Privacy Management

Effective September 2019

Protecting your privacy is fundamental to the way Goldleaf Partners, part of FuturePlan by Ascensus® (hereinafter “Goldleaf”) and its affiliated companies (“Goldleaf”, “we,” or “us”) conducts business. The purpose of this webpage is to inform you how we collect, use, and share the personal information we collect about you from your use of our (i) websites; (ii) mobile apps, if applicable; (iii) products and/or services (collectively, the “Services”); or (iv) when you otherwise interact with us or receive a communication from us.

Our Information Collecting Practices

For detailed information regarding our collection of personal information (i.e., Why we collect it; How we use it; and Your options for limiting our receipt of such personal information) please see our full Goldleaf Partners Privacy Policy.

Additional Protections

Goldleaf complies with all applicable federal regulations related to the handling and processing of your personal information. In addition to these laws, some states provide its residents additional protections and rights regarding our use of personal information. To learn more about your state’s additional privacy rights, if applicable, please review the section below titled, State Privacy Rights.

Note that we never sell your personal information. We also do not share your personal information unless permitted or required by law or contract.

Contact Directory

Goldleaf appreciates your business and strives to provide an enhanced customer service experience. For general questions, please see the information below:

Contacting us
Goldleaf Partners
8009 34th Ave S., Suite 320
Bloomington, MN 55425
Phone: 866.882.8442
Email: info@goldleafpartners.com

Specific Privacy Related Inquiries
For specific questions regarding a particular service, please contact your Goldleaf Partners representative or at the number located on your plan documents or account statements.

For any questions regarding your rights under a particular state’s laws, please refer to your state’s section under State Privacy Rights, below, for contact information. If your state is not listed below, then your state does not have any additional rights beyond those addressed in the Goldleaf Partners Privacy Policy, and you may contact us as described above for general or product-specific inquiries.

Note:  To help assure your personal information is kept confidential, we require that you identify yourself when calling by providing specific information, such as your account information and other identifying information.

State Privacy Rights
If your state of residence has privacy laws related to your personal information, and you have questions or would like to exercise such rights, please refer to your applicable state’s Privacy Statement section below:

If there is no Privacy Statement section listed for your state that means no additional privacy rights, beyond current federal statutes or regulations, exist within your state at this time.

California

PRIVACY STATEMENT – CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Goldleaf Partners Privacy Policy and applies solely to those who reside in the State of California (“consumers” or “you”). Goldleaf Partners, part of FuturePlan by Ascensus® and its affiliated companies (“Goldleaf,” “we,” or “us”) adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this statement.

Note that we never sell your personal information. We also do not share your personal information unless permitted or required by law or contract.

Information We Collect

We collect Personal Information. For purposes of the CCPA, personal information is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked directly or indirectly with a particular consumer or device. In particular, we’ve collected for a business purpose, the following categories of personal information from consumers within the last 12 months:

  1. Identifiers.
    A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
    A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  3. Protected classification characteristics under California or federal law.
    Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  4. Commercial information.
    Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  5. Internet or other similar network activity.
    Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  6. Professional or employment-related information. Current or past job history; employer names and addresses.
  7. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
    Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

In the preceding twelve (12) months, we have not sold any personal information.

The categories of Personal Information noted above are obtained from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our websites. For example, from submissions through our website portal or website usage details collected automatically.
  • From third parties that interact with us in connection with the services we perform for you. For example, from affiliated institutions that provide specified financial service products.

Use of Personal Information

We use or disclose the personal information we collect for one or more of the following business purposes:

  • To provide you with information, products or services that you request from us. For example, if we receive your personal information in order for us to maintain or administer your retirement or educational savings plan, we will use that information to provide you those services.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To maintain and improve our website.
  • To protect the rights, property or safety of Ascensus, our clients or others as is necessary or appropriate.
  • To respond to law enforcement requests and as required by applicable law, rule, regulation, court order, or governmental regulations.
  • To fulfill or meet the reason for which the information is provided.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, or similar proceeding, in which personal information held by us is among the assets transferred.

We won’t collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice. Notice will be in the form of an update to this Privacy Management Page.

Note that the following information is excluded from the scope of the CCPA:

  • Publicly available information from government records (if used for a purpose compatible with the purpose for which the data is maintained and made available in the government records).
  • De-identified or aggregated consumer information. De-identified information is information that can’t reasonably identify, relate to, or describe a particular consumer. In other words the information can’t be traced to any particular person. Aggregated information is information about a group of consumers from which individual consumer identities have been removed.
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Sharing Personal Information

In order to effectively deliver our services to you, your personal information may be disclosed to a third party for a business purpose, in accordance with the Information We Collect section above. This may include but not be limited to (i) our affiliates; (ii) service providers (e.g., a print vendor with responsibility to produce and/or mail paper statements and notices; or (iii) the applicable custodial banking institutions who hold your money); and third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Prior to any such disclosure to any third party, we require an executed contract that describes the specified purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose, except to perform the specific services stated within such contract.

Your Rights and Choices

California law provides California residents with specific rights regarding their personal information. This section describes your California privacy rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and verify your request, we’ll disclose specific information to you as it relates to your account regarding:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific items of personal information we collected about you which are subject to such disclosure.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we’ll delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Accordingly, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested or that a third party requested on your behalf, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you or the sponsor of your plan or account.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  5. Comply with a legal obligation.
  6. Make other internal and lawful uses of that information that are compatible with the context in which you provided the information.

Exercising Access, Data Portability, and Deletion Rights

To receive access to your personal information or to request a deletion:

Method 1

To access your personal information, please log into your existing account profile within the applicable secure portal, which enables you to view your account balance and other associated personal details.

Method 2

If you are unable to use Method 1, we suggest you contact us at the number located on your plan documents or account statements.

Method 3

For general inquiries or requests with respect to your rights under CCPA, please submit a request to one of the following options:
Phone: 800# will be displayed prior to January 1, 2020
Email Address: Privacy@ascensus.com
Address: 200 Dryden Road, Suite 4000, Dresher, PA 19025, Attention: Compliance Department

Please note that we’ll need to verify your identity before we can discuss your request any details about your account.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with any personal information if we cannot verify your identity or if we determine that you do not have the authority to make the request or confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. To verify a consumer request, we’ll only use personal information previously provided to us to verify the requestor’s identity and authority to make the request.

Response Timing and Format

We try to respond to a verifiable consumer request within 45 days. If we require more time (up to 90 days), we’ll inform you of the reason and extension period in writing. If you have an account with us, we’ll deliver our written response to the address on record for that account. If you do not have an account with us, we’ll deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons why we can’t comply with a request, if applicable. For data portability requests, we’ll select a format to provide your personal information that is secure and readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Generally we don’t charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine the request warrants a fee, we’ll tell you why that decision was made and provide you with a cost estimate before completing your request.

Non-Discrimination

We won’t discriminate against any California resident in the exercise of their CCPA rights. Unless permitted by the CCPA, we won’t do any of the following solely because you exercised your CCPA rights:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to our Privacy Notices

We reserve the right to amend this privacy notice at any time at our discretion.

Goldleaf Partners Privacy Policy

Effective September 2019

This Online Privacy Policy (the “Policy”) covers the privacy practices of Goldleaf Partners, part of FuturePlan by Ascensus® and its affiliated companies (individually and/or collectively, “Goldleaf” or “we” or “our” or “us”), and describes Goldleaf’s practices relating to the collection and use of personal information collected through websites Goldleaf maintains (the “Sites”). For more information, including information specific to privacy laws in your state, please visit our Privacy Management Page.

What is Personal Information?
As used in this Policy, “personal information” means data identifiable to any person, including, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at other institutions.

Information Collected
Information you provide to us.
We obtain information that you, or someone on your behalf, has provided to us in writing or by telephone, such as when you, or your employer acting on your behalf, signs up for services with Goldleaf; contacts Goldleaf’ customer service staff members; and/or inputs information through our Site(s). This information includes items such as your name, address, birthdate, telephone number, location, social security number, credit card numbers and/or other financial account information such as account numbers.

Information we receive from third parties.
We obtain information about you from third parties, including our business clients, partners, or public sources. This information includes, among other things, information about your transactions and account activity with us.

Information we collect automatically.
When you access a page of a Site via a browser, application, or handheld device, our web servers automatically record certain information, known as “log information.” This log information includes information such as the web page you are coming from or going to, terms you search, pages you view on a Site or mobile application, your interaction with a Site, application or online service provider, your IP address, mobile device ID, browser type, browser language, device type, and data contained in one or more Cookies (discussed in more detail, below) that uniquely identifies your browser, your computer, your device and/or your Goldleaf account. This log information is collected to allow us to deliver services or information you have requested, better understand user behavior on our Sites, assist in troubleshooting problems, and improve the quality of our service. Please be aware that in some cases your IP address will be used to determine your general location.

Additionally, if you allow your browser and/or mobile device provider to send information to us, we shall receive your location, mobile device ID, publicly available demographic data, and information used (i) to comply with regulatory or contractual requirements; (ii) to ensure the accuracy of data; (iii) to better understand your likely interests; and/or (iv) to prevent fraud.

Use of Cookies and Other Tracking Technology to Collect Information
A “Cookie” is a small string of text that is sent to your computer or mobile device when you use our Site(s).

Goldleaf uses common Internet technologies, such as cookies and web beacons to manage its websites and services, advertising, and e-mail programs. Goldleaf collects user feedback, community discussions, chats, and other interactions, such as surveys. Goldleaf may obtain additional information about users, such as demographic information from commercially-available sources and may combine this with information collected from users through this Site or offline (e.g., paper forms).

If you would prefer not to accept Cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a Cookie, which lets you choose whether or not to accept it; (ii) disable existing Cookies; or (iii) set your browser to automatically reject Cookies. Please note that if you are an existing customer you will not be able to turn off Cookies and use the Site(s), as those Site(s) must be capable of identifying and authenticating you to maintain the security of the information contained within them. Additionally, depending on your device and/or operating system, you may not be able to delete or block all Cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting Cookies does not delete local storage objects, such as Flash objects and HTML5.

Use of Personal Information
Goldleaf uses personal information to develop, offer, deliver and improve our products and services, to fulfill legal, regulatory and/or contractual requirements, and as otherwise permitted by applicable law.

For example, we use the information to:
• Operate the Site(s) and services;

• Deliver products and services to people who use our Site(s) and services;

• Understand how visitors use our Site(s) and determine whether the content on the Site(s) is effective;

• Improve our Site(s) and service offerings;

• Personalize your experience when you use our Site(s) and services and customize the communications and advertisements you receive from us;

• Deliver information about products, services and applications offered by Goldleaf via email;

• Let us know which emails have been opened by recipients to understand the effectiveness of our marketing and other communications and to make those communications more useful and interesting to you;

• Communicate with you, including via email, text message, push notifications, and/or telephone calls;

• Identify you across different devices that you use; and/or

• Diagnose or fix technology problems.

If you do not wish to receive marketing messages from Goldleaf, you may indicate your preferences by clicking the “Unsubscribe” link in the email.

Our Information Sharing Practices

Information about our customers, website visitors, and mobile application users, if applicable, is an important part of our business. We never sell your personal information, and we do not share your personal information except as permitted or required by law or contract, including as provided below:

Ascensus Affiliated Companies. We provide personal information about you to Ascensus Affiliated Companies pursuant to a contractual obligation and to the extent permitted by applicable law. These Affiliated Companies may use personal information to market to you their products and services.

Sharing Information with Nonaffiliated Third Parties. We do not share your personal information with nonaffiliated third parties except as permitted or required by law, including as provided below:
• Agents and Service Providers. In order to provide our products and services, we share personal information about you with agents and service providers to perform functions on our behalf, such as to send email and postal mail, analyze data, provide marketing services, and service accounts. When we use these third parties, we disclose some of the personal information that we collect, although we give them only the personal information reasonably necessary to perform the service.

Maintain and Service your Goldleaf Account. We disclose personal information about you to third parties as reasonably necessary to maintain and service your Goldleaf account, including to facilitate transactions.

Protection of Goldleaf and Others. We disclose personal information about you to third parties when we believe such disclosure is appropriate to comply with a legal requirement, such as a law, regulation, court order, subpoena or search warrant, or in the course of a legal proceeding.

Business Transfers. If there is a change of control in Goldleaf’s business (whether by merger, sale, or otherwise), your information could be sold as part of that transaction and your personal information potentially could be used by the purchaser.

With your Consent. We also share your personal information with a third party if you consent to the sharing.

Goldleaf does not share personal information with nonaffiliated institutions to enable them to market their products and services directly to you.

Goldleaf may share with third parties, including nonaffiliated, non-financial institutions, information that does not personally identify you for any reason Goldleaf deems necessary or desirable.

How We Store and Protect Your Information
Your information collected through our Site(s) is stored and processed in the United States. We care about the security of your information and have implemented and continue to maintain physical, administrative, and technological safeguards intended to preserve the integrity and security of all information collected through our Site(s). However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.

Data Collection, Storage, and Retention
Please reach out to your Goldleaf Partners contact to update your contact information.

We will retain your information for as long as we reasonably deem it necessary to provide you services, comply with our legal or other obligations, resolve potential disputes, audit our records and/or enforce our rights and obligations. If you no longer want us to use your information to provide you services, you will need to take the appropriate steps to terminate your relationship with Goldleaf and/or the applicable Affiliated Companies. However, legal or other obligations may require us to retain your information even if you request that we delete it.

Collection of Information from Children
Goldleaf does not knowingly collect or solicit any information from anyone under the age of 13 on the Site(s). In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will promptly delete that information. If you believe that we might have any information from a child under 13, please contact us using the contact information listed below.

Changes to this Online Privacy Policy
Please note this privacy policy may change from time to time. Please check this site to view changes.