Privacy policy
Welcome to Retirement Loan Protection! As a retirement plan participant in a plan that has elected to offer Retirement Loan Protection, certain information about you will be shared between your retirement plan service provider and Custodia Financial, LLC. We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Custodia Financial, LLC collects when operating the Retirement Loan Protection service, which includes the Retirement Loan Protection website (www.custodiafinancial.com). Privacy is important to Retirement Loan Protection. If you have any questions, please send us a note at support@custodiafinancial.com.
SUMMARY
- Information that we collect from you:
- We collect device-related information, server log information, and other types of anonymous information when you visit Retirement Loan Protection.
- Additionally, we collect and store personal information from your retirement plan service provider and when you log in and use your Retirement Loan Protection customer account. The types of personal information we collect and share depend on the relationship that your retirement plan service provider has with us and on whether you have elected to opt out of Retirement Loan Protection.
- Why we collect your personal information:
- We serve as the administrator of the Retirement Loan Protection program for our customers, and we need certain information in order to administer the program.
- We use your personal information to maintain your account, provide customer service, and enhance your customer experience.
- We use aggregate personal information and non-personal information to improve Retirement Loan Protection and monitor and protect the security of our service.
- Who we share your personal information with:
- We do not sell, rent, or trade your personal information with any third parties except as provided in this privacy policy, with your consent, or as required by law.
- Your choices as a consumer:
- In order to administer Retirement Loan Protection and provide loan protection, we require certain personal information. Most of this information is obtained by us through our relationship with your retirement plan service provider. Your use of the Retirement Loan Protection website is optional.
HOW YOU ACCEPT THIS POLICY
By using the Retirement Loan Protection service, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this Privacy Policy.
INFORMATION WE COLLECT AND WHY
In order to provide a high-quality service, Retirement Loan Protection collects various types of information when you visit the website or when your retirement plan elects to offer the Retirement Loan Protection program.
As a Visitor
We collect various types of anonymous information about visitors to Retirement Loan Protection, such as device-related information (browser type, IP address) and server log information (date and time of day of your visit). We also collect information that you input into our website. We use this information to better understand our visitors and our business, to provide the services you request, and to enhance the Retirement Loan Protection service.
As a Customer
When your retirement plan chooses to offer Retirement Loan Protection, we will collect certain personal information, including your full legal name, social security number, email address, permanent address, and date of birth. This information is shared with us by your retirement plan service provider. In order to provide loan protection, we will also collect information about your employment status and any loans that you may take from your retirement plan.
We may also collect various other types of personal information if you use the site. Further, we may collect personal information if you contact us or otherwise give it to us (e.g., in an email).
Cookies & Pixels
Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.
We use these technologies in order to customize Retirement Loan Protection and improve your experience with the site. Cookies store anonymous information, such as whether you viewed the site from your mobile device.
Cookies are required for site functionality. Refusing to accept cookies or pixels will make Retirement Loan Protection inoperable for certain functions.
Analytics Services
We use analytics tools such as “Google Analytics” (collectively referred to as “Analytics Services”) to collect information about the usage of this site. These analytics services collect information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We only use the information we get from these Analytics Services to improve this site.
These Analytics Services only collect the IP address assigned to you on the date you visit this site, not your name or other identifying information. We do not combine the information collected through the use of these Analytics Services with personally identifiable information. The Analytics Services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on here.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information to administer the Retirement Loan Protection program, enhance your customer experience, operate and maintain your account in accordance with US law, investigate and understand how Retirement Loan Protection is used, monitor and protect the security and integrity of Retirement Loan Protection, and better market and advertise Retirement Loan Protection’s services.
As part of this process, we may from time-to-time aggregate some of your personal information in certain data analysis, reports, or other interpretations of retirement-related trends for both internal and external purposes. When aggregating personal information, we make sure that the information is not identifiable to any particular customer.
WHEN WE SHARE YOUR INFORMATION
We do not sell, rent, or trade your personal information with any third parties except as provided in this privacy policy, with your consent, or as required by law.
In order to provide loan protection services, we may share your personal information with third parties, such as consumer identification verification services and insurance firms with which we have a relationship, for the purpose of serving you as a customer. We have entered into agreements that require that these third parties keep this information confidential.
We also may disclose some of the personal information we collect to service providers, companies that perform marketing and analytics services on our behalf, or to other financial institutions.
We may disclose personal information in response to service of legal process, such as a court order, summons, subpoenas, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use or customer agreements.
Last, we may disclose personal information with your consent.
Information about our users, including personal information, may be disclosed or transferred to entities now or in the future affiliated with Retirement Loan Protection or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any entity receiving it.
CHILDREN
Our service is not directed towards anyone under 18 unless they are eligible to take a loan under their retirement plan covered by RLP. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Retirement Loan Protection and/or provided us with personally identifiable information, please contact us at support@custodiafinancial.com. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will advise the retirement plan, which has the right to terminate his or her account.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION THAT WE HAVE COLLECTED
Once you have registered with Custodia Financial, you can access your profile, review the information that is stored, and in some cases, revise that information. If you have any problems, you may also contact us at support@custodiafinancial.com. Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of six years.
PROTECTION OF PERSONAL INFORMATION
Custodia Financial works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use strong browser encryption, store our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access, and we require third parties who perform services for Retirement Loan Protection to agree to keep your information confidential. Furthermore, if you choose to opt out of protection or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here.
ONLINE TRACKING
Online tracking is the collection of data about an individual’s internet activity used to deliver targeted advertisements and for other purposes.
CHANGES TO THE POLICY
We may modify this privacy policy over time. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. If the changes are significant, Retirement Loan Protection will do our best to notify you via email or through a notification on the site. Please check the effective date below to determine if there have been any changes since you have last reviewed the Retirement Loan Protection privacy policy.
YOUR RIGHTS AS A CALIFORNIA RESIDENT
Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at support@custodiafinancial.com. Your request should specify your full name and the email address you used when submitting personal information to us.
YOUR RIGHTS AS A VERMONT RESIDENT
We do not share nonpublic personal financial information we collect about Vermont residents with non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us at support@custodiafinancial.com. Please note, however, that we will not be able to provide you with services through Retirement Loan Protection without the ability to share this financial information.
INTERNATIONAL VISITORS
This service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this Privacy Policy.
OPT-OUT NOTICE
If you would like to opt out of any of the above, please contact support@custodiafinancial.com
QUESTIONS
If you have any questions about this privacy policy, please contact us at:
Custodia Financial, LLC
17855 Dallas Parkway
Suite 100
Dallas, TX 75287
Tel: 214.393.3511
EFFECTIVE DATE: October 18, 2023
