GENERAL 3Nickels values your privacy. As a 3Nickels user, be assured that your privacy is protected. Information obtained directly from our users; your plan sponsor; and/or plan record keeper is used only for the stated purpose. Information that 3Nickels collects and maintains will not be released to any party outside of 3Nickels except as otherwise disclosed in this Policy.
TECHNOLOGY We help protect against unauthorized access and alteration to customer data through the use of malware detection and prevention, firewalls, and other industry-standard technologies. 3Nickels encrypts sensitive information transmitted online and uses advanced technologies for information backup and recovery.
EMPLOYEE TRAINING Only authorized personnel have access to confidential information. We require our employees to have information security training and implement these practices every day.
OBTAINING AND HANDLING YOUR CONSENT By using our websites or submitting personal information to us via your record keeper and/or plan sponsor, you agree that we may collect your personal information and you consent to the use, disclosure, and transfer of your personal information in accordance with this Policy and as permitted or required by law. If you do not agree with this Policy, please do not use our websites, provide us with your personal information, or otherwise grant your consent.
You may refuse consent to our collection, use, and disclosure of your personal information, subject to legal and contractual requirements and reasonable notice. You may withdraw or revoke your consent to further collection, use, and disclosure of your personal information for certain of the purposes identified herein.
There are instances where we may collect, use, or disclose your personal information without your consent. For example, we may use or disclose your personal information to comply with a subpoena or court order or under applicable law.
WHAT INFORMATION 3NICKELS COLLECTS 3Nickels may capture the following information about users of our services:
|Categories of Personal Information||Specific Personal Information||Source of Personal Information|
|Identifiers||NameAddressPhone Email addressDate of birthGenderMarital statusTax filing statusState where you file your tax returnsRetirement ageSpouse’s nameSpouse’s genderSpouse’s retirement ageDependent’s nameDependent’s birth yearEligibility for HSASelf-employment status||Information collected directly from user|
|Financial information (as described in CA Code §1798.80)||Your annual salarySpouse’s annual salaryOther financial information, e.g., investment balances, pension information, contributions to retirement plans||Information collected directly from user, account aggregation|
|Internet/electronic activity||User status when logged in to 3Nickels account||Website cookies|
HOW DO WE USE YOUR INFORMATION? We may use the information we collect from you for a variety of reasons related to our business operations and as set forth in this Policy. Examples of ways that we may use such information include the following:
- Providing financial advice and guidance;
- Responding to your requests;
- Communicating with you;
- Contacting you at a telephone number you have given us to in order to respond to a service request;
- Tracking our visitors’ use of our websites;
- Improving the content, appearance, and utility of our websites;
- Compliance, audits, and providing assistance to law enforcement; and
- Completing a corporate transaction, such as a merger, sale, joint venture, or disposition of all or any portion of our business, assets, or stock.
HOW DO WE SHARE YOUR INFORMATION? 3Nickels is committed to protecting the personal information that our customers provide to us. The data you send to or enter into the 3Nickels website is considered your confidential and proprietary information. It is our policy to respect the privacy of our customers, and for this reason we do not sell, reveal, or share any of your personal information with any third parties, including your own employer. We will not monitor, edit, or disclose the contents of your data except to our service providers for our business purposes or if required to do so by law or in the good faith belief that such action is necessary to:
- Conform to the law or comply with legal process served on 3Nickels;
- Protect and defend the rights or property of 3Nickels; or
- Act under exigent circumstances to protect the personal safety of our customers or the public.
DO WE MONITOR WHO USES OUR WEBSITE? Each time a user visits our website, our server collects certain use and navigation information. This information is aggregated and analyzed to tell us when and how the website is used and navigated, including the number, frequency, and duration of visits to each web page. It also helps to inform us of any performance-related issues we have so that we can correct them to provide you with a more efficient website.
RETENTION OF YOUR PERSONAL INFORMATION The personal information that you provide will be retained by us for a period necessary for the purpose in question or in accordance with applicable laws.
SECURITY We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, for example, if you feel that the security of your account has been compromised, please notify us immediately in accordance with the “Contact Us” section below.
CHOICE AND OPT-OUT Subject to reasonable notice, you may withdraw your consent to certain of the purposes identified herein at any time, unless the personal information is necessary for us to fulfill our legal requirements or similar obligations. To withdraw your consent, please contact us at the address below and advise us of what personal information you no longer wish us to use.
If you withdraw or revoke your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. In the event of changes or opt-out requests, we may retain your personal information for reasonable purposes, for example, in connection with your past transactions.
Please note, to identify you, we may need to ask you for additional information in order to be able to fulfill your opt-out request, and that applicable laws may contain restrictions and other provisions that relate to your rights above.
CALIFORNIA PRIVACY RIGHTS AND CHOICES The California Consumer Privacy Act of 2018 (the “CCPA”) provides California residents with specific rights regarding the collection and storage of their personal information. This section describes how these rights apply to you if you are a California resident.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS You have the right to request that 3Nickels disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. Once we have received a request from you, we may ask you to provide certain information to identify you and verify your request. Upon verification, we will disclose to you:
- The categories of personal information we collected about you.
- The specific pieces of personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- We do not sell personal information; however, if we disclose your information to a third party, we will provide to you the categories of third parties with whom we share personal information and the categories of information that we share with each third-party recipient.
DELETION REQUEST RIGHTS You have the right to request that 3Nickels delete any of the personal information collected from you and retained by us, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that data in accordance with applicable law, we will delete and direct our service providers to delete your personal information from our records. Your request to delete the personal information collected may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA.
EXERCISING YOUR RIGHTS To exercise any of the rights described above, please submit a verifiable consumer request to us by:
- Calling us at 888-675-4532
- Visiting https://www. 3Nickels.com/privacy
- Sending an email to email@example.com
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 make a verifiable consumer request for access only twice within a 12-month period. Your verifiable consumer request must:
- Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information, or a person authorized to act on your behalf; and
- Describe your request with sufficient detail to properly understand and respond to it.
We will use the personal information that you have provided in a verifiable consumer request in order to verify your request only. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.
Making a verifiable consumer request does not require you to create an account with us.
RESPONSE TIMING AND FORMAT We aim to respond to customer requests within forty-five (45) days of receipt. If we are unable to deliver a response to verifiable consumer requests within this timeframe, we will inform you of the reason and estimated extension period in writing. We will deliver a written response by mail or electronically, at your option.
Any disclosures will cover only the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Data portability requests will be issued in a format that is readily usable. We do not charge a fee unless your request is excessive, repetitive, or manifestly unfounded. If the request warrants a reasonable fee, we will tell you why and provide you with a cost estimate before completing your request.
If you wish to access or change any of the information collected by 3Nickels, you may do so by sending an email to help@3Nickels.com. When contacting us, please be sure to provide us with your exact email address, name, address and/or telephone number(s) so that we may handle your request appropriately. In some circumstances, we may not provide access to your personal information if, for example, it contains the personal information of other people, if it constitutes confidential commercial information, or if it is otherwise not the subject of an access request.