Privacy Policy
O’Brien Wealth Partners LLC
PRIVACY POLICY
Effective Date: September 25, 2023
O’Brien Wealth Partners, LLC (“O’Brien Wealth Partners,” “we,” “us,” “our”) respects and values your privacy and wants you to be familiar with how we collect, use, protect, and disclose information from and about you. This Privacy Policy (“Policy”) describes our practices in connection with personal information collected through our websites (“Sites”) or as otherwise described herein.
This Policy applies to our collection of personal information (i.e. information that may identify, relate to, describe, reference, is capable of being associated with or could reasonably be linked, directly or indirectly, with you or your device). This privacy policy applies to consumers, including website visitors and potential clients. If you are looking for GLBA-specific disclosures, please refer to O’Brien Wealth Partners’ Consumer Privacy Notice at https://obrienwp.com/assets/consumer-privacy-notice-20230925.pdf.
How Do We Collect Personal Information
- From you. We may collect personal information and other information that you provide when you use our Sites, register or log in to your account online, or otherwise communicate with us or our advisors.
- From devices you use when you interact with us online. This includes information collected through our Sites and automatically from devices you use to connect to our Sites. For more information about this, please see our “Cookies and similar technologies” section below.
- From third parties and publicly available sources. This includes personal information we collect from public sources including, but not limited to, websites that enable social sharing, social media sites, and from our vendors and suppliers, our affiliates, or other individuals and businesses.
- From you in person. This includes information you may give one of our advisors if you meet with them in person.
Types of Personal Information We May Collect from You
Depending on how you interact with us and our Sites, we may collect the following information:
- Contact information such as name, email address, zip code, phone number, and home address.
- Biographical and identifying information such as date of birth, location, and Social Security Number.
- Financial information such as your income, investment preferences, accounts with us and other financial institutions, as well as other financial details.
- Internet usage information such as browsing history, search history, information regarding your interaction with our online services or advertisements, IP address, browser type, and clickstream data.
- Device information. Such as browser or device model and settings, operating system, and unique identifiers, and the version of the internet browser you’re using.
- Inferences such as inferences drawn from any of the personal information we collect to better understand your preferences.
- Account information such as information you provide when you create an account, like username and password.
- Transaction information such as information needed to complete your transactions, such as your bank account information, and your transaction history.
If you submit any personal information relating to other people to us, such as information about other account holders, family members, or beneficiaries, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.
How We May Use Your Personal Information
We may use information you provide us through our online services to:
- Provide, market, and develop our products and services. O’Brien Wealth Partners Financial collects information to provide our services, maintain our Sites, and better understand the interests of our clients who use our services and products.
- Process transactions and administer your account. We may use your information to process your transactions and requests.
- To process your employment application. We may use your information to process employment applications, including verifying statements made on your application (e.g., credit and employment history), and performing background and credit checks.
- Communicate with you. We may use your information to respond to your inquiries and send you communications regarding our products and services.
- Develop new products and services and quality assurance. We may use personal information to study, develop, and improve our products and services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
- Security and fraud prevention. We may use personal information to monitor, detect, and prevent fraud and improper or illegal activity. It may also be used to investigate any suspected fraud, harassment, or other violations of any law, rule, or regulation, the terms, rules or policies of our online services, or the rights of third parties, or to investigate any suspected conduct which we deem improper. We may also use it to enforce our agreements between you and O’Brien Wealth Partners Financial.
- Verify your identity and verify our records. We may use personal information to verify your identity for the purposes of responding to a request regarding your personal information that you make. This information may also be used to verify our own records for accuracy.
- Debugging and performance of systems. We may use your personal information to secure our online services including our network and websites and to debug our online services. We may also use it to diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services.
- Comply with law. We may use personal information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigation.
- Internal business purposes. We may use personal information for our internal business purposes, such as data analysis, audits, and enhancing our Sites. We may also use inferences drawn from personal information to create a profile reflecting your preferences so we can tailor our Sites to you.
- In accordance with our financial services Consumer Privacy Notice. We may use your information in the ways indicated in our Consumer Privacy Notice.
How We Disclose Personal Information
We may disclose personal information in the following ways:
- Service providers. We may provide personal information to vendors, contractors, business and service partners, or other third parties who provide services to us including data storage firms, payment companies, technology suppliers, technology services, customer service, risk solution providers, analysis firms, fraud prevention companies, advertisers, marketers, and others. For example, our online portal is provided by a third-party service provider.
- Collaborators and advisors. We may disclose personal information with collaborators with whom we jointly develop or promote our services, such as our Advisors.
- Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
- At your direction. We may disclose your personal information at your direction or with your consent.
- Aggregate data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.
- In connection with a merger, acquisition, or business transfer. If O’Brien Wealth Partners sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a reorganization, merger, or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), O’Brien Wealth Partners may transfer or disclose your information to the party or parties involved in the transaction as part of that transaction.
Children’s Privacy
You must be 18 years or older to use our Sites. Our Sites are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.
Links to Third-Party Websites
We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.
If you provide any personal information through a third-party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.
Advertising and Opt-Out Disclosures
When you use our Sites, our third-party advertising partners, social media providers, and analytics providers may collect personal information about your online activity on our Sites and on third-party websites.
These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third-party websites within their networks. If you would like more information about this practice and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.
For example, we use third-party analytics services, including Google Analytics and others, to collect information about your use of our sites and enable us to improve our sites. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners. Google Analytics and other third-party analytics services use cookies and similar technologies to collect information about the use of our sites and to report website trends to us, without identifying individuals to us. We use this information to see the overall patterns of usage on our sites, help us record any difficulties you have with our sites, and tell us whether our communication efforts are effective. We may also link the information provided by third-party analytics services with the information we collect, or you provide in other contexts on our site (newsletters, etc.), to personalize, connect and streamline your experience when visiting our Sites. You can opt out of data collection or use by Google at the following link: Google Analytics: tools.google.com/dlpage/gaoptout (requires you to install a browser add-on).
Information Security
We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, and unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.
Cookies and Similar Technology
We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Sites use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Sites, such as pages you have visited, other content you viewed, and search history.
We and our partners may also use these technologies to gather personal information about how you view and use our Sites and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Sites. The use of these technologies helps us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.
Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies such as cookies. To find out more about cookies, visit www.aboutcookies.org. Also, certain versions of the Android operating system allow you to “Opt-out of Ads Personalization” in the system settings. The options you select are browser and device specific.
Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT or a common definition of “tracking,” we do not currently respond to the DNT signal on our websites. We do, however, honor other global privacy preferences when required by law. More information about Do Not Track is available at www.allaboutdnt.org.
Your Marketing Preferences
We may periodically send promotional materials or notifications related to our products and services. If you no longer wish to receive promotional marketing materials from us, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by contacting us at: (617) 547-6717 or email [email protected]
Suspicious Email
It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from O’Brien Wealth Partners but you suspect may be from another source and might be fraudulent, please contact us immediately at: (617) 547-6717 or email [email protected]
Social Media
You may also find additional information on our products and services through our social media sites such as Facebook, LinkedIn, Instagram or X. Please keep in mind that any information you share is visible to all participants on these social media sites and you should never post any sensitive personal information (such as account number or tax identification). Please carefully review the Terms of Use and Privacy Policy on these social media sites as they may be different than our own policies.
Updating and Correcting Your Personal Information
Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate, or not current, please feel free to also contact us at: (617) 547-6717 or email [email protected]
Storage and Protection of Personal Information
We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. Procedurally, O’Brien Wealth Partners employees are bound by and held accountable to a code of conduct and policies regarding confidentiality and the treatment of client information.
In order to help secure personal information collected from you as an O’Brien Wealth Partners online portal user, including sensitive financial data, the information is protected by SSL encryption when it is exchanged between your web browser and O’Brien Wealth Partners online portal. However, the internet is not a fully secure environment, and we cannot ensure or warrant the security of any information transmitted to or generated by O’Brien Wealth Partners in connection with O’Brien Wealth Partners’ online portal. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.
While we take the aforementioned steps to secure our Sites and our portal, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet. O’Brien Wealth Partners cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to O’Brien Wealth Partners, you do so at your own risk.
By using O’Brien Wealth Partners services, you agree that the procedures provided for in this Privacy Policy to protect personal information and to verify the identity of users including, but not limited to, those procedures described in the foregoing paragraph, constitute commercially reasonable website security and customer verification procedures.
Notice to Persons Accessing the O’Brien Wealth Partners Site or Online Portal from Outside the United States
If you access the O’Brien Wealth Partners Site or online portal outside the United States, any information you provide to us through the O’Brien Wealth Partners Site or online portal will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States.
Contacting Us About Privacy Questions
If you have questions or concerns regarding this Privacy Policy, you should contact us at: (617) 547-6717 or email [email protected]
Changes to the Privacy Policy
We reserve the right to modify or supplement this Privacy Policy at any time. Therefore, we recommend that you review this Privacy Policy, updated and posted on this Site, regularly for changes. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the top of this Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the site. Your use of the O’Brien Wealth Partners Site and/or online portal following these changes means that you accept the revised Privacy Policy.