Privacy Policy

Effective Date: December 31, 2019

Returso (" Company ") is committed to protecting your privacy. We have prepared this Privacy Policy to describe our practices with respect to personal data (as defined below) that we collect from users of our website, located at www.returso.com (the " Site ") and related services ( collectively, " Services ").

1. USER CONSENT. By submitting personal data through our Site and Services, you agree to the terms of this Privacy Policy and expressly consent to the processing of your personal data in accordance with this Privacy Policy.

2. A NOTE ON CHILDREN.We do not intentionally collect personal data about visitors under the age of 13.

3. A NOTE TO USERS OUTSIDE THE UNITED STATES. Your personal data may be processed in the country in which it was collected and in other countries, including the United States, where the laws regarding the processing of personal data may be less stringent than the laws of your country. BY USING OUR SITE OR SUBMITTING PERSONAL DATA THROUGH OUR SITE OR SERVICES, YOU EXPRESSLY AGREE TO THE PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY.

4. TYPES OF DATA WE COLLECT.
Personal data you provide to us. We collect personal data from you when you voluntarily provide it on the Site.You may provide your name, phone number, email address, zip code, marital status, financial goals, family income, home ownership status, details about your family, Twitter account, Facebook profile, and other details that we can send. You may also provide information in response to our surveys,

Personal Data collected through technology. To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect personal data from you, including your IP address or HTTP referrer.We also use cookies (as defined below) and browsing data such as Uniform Resource Locators (URLs) to collect information about the date and time of your visit and the solutions and information you searched for and viewed. Like most Internet services, we automatically collect this personal data and store it in log files whenever you visit our website or access your account on our network.
We may use session cookies (which expire once you close your web browser) and persistent cookies (which remain on your computer until you delete them) to provide you with a more personal and interactive experience on our website. Persistent cookies can be removed by following the instructions in the Internet browser's help file. If you choose to disable cookies, some areas of our website may not function properly. We have also enabled Google Analytics features, including demographic and interest reporting, to collect the demographic information provided by these features. You can opt out of Google Analytics for display advertising and personalize ads on the Google Display Network by changing your Google ad settings.

Returso is a member of the Digital Advertising Alliance (DAA) self-regulatory program and adheres to the DAA Self-Regulatory Principles for Online Behavioral Advertising. We work with a variety of advertisers, ad networks, and analytics companies ("Advertising Partners") that collect information about your use of our services. You can opt out of interest-based advertising at any time by visiting the Digital Advertising Alliance's consumer choice page.

Our relationship with social networking sites.We have created, and may offer you, interfaces that allow you to connect with social networking websites such as Facebook and Twitter ("SN Sites") through our Site. We will work with the SN Site's application protocol interface (better known as your developer API) in a way that allows you to authorize us to access your account on that SN Site on your behalf. To provide this authorization, you will not provide us with your username or password for the SN Site, but you will need to log in to that SN Site directly through our Site. Once authorized by you, the SN Site will provide us with a token that will allow the SN Site to recognize us when we request, on your behalf, access to your account information or to post information.

 

5. USE OF YOUR DATA.

General use. In general, the personal data you submit to us is used to respond to requests you make or to help us provide you with a better service. The company uses your personal data in the following ways:

  • Provide you with the Services and customer support;
  • Respond to your requests, resolve disputes and/or solve problems;
  • Verify compliance with your obligations in our Terms of Use or other policies;
  • Improve the quality of the Site and the Services;
  • Communicate with you about the Site and the Services;
  • Market our Services (and those of third parties) that we think may be of interest to you. If you prefer that we not send you these messages, please see the section below on YOUR CHOICES REGARDING YOUR PERSONAL DATA to learn how to opt-out.

Compliance and Protection. We may use your personal information to:
 

  • Comply with applicable laws, legal requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • Protect our rights, privacy, safety or property, yours or others (including when making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern the Site and the Services; Y
  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyber-attacks and identity theft.


Creation of Anonymous Data. We may create anonymous data records from personal data by excluding information (such as your name) that makes the data personally identifiable. We use this Anonymous Data to analyze request and usage patterns so that we can improve the content of our Products and services and enhance site navigation. The Company reserves the right to use and disclose Anonymous Data to Third Party Companies at its discretion.

Commentary.If you provide us with feedback on the Site or Services, we may use such feedback for any purpose, as long as we do not associate such feedback with your personal data. The Company will collect any information contained in such communication and will treat the personal data in such communication in accordance with this Privacy Policy.

6. DISCLOSURE OF YOUR PERSONAL DATA.

affiliates . Although we currently do not have a parent company, subsidiaries, joint ventures or other companies under common control (collectively, "Affiliates"), we may have it in the future. We may share some or all of your personal data with these Affiliates, in which case we will require our Affiliates to abide by this Privacy Policy. If another company acquires the Company or our assets, that company will own the personal data collected by it and by us and will assume the rights and obligations with respect to your personal data as described in this Privacy Policy.

Disclosure to Third Party Service Providers. We may share your personal data with third party service providers to facilitate account creation or to provide us with services that allow us to make the Site or Services available to you.

Disclosure to SmartAdvisor Marketplace and Marketing Participants.We may share Adviser Match Form intake data with relevant financial adviser matches who meet the entry criteria and actively participate in the SmartAdvisor platform. The terms and conditions allow those advisers to contact you with the information you have provided.

Other disclosures.Regardless of the choices you make with respect to your personal data (as described below), Company may disclose personal data if it believes in good faith that such disclosure is necessary to: (a) comply with applicable laws or to respond to subpoenas or court orders filed on Company; or (b) protect or defend the rights or property of Company or users of the Products or related services.

7. THIRD PARTIES.

Personal and/or Anonymous Data Collected by Third Parties. We may receive Personal and/or Anonymous Data about you from other sources, such as by telephone or fax, or from companies that provide our Services through a co-branded or private-labeled website or companies that offer their products and/or services on our website ("Third Party Companies"). Our third party companies may provide us with personal data, such as your email address, to help us establish the account. We may add this information to the information we have already collected from you through our website to improve the Services we provide.

Our provision of a link to any other website or location, such as payment processing websites, is for your convenience and does not signify our endorsement of such other website or location or its content. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect personal data or anonymous data from you.

We have no control over, do not review, and cannot be responsible for these external websites or their content. Please note that the terms of this Privacy Policy do not apply to these external websites or content, or to any data collection after you click on links to such external websites.

NOTICE TO CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83).

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHICH THEY HAVE ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY OR HOUSEHOLD PURPOSES (A "CALIFORNIA CUSTOMER"), MAY REQUEST INFORMATION REGARDING WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THIRD PARTY DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIVING A REQUEST FROM A CALIFORNIA CUSTOMER, THE BUSINESS MUST PROVIDE A LIST OF ALL THIRD PARTIES TO WHICH PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED.

8. YOUR OPTIONS REGARDING YOUR PERSONAL DATA.

Elections.. We offer you choices regarding the collection, use and sharing of your personal data. We will periodically send you free newsletters and emails that directly promote the use of our site or the purchase of our Services and may contain advertisements from Third Party Companies. When you receive newsletters or promotional communications from us, you can indicate your preference to stop receiving further communications from us and you will have the opportunity to "unsubscribe" by following the unsubscribe instructions provided in the email you receive or by contacting us. directly (see contact information below). If you decide to opt out of receiving future mailings,

Changes in Personal Data. You can ask us to delete your personal data, but please note that we may be required (by law or otherwise) to retain this information and not delete it (or to retain this information for a certain time, in which case we will comply with your deletion request only after we have complied with such requirements). When we delete any information, it will be removed from the active database, but may remain in our files.

9. JOB APPLICANTS.When you visit the careers section of our Sites, we collect the information you provide us in connection with your job application. This includes business and personal contact information, professional skills and credentials, educational and employment history, and other information of the type that might be included on a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process job applications, for example, by evaluating a candidate for a job activity and by monitoring recruitment statistics. We may also use this information to operate and improve the Services, and as necessary for compliance, fraud prevention, and security purposes.

10. SECURITY OF YOUR PERSONAL DATA. The company is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. Despite these measures, you should be aware that the Company cannot fully eliminate security risks associated with personal data and errors may occur.

11. CONTACT INFORMATION. The company welcomes your comments or questions regarding this Privacy Policy. Send us an email at [email protected] or contact us at the following address:

. 12. DISPUTE RESOLUTION.If you believe that the Company has not adhered to this Statement, please contact the Company by email at [email protected] . We will do our best to address your concerns. If you believe your complaint has been incompletely addressed, we invite you to notify us for further investigation.

13. CHANGES TO THIS PRIVACY POLICY.This Privacy Policy is subject to revision from time to time, and if we make any material changes to the way we use your personal data, we will notify you by sending you an email at the last email address you provided to us and/or by posting prominently. notice of the changes on our website. Any material changes to this Privacy Policy will be effective thirty (30) calendar days after we send you notice by email or thirty (30) calendar days after we post notice of the changes on our site, The thing that happens first. These changes will be effective immediately for new users of our website, Products or related services. Please note that at all times you are responsible for updating your personal data to provide us with your most recent email address. In the event that the last email address you provided to us is invalid, or for any reason unable to provide you with the notice described above, our sending of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any case, changes to this Privacy Policy may affect our use of personal data that you provided to us before we notified you of the changes. If you do not wish to allow changes to our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Your continued use of our website, Products or related services, following notice of such changes, will indicate your acknowledgment of such changes and your agreement to be bound by the terms and conditions of such changes. Our sending of the email containing such notice will, however, constitute effective notice of the changes described in the notice. In any case, changes to this Privacy Policy may affect our use of personal data that you provided to us before we notified you of the changes. If you do not wish to allow changes to our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Your continued use of our website, related Products or services, upon notification of such changes, you will indicate your acknowledgment of such changes and your agreement to be bound by the terms and conditions of such changes. Our sending of the email containing such notice will, however, constitute effective notice of the changes described in the notice. In any case, changes to this Privacy Policy may affect our use of personal data that you provided to us before we notified you of the changes. If you do not wish to allow changes to our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Your continued use of our website, Products or related services, following notice of such changes, will indicate your acknowledgment of such changes and your agreement to be bound by the terms and conditions of such changes. Changes to this Privacy Policy may affect our use of personal data you provided to us before we notified you of the changes. If you do not wish to allow changes to our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Your continued use of our website, Products or related services, following notice of such changes, will indicate your acknowledgment of such changes and your agreement to be bound by the terms and conditions of such changes. Changes to this Privacy Policy may affect our use of personal data you provided to us before we notified you of the changes. If you do not wish to allow changes to our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Your continued use of our website, Products or related services, following notice of such changes, will indicate your acknowledgment of such changes and your agreement to be bound by the terms and conditions of such changes.

14. NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (" CCPA ") requires us to provide California residents with an explanation of how we collect, use, and share their personal information, and of their rights and choices. that we offer to California. residents regarding our handling of your personal information. CCPA Scope and Exclusions. The description of our Privacy Practices and Privacy Rights in this Notice applies only to California residents whose interactions with Returso are limited to:

  • By visiting our website,
  • Sign up to receive email alerts,
  • Comment or contribute in our forums, or
  • Apply for our job postings on our websites (however, the CCPA does not extend privacy rights to job applicants).



The CCPA's description of our privacy practices and privacy rights do not apply to personal information we collect, use, or disclose about:
 

  • Consumers who start or complete the application process for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act ("GLBA") and implementing regulations, or the California Financial Information Privacy Act ("FIPA"), and
  • Representatives of companies seeking to obtain our Services, or provide us with their products or services.


Privacy Practices. We do not sell personal information. As we explain in our Privacy Policy :

  • We use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you want to know how you can opt out of our (and our third-party advertising partners') use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-Out Guide .
  • Through our services, for example, by inquiring about hiring a financial advisor, you direct us to disclose your information to companies that provide the services in which you are interested.


Please note that we may also disclose personal information to comply with the law and for compliance, fraud prevention and security purposes; in case of business transfers; and to our professional advisors, as described above in the Privacy Policy.

The CCPA gives individuals the following rights:

  • Information. You can request information about how we collected, used, and shared your personal information over the past 12 months.
  • Access. You may request a copy of the personal information we maintain about you.
  • Suppression. You can ask us to delete the personal information we collect or maintain about you.


Please note that the CCPA limits these rights, for example, by prohibiting us from providing certain sensitive information in response to an access request and by limiting the circumstances in which we must comply with a deletion request. We will also respond to information and access requests only to the extent that we can with reasonable effort associate the information we maintain with the identifying details you provide in your request. If we deny your request, we will tell you our decision.
You have the right to exercise the rights described above without discrimination.

How to submit a request. To request access or deletion of personal information:

Identity verification. The CCPA requires that we verify the identity of the person submitting a request to access or delete personal information before providing a substantive response to the request.
Authorized Agents. California residents may authorize an "authorized agent" to file applications on their behalf. We will require that the authorized agent have a written authorization confirming that authority.

Online Tracking Opt-Out Guide

Like many online businesses, we use services provided by Google, Facebook, and other companies that use tracking technology. These services rely on tracking technologies, such as cookies and web beacons, to collect information directly from your device about your browsing activities, your interactions with the websites, and the device you are using to connect to the Internet. There are several ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

  • Cookie blocking in your browser. Most browsers allow you to delete or reject cookies, including those used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org .
  • Blocking the use of advertising IDs in the settings of your mobile device. Your mobile device settings may provide functionality to limit the use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • Use of privacy or browser plug-ins. You can prevent our websites from setting cookies used for interest-based ads by using a browser with privacy features, such as Brave , or by installing browser plug-ins such as Privacy Badger , Ghostery , or uBlock Origin , and setting them to block third-party cookies/trackers. .
  • Platform opt-outs. The following advertising partners offer opt-out features that allow you to opt out of the use of your information for interest-based advertising:
  • Advertising industry opt-out tools. You can also use these opt-out options to limit the use of your information for interest-based advertising by participating companies:

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