Advizmo Privacy Policy
Introduction
This Privacy Policy describes how Advizmo collects, uses, shares, and protects personal information of users of the Advizmo mobile application and related services. Our business model is based on subscription and advisory fee revenue, and we do not sell personal information to third parties. By using Advizmo, you agree to the data practices described in this Policy.
Advizmo offers two distinct services:
Platform Services: Financial technology tools including cash flow analysis, expense tracking, account aggregation, and spending insights. These are non-advisory services.
Investment Advisory Services: SEC-registered investment advisory services for automated portfolio management through Interactive Brokers LLC. These services involve managing your investment accounts and are subject to additional agreements and disclosures.
This Privacy Policy applies to both Platform Services and Investment Advisory Services.
Our Privacy Commitment: Key Points
No Selling Your Data: We will not sell your personal information to third parties.
Subscription-Based Business: Our business model is based on subscription revenue, not advertising. We rely on your subscriptions to provide our Services.
Minimal Data Collection: We collect only the information necessary to deliver excellent financial management services.
Third-Party Sharing Limitations: We only share your data with third parties when necessary to provide our services.
Privacy Rights: We respect your privacy rights and offer clear ways to access, correct, or delete your data.
Data Retention: We retain account data for up to 12 months after subscription expiration unless you delete your account sooner.
1. Information Collection
1.1 Profile and Contact Information
We collect personal information you provide, such as your name, email address, phone number, and financial preferences when you create an account or use certain features of the App.
1.2 Financial Information
Platform Services: With your explicit consent, we collect information from your connected financial institutions (banks, credit cards, etc.) including transaction details and account balances for financial analysis and insights.
Investment Advisory Services: If you use our investment advisory services, we access your brokerage account information at Interactive Brokers LLC, including portfolio holdings, transactions, account values, and tax lot information to provide automated portfolio management.
Security: Your banking login information is never viewed or stored by Advizmo. All financial information is encrypted in transit using TLS 1.3 and at rest using AES-256.
1.3 Technical Information
We collect information about your device (type, operating system, identifiers), your IP address, usage data, and other technical information when you use the App.
1.4 Cookies and Tracking Technologies
We use cookies, web beacons, and similar technologies to collect information about your interactions with the App and to personalize your experience. You can manage cookie preferences through your browser settings or our Cookie Preferences center.
2. How We Use Your Information
2.1 Service Provision and Improvement
We use collected information to provide financial insights, budgeting tools, and recommendations. We also use this information to improve our services and develop new features.
2.2 Personalization
We may use your information to tailor content, offers, and user experience to your preferences.
2.3 Communication
We may use your information to communicate about your account, App updates, security alerts, and promotional offers (which you can opt out of).
2.4 Analytics
We aggregate and anonymize data for analytics and statistical purposes, which helps us understand how users interact with our services.
2.5 Legal Compliance
We may use and disclose information as required by applicable laws, regulations, legal processes, or government requests.
Investment Advisory Compliance: As an SEC-registered investment adviser, we are required to maintain certain records about your investment advisory relationship, including account opening documents, investment recommendations, and communications. These records are maintained in accordance with SEC recordkeeping requirements under the Investment Advisers Act of 1940.
3. Information Sharing Practices
3.1 Service Providers
We share information with trusted third-party service providers who help us operate and enhance Advizmo. These providers are authorized to use your information only as necessary to perform services on our behalf.
Investment Advisory Services: For investment advisory clients, we share information with:
Interactive Brokers LLC (custodian and broker-dealer) to execute trades and maintain your investment account
Portfolio management systems and tax optimization software necessary to provide investment advisory services
3.2 Financial Institutions
With your consent, we use Plaid Inc. to securely connect to your financial institutions and retrieve account data (such as balances, transactions, and account ownership information) necessary to provide our services. When you connect an account, you authorize Plaid to collect this data on our behalf. Plaid's collection, use, and disclosure of your information is governed by Plaid's End User Privacy Policy at plaid.com/legal. We do not receive or store your bank login credentials.
3.3 Business Transfers
If Advizmo is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.
3.4 Anonymized Data
We may share aggregated, anonymized data that cannot identify you personally with third parties for research, analytics, or marketing purposes.
3.5 Legal Requirements
We may disclose information to comply with laws, regulations, legal processes, or to protect rights, property, safety, and prevent fraud.
4. Security and Data Protection
4.1 Security Measures
We implement appropriate technical and organizational safeguards to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These safeguards include industry-standard encryption, access controls, and regular security assessments.
4.2 Encryption Practices
We use TLS 1.3 to protect data in transit and AES-256 to protect data at rest.
4.3 Data Storage
Your information is stored in secure cloud infrastructure with the following characteristics:
Primary data storage is in SOC 2 Type II certified data centers located in the United States
Data is replicated across multiple geographic locations for reliability, but remains within the United States
We maintain logical separation between customer data to prevent unauthorized cross-account access
Our storage systems are monitored 24/7 for unauthorized access attempts
We implement multiple layers of redundancy to protect against data loss
4.4 Your Role in Security
We encourage you to protect your personal information by using strong passwords and keeping login credentials confidential.
4.5 Security Policy
For more information about our security practices, please visit our Security Policy.
4.6 Notice of Security Incidents
If we determine that there has been unauthorized access to or use of your sensitive personal information that is reasonably likely to result in substantial harm or inconvenience, we will notify you no later than 30 days after we become aware of the incident, in accordance with SEC Regulation S-P (as amended in 2024) and applicable state breach notification laws. Notice may be delayed only where a law enforcement agency determines in writing that immediate notice would interfere with a criminal investigation.
5. Data Retention and Deletion
5.1 Retention Periods
Platform Services Data: We retain platform account data for up to 12 months after your subscription expires unless you delete your account sooner.
Investment Advisory Data: As an SEC-registered investment adviser, we are required to retain certain investment advisory records for at least 5 years from the end of the fiscal year in which the last entry was made, with the first 2 years in an easily accessible location. These records include:
Investment advisory agreements
Account opening documents
Trade confirmations and statements
Communications related to investment recommendations
Fee billing records
Different types of data may have different retention periods:
Transaction data: Retained for 24 months (platform) or 5+ years (advisory)
Account login information: Retained for the duration of your account plus 12 months
Customer service communications: Retained for 18 months (platform) or 5+ years if advisory-related
Marketing preferences: Retained for the duration of your account plus 6 months
5.2 Deletion Process
When you request deletion of your account, we follow these procedures:
Initial deletion request triggers an immediate process to remove your account from active systems
Your data is marked for deletion and removed from user-accessible systems within 30 days
Complete deletion from all primary systems occurs within 90 days of your request
We use secure deletion methods that prevent recovery of the information
5.3 Backup Handling
Your data may persist in encrypted backups for a limited time after deletion:
Backups are maintained for disaster recovery purposes for up to 180 days
As backup archives expire, your deleted data is permanently removed
Backups are encrypted and access is strictly controlled
In the event of a backup restoration, previously deleted data will be re-deleted
5.4 Post-Deletion Practices
After deletion, we may retain your email address to confirm deletion of associated data and to prevent fraudulent account creation.
5.5 Legal Requirements
We may retain information as necessary to comply with legal obligations or in connection with legal proceedings.
SEC Recordkeeping: Investment advisory records are retained for at least 5 years as required by SEC regulations, even if you request account deletion. This includes investment advisory agreements, portfolio management records, and fee-related documentation.
When retention is required for legal or regulatory purposes, we implement additional access controls to ensure this data is only accessible for the required legal purpose.
6. Your Privacy Rights and Choices
6.1 Access and Management
You can update and manage your account information through the App settings.
6.2 Opt-Out Options
You may opt out of marketing communications through unsubscribe links or preference settings in the App.
6.3 Account Deletion
You may cancel your account at any time through the Settings page or by contacting support@advizmo.com.
6.4 Additional Privacy Rights
Depending on your jurisdiction, you may have rights to:
Access or receive a copy of your personal information
Correct inaccurate information
Delete certain personal information
Receive information about how we collect, use, and share your data
6.5 Exercising Your Rights
To exercise these rights, contact us at privacy@advizmo.com.
6.6 Authorized Representatives
You may authorize an agent to exercise privacy rights on your behalf with proper documentation.
6.7 Appeals Process
If we deny your privacy request, you can appeal by emailing privacy@advizmo.com with the subject "Privacy Request Appeal."
7. Advertising and Cross Context Behavioral Advertising
7.1 No Sale of Personal Information
Advizmo does not sell your personal information to third parties. Our business model is subscription based, not advertising based.
7.2 No Cross Context Behavioral Advertising
Advizmo does not share your personal information with third parties for cross context behavioral advertising as that term is defined under the California Consumer Privacy Act and similar state laws. The Advizmo mobile application does not display third party advertisements.
7.3 Browser Signals
Advizmo honors legally recognized browser based opt out preference signals such as Global Privacy Control in accordance with applicable law. Because Advizmo does not sell or share personal information for cross context behavioral advertising, these signals do not change our underlying data practices. They are acknowledged and logged for transparency.
7.4 Changes to Advertising Practices
If Advizmo ever begins to sell personal information or share it for cross context behavioral advertising, Advizmo will update this Privacy Policy and provide a clear opt out mechanism before any such sharing begins.
7.5 California Residents and Other Privacy Rights
California residents and residents of other states with applicable privacy laws retain the rights described in Section 6 Your Privacy Rights and Choices, including the right to access, correct, and delete personal information. To exercise these rights, contact privacy@advizmo.com.
8. Special Provisions
8.1 Financial Incentives
We may offer incentive programs (like rewards for surveys) that involve personal information. Participation is voluntary and subject to program-specific terms.
8.2 Children's Privacy
Our services are intended only for individuals who are at least 18 years old. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will delete it promptly. If you believe we may have collected such information, please contact us at privacy@advizmo.com.
8.3 Third-Party Links
Our App may contain links to third-party websites not covered by this Privacy Policy. Review their privacy policies before providing information.
8.4 International Data Transfers
We operate from the United States. If you're located elsewhere, your information will be transferred to and processed in the U.S.
8.5 State-Specific Privacy Rights
Depending on your state of residence, you may have additional privacy rights under state law, including under the California Consumer Privacy Act (CCPA / CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Texas Data Privacy and Security Act (TDPSA), and similar laws in other states. These rights may include the right to access, correct, delete, or receive a portable copy of your personal information, and the right to opt out of certain processing activities such as targeted advertising or sales.
To exercise any of these rights, contact privacy@advizmo.com. We will respond to verifiable requests within the time frames required by applicable law.
Certain financial information we collect is exempt from these state privacy laws to the extent it is regulated under the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act.
9. Policy Updates and Contact Information
9.1 Policy Changes
We may update this Privacy Policy periodically and will notify you of material changes through the App or other channels.
9.2 Contact Us
If you have questions about this Privacy Policy, please contact us at privacy@advizmo.com.
By using Advizmo, you acknowledge that you have read and understood this Privacy Policy and consent to our data practices as described herein.
10. Regulation S-P Privacy Notice for Advisory Clients
This section satisfies our obligation under Regulation S-P (17 CFR Part 248) to provide an annual privacy notice to clients of our SEC-registered investment advisory services.
10.1 Information We Collect
In connection with providing investment advisory services, we collect nonpublic personal information about you from the following sources.
Information you provide on applications and other forms (such as name, address, Social Security number, date of birth, employment information, financial goals, risk tolerance, and investment objectives).
Information about your transactions with us, our affiliates, or others (such as account balances, holdings, and trading activity).
Information from your custodian, Interactive Brokers LLC (IBKR), and from connected financial institutions through our aggregation partner.
Information from consumer reporting agencies and identity verification providers as needed for account opening and anti-money-laundering compliance.
10.2 Information We Disclose
We do not sell your nonpublic personal information. We disclose nonpublic personal information only as permitted by law, including the following.
To Interactive Brokers LLC, our custodian and broker-dealer, to open accounts, execute trades, and maintain records.
To service providers who help us operate our advisory services (including portfolio management, tax optimization, account aggregation, identity verification, and cloud infrastructure providers) under written contracts that restrict their use of your information to the services they provide on our behalf.
To regulators, examiners, auditors, and law enforcement as required by law or in response to lawful requests.
In connection with a merger, acquisition, financing, or sale of all or substantially all of our assets, subject to confidentiality obligations.
10.3 Information We Disclose to Affiliates
TalkAboutHealth, Inc. DBA Advizmo currently has no affiliates within the meaning of Regulation S-P. If we add affiliates in the future, we will update this notice and provide opt-out rights where required by law.
10.4 Information We Disclose to Nonaffiliated Third Parties
We do not disclose your nonpublic personal information to nonaffiliated third parties for marketing purposes. Because we do not engage in this type of disclosure, no opt-out is required under Regulation S-P. We will provide you with a revised privacy notice and an opportunity to opt out before changing this practice.
10.5 Confidentiality and Security
We restrict access to your nonpublic personal information to employees and service providers who need the information to provide services to you or to comply with legal obligations. We maintain physical, electronic, and procedural safeguards designed to protect your nonpublic personal information, including those described in our Security Policy.
10.6 Information About Former Clients
We continue to apply this Privacy Notice to your nonpublic personal information after the end of our advisory relationship for as long as we retain that information.
10.7 Annual Notice
We deliver this Privacy Notice at the time you become an advisory client and at least annually thereafter. The most current version is always available at advizmo.com/privacy.
10.8 Notice of Data Breach
Consistent with the Securities and Exchange Commission amendments to Regulation S-P adopted in 2024, we will notify affected individuals of any unauthorized access to or use of their sensitive customer information that is reasonably likely to result in substantial harm or inconvenience, no later than 30 days after we become aware of the incident, except where a longer period is necessary as determined by law enforcement.
10.9 Questions
For questions about this Privacy Notice or to request a paper copy, contact us at privacy@advizmo.com.