held, statements and other account information.
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- Provide you the holistic view of all of your finances in our Dashboard
- Provide you our free financial planning tools such as our Cash Flow tool, Budget tool and others
- Allow background automatic refreshes of your data so that your Dashboard is always up to date
- Recommend Empower products and services that may be of interest to you
- Customize your User experience
- Conduct and publish anonymized aggregated research on personal finance trends
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Yes, those are optional services which you are free to use or not use.
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[Optional] Postal Code Information
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- To measure the efficacy of our marketing efforts in recommending Empower products and services that may be of interest to you
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Yes, it is optional to input your postal code information.
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Product Use Information
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- Monitor and maintain system performance
- Identify most popular features and inform new features development
- Personalize your experience with Empower
- Recommend Empower products and services
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No, if you are a User we will collect this information.
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Empower Cash Customers
Personal Capital Services Corporation (“PCSC”) manages our Empower Personal Cash program, which provides services to customers who have opened an Empower Personal Cash account. If you are opening a Empower Cash program account, we consider you an Empower Cash Customer. Empower Cash Customers are also considered Users and Visitors and may also be Advisory Clients, so this section describes the information that we collect in addition to what is described in the section for Users and Visitors, respectively. For further privacy information relevant to Cash Customers, please see the Privacy Notice at the end of this document.
What do we collect?
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Why do we collect it?
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Can you limit?
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Detailed Account Information
- Name
- Date of birth
- Social Security Number
- Physical and mailing address
- State ID, driver’s license or passport number
- Citizenship and country of birth
- Income and other financial information
- Occupation
- Contact, account & routing number, titling and fraud information for accounts you want to move funds to or from
- Other required personal information
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- Verify your identity and develop a behavior profile to enable us to better prevent fraud
- Facilitate the opening of a Empower Cash program account, on your behalf, with our selected bank partners
- Enable our bank partners to comply with their customer identification programs to combat money laundering and prevent financial fraud
- Provide ongoing information required to provide continuing services to you
- Recommend Empower products and services that may be of interest to you
- Satisfy legal and regulatory requirements
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Yes, becoming a Empower Cash Customer is entirely voluntary. If you opt to become a Empower Cash Customer, this information is required.
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Advisory Clients
Personal Capital Advisors Corporation (“PCAC”) provides discretionary and non-discretionary investment advisory services to retail investors, and operates as an investment advisor registered with the Securities and Exchange Commission (“the SEC”) under the Investment Advisers Act of 1940, as amended. Any investment advisory services are offered only by PCAC*. *Effective on or around April 3, 2023, PCAC will merge, or will have merged, as applicable, with Empower Advisory Group, LLC (known as “EAG”), an investment adviser registered with the SEC and affiliate of Empower (the “Merger”). Following the Merger, EAG shall be the provider of investment advisory services to PCAC’s Clients (as hereinafter defined). If you are opening a wealth management advisory account with us through the Dashboard and utilizing our fee-based advisory service, we consider you an Advisory Client. Advisory Clients are also considered Users and Visitors and may also be Empower Cash Customers, so this section describes information that we collect in addition to what was described previously, as applicable. For further privacy information relevant to Advisory Clients, please see the Privacy Notice at the end of this document.
As part of our relationship with you as an Advisory Client, we will utilize the information we have on your financial dashboard in order to provide you with our holistic financial advice. We may also, at your request or as appropriate for your situation and needs, recommend third-party services to you.
What do we collect?
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Why do we collect it?
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Can you limit?
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Detailed Account Information
- Name
- Social Security Number
- Mailing address
- Tax planning information
- Transferred securities information such as cost basis
- Your beneficiaries
- Contact information for investment accounts or banks you want to move funds from
- Your investment objectives, if not previously collected
- Other required personal information
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- Opening an account, on your behalf, with an independent securities brokerage trading and clearing custodian account or banking institution
- Enabling us to fund your accounts with your other investments assets or cash
- Providing the independent broker or banking institution with ongoing information required to provide continuing services to you
- Allowing us to perform tax analysis on the movement of assets, if applicable.
- Designing, implementing and managing your investment portfolio strategy
- Providing you with account statements, trade confirmations, tax information and other notifications related to the Advisory Service
- Satisfying legal and regulatory requirements
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Yes, becoming an Advisory Client is entirely voluntary. If you opt to become an Advisory Client, this information is required.
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What Information Do We Share and Why?
Empower’s core business is wealth management. This means that our objective is to win you over as a Empower Advisory Client. We share some information as described in the table below.
Personal Information
Sharing Category
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What do we share and why?
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Our Service Providers
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Like most businesses, we use third-party service providers to deliver some of the services mentioned in this Privacy Policy. In doing so, we provide some of your data (including your Personal Information) to those third-party service providers, on a need to know basis. Our contracts with those service providers require them to safeguard your information and prohibit them from using your data for any purpose other than to provide services to us or to improve their services.
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Empower Cash program account partners
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If you are a Empower Cash Customer, you will own a program account provided through our banking partner and other participating program banks. Our banking partner for our Empower Cash Customer program accounts is UMB Bank, National Association (“UMB”), and we will share Detailed Account Information with UMB. Our contract with UMB requires them to treat your information as confidential information. UMB’s Privacy Policy is available here.
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Identity verification and fraud analysis
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If you are a Empower Cash Customer or an Advisory Client, we will share some of your Personal Information and Detailed Account Information with third-party identity verification providers and fraud analysis partners for the sole purpose of verifying your identity and preventing fraudulent transactions. These providers are required under contract with us to safeguard your information and not provide it to any third parties except as required to provide the services or as otherwise required by law, regulation or by court order.
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Your brokerage account(s)
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If you are an Advisory Client of Empower, you will have a custodial brokerage account to hold your personal portfolio. Our custodial brokerage partner for our Advisory Clients’ accounts is Pershing, and we will share Detailed Advisory Account Information with them. You will have direct visibility, access, and interaction with Pershing while you are a Empower Advisory Client. Pershing’s Privacy Policy is available here.
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Security, Legal & Regulatory Requirements
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We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the services we provide and any facilities or equipment used to make those services available, (v) comply with any law or regulatory requirement, including pursuant to a subpoena, court order or other legal process, or (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
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Anonymized Information
We may use anonymized information that is summarized or derived from information that you provide to us for research, benchmarking and publication. Anonymized information is information that does not include any personally identifiable information and therefore is outside of the terms of this Policy.
Additional Privacy Information and Your Privacy Rights and Resources
Affiliate Use
We may share Personal Information among our affiliated companies for their everyday business purposes to provide services that you have requested. We do not share your Personal Information with affiliates for their marketing purposes. From time to time, we may make you aware of products and services that are available from our affiliates. For a list of the Empower Family of Companies, please see the Privacy Notice at the end of this document.
Our Use of Google Analytics
We use Google Analytics to help us understand how you interact with our website and mobile app, to market our products and services to you, and to improve the User experience. To do this, we share a unique identifier with Google. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see “How Google uses data when you use our partners’ sites or apps” linked here. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On, here.
Our Use of Tags, Pixels, Cookies and Other Trackers
Tags, pixels and cookies are bits of code that we use to gather information to operate and measure engagement with our site. These generally fall into two categories:
- User Experience – Information that helps us determine which features are most popular with our users, provide content and offers that are relevant to a user’s financial situation or site engagement, market our products and services to you, and identify errors or other technical issues on our site; and
- Marketing Attribution – Information that allows us to track the effectiveness of advertising we run on other sites and to manage our affiliate marketing program, as well as to optimize marketing of our services and products. For example, marketing pixels operate by sending a small amount of information when triggered by specific events, such as when a user registers on our site after clicking through a promotional link on another site. To do this, the pixel uses a unique identifier that does not contain personally identifying information to connect that data (user registration) back to the action (clicking on the link).
To implement the features described above, Empower contracts with trusted service providers to place tags, web beacons, cookies, and similar technologies on the Empower site and applications, which collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. These service providers are prohibited from using any Personal Information they collect on our behalf for any purpose other than providing services to Empower. Some of our service providers are members of the Network Advertising Initiative, an AdTech self-regulatory organization. You may learn more about the Network Advertising Initiative and the opt-out of interest-based advertising that they offer by visiting http://www.networkadvertising.org/managing/opt_out.asp and following the opt-out instructions therein.
How to Request Deletion of the Personal Information We Collect
Empower allows you to delete your Dashboard account. You can consult our support article for instructions on how to do so. We will retain information on deleted accounts as required for legal, regulatory and security purposes. If you use other services from Empower or its affiliates, deleting your Dashboard account will not terminate or delete your account with respect to those other services.
Opt-out Information
If you request to be added to our opt-out lists from our communications activities arising from your use of the Dashboard, we will keep your Personal Information on those Opt-out lists until you request to be removed from such lists. We allow you to opt-out of the following:
- Promotional or Product Notification emails - see reference
- Advisor phone calls - notify your advisor at the time of the call to place you on the do not call list or reach out to our support team at donotcall-epw@empower.com.
- Physical Mailings - send your request to our support team at support-epw@empower.com to be added to the opt-out list
- Short Message Service (SMS) Messages - Empower supports industry standards for SMS Opt-out such as replying with “STOP” to opt-out of those messages.
For opt-out requests, please find contact information under “Privacy Questions, Comments or Feedback?” below.
How We Respond to “Do Not Track” Signals
Some modern web browsers have the ability to activate a “Do Not Track” signal. At this time, Empower does not respond to “Do Not Track” signals as it does not engage in activities that require a response to such signals.
Email Records
Empower currently keeps business records, including emails you send to us that constitute business records, for a minimum of five (5) years or for any time period required to meet our regulatory requirements.
Data Residency
Our services and data are primarily hosted in the United States and are intended for individuals located within the United States.
US State Residents Privacy Notices
To exercise any of your rights described below, please find contact information under “Privacy Questions, Comments or Feedback?” below.
Nevada Residents
We are providing you this notice under Nevada state law. You may be placed on our internal Do Not Call List by contacting us.
In addition to contacting us, Nevada residents can contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, in writing at 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; by calling (702) 486-3132; or by emailing: BCPINFO@ag.state.nv.us.
Vermont Residents
Under Vermont law, we will not share any Personal Information we collect about Vermont residents with third parties, unless the law allows.
California Residents
For a full description of your rights as a California resident under the California Consumer Privacy Act (“CCPA”), as amended, please see our California Privacy Policy in Appendix A.
Virginia Residents
For a full description of your rights as a Virginia resident under the Virginia Consumer Data Protection Act (“VCDPA”), please see our Virginia Privacy Policy in Appendix B.
Protecting Children’s Privacy Online
Empower is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our websites or applications. We do not knowingly collect information from children under 13 without parental consent. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website.
Modifications to our Privacy Policy
We change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy Policy, and we will post the revised document on our website, currently located at https://www.empower.com/hpc/privacy-policy.
When changes to this Privacy Policy are material, we will provide notice to Empower Cash Customers and Advisory Clients. Notice may be sent by email or by posting notice of changes in your account.
Privacy Questions, Comments or Feedback?
Please contact us*
Requests or comments
To submit privacy-related questions, requests, or comments, please call our toll-free number at 855-756-4738 or send us an email at Privacymatters@empower.com Please do not put any confidential or personal account information in an email request.
In addition, you may contact us by mail to the address below:
Empower
Attn: Chief Privacy Officer
8525 E Orchard Rd, 2T3
Greenwood Village, CO 80111
*Note that the Privacy Team may not respond to automated requests or other requests that do not appear to be legitimate in nature.
Last updated February 15, 2023
PRIVACY NOTICE APPLICABLE TO ADVISORY CLIENTS AND CASH CUSTOMERS FOLLOWS BELOW:
PRIVACY NOTICE
REV 2/2023
FACTS
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What does Empower Retirement, LLC (Empower) do with your personal information?
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WHY?
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Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.
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WHAT?
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The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social Security number and account balances.
- Retirement assets and transaction history.
- Employment information and income.
When you are no longer our customer, we continue to share your information as described in this notice.
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HOW?
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All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Empower chooses to share and whether you can limit this sharing.
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REASONS WE CAN SHARE YOUR PERSONAL INFORMATION
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DOES EMPOWER SHARE?
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CAN YOU LIMIT THIS SHARING?
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For our everyday business purposes —
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
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Yes
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No
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For our marketing purposes —
to offer our products and services to you
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Yes
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No
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For joint marketing with other financial companies
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No
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We don’t share
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For our affiliates’ everyday business purposes — information about your transactions and experiences
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Yes
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No
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For our affiliates’ everyday business purposes — information about your creditworthiness
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No
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We don’t share
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For nonaffiliates to market to you
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No
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We don’t share
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QUESTIONS?
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Call toll-free at 855-756-4738 or go to empower.com/privacy
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