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Stifel Wealth Tracker Privacy Statement

Last updated on December 7, 2023

Stifel Wealth Tracker (“we,” “our,” or “us”) is committed to the protection of your privacy.

This Stifel Wealth Tracker Privacy Statement (this “Privacy Statement”) describes the specific policies and procedures we use to collect, process, disclose, share, and protect Personal Information (defined below) of the users (“you” or “Users”) of our websites, mobile applications, data, content, and software, and other online offerings (collectively, “Services”), including the Stifel Wealth Tracker Platform (“Wealth Tracker”). This Privacy Statement applies to Personal Information (defined below) collected from you directly or received from third parties on your behalf. This Privacy Statement is incorporated in and made part of the Terms of Use Agreement that governs your use of the Services (“Governing Terms”). The use of the term “including” means “including, without limitation” throughout this Privacy Statement.

What Personal Information Do We Collect?

In connection with your access and use of the Services, we may collect information that identifies or can be used to identify an individual person (“Personal Information”). Such Personal Information may include your name, e-mail or mailing address, phone number, account numbers, account login credentials, and other similar identifiers. Except as set forth in this Privacy Statement, we do not share your Personal Information with anyone.

User Account Information. When you register to use Wealth Tracker or otherwise make use of the Services, you will be asked to open a user account and to provide certain information that includes:

• Your name;
• Your e-mail address;
• Your phone number; and
• Other optional information designed to help determine your overall financial picture and investment profile.

If you elect to use Wealth Tracker to aggregate your banking and other accounts maintained at third-party financial institutions, you will be asked to provide information that includes:

• Your account login credentials (including user names and passwords) for the accounts you wish to aggregate;
• Account security and/or challenge questions for those accounts, if applicable; and
• We will ultimately receive transactional information from those third-party financial institutions related to any accounts that you link (including account balances, transactions, and holdings).

As explained in our Governing Terms, data aggregation and account-linking services are provided by Plaid Inc. (“Plaid”), and Plaid is neither affiliated with Stifel Wealth Tracker nor controlled by Stifel Wealth Tracker. When you link accounts for aggregation, you are providing your login and related information relative to those accounts directly to Plaid (and not to Stifel Wealth Tracker), and doing so strictly pursuant to Plaid’s Privacy Policy at https://plaid.com/legal/#end-user-privacy-policy.

Cookies, Applets, Website Use, and Data Logs. When you visit Wealth Tracker or use the Services, even if you have not opened a user account, we (or a third party retained by us to support us in providing our Services) may place on your mobile device and/or computer an applet, such as a cookie, pixel tag, or web beacon that will allow our system to recognize you when you next visit Wealth Tracker or use the Services. These applets help to optimize, secure, and simplify your experience with us. These applets may collect and use information about your use of our Services, including your IP address and information about your operating system, internet browser, time spent on any of our Services, and which of our pages you visited (“Activity Data”). We use Activity Data to personalize your experience, ensure that our Services function properly, and for security purposes, as well as to improve our Services. We also gather statistical information about usage of our Services in order to improve their design and functionality, to assist us with resolving technical support questions, to track advertising performance, and to collect aggregate data on web page viewing and mobile app usage. Cookies also may be connected to third-party companies or third-party websites. The privacy practices of the companies placing such cookies are governed by the privacy policies of such third-party companies or third-party websites.

Your browser may have settings that will block the installation of cookies and other similar applets. You can also delete cookies that have already been placed on your computer. Consult the “Help” function of your browser to explore your options. If your browser is set in this manner, certain functions or features of our Services may not be available to you.

Photos of Financial Documents. We might collect images of financial documents — including checks and account statements — that you provide us by scanning with the camera on your device, or uploading, or using another method.

How Do We Use Your Personal Information?

We use your Personal Information to:

• Provide our Services to you;
• Allow you to add to your user account information from your financial accounts located with third-party financial institutions, such as account balances, statements, transactions, and holdings from your financial institutions, and to aggregate other third-party data;
• Deliver third-party financial information and market data, and provide you with contextual and relevant observations and insights;
• Develop aggregated and anonymized user data;
• Provide comparisons of your financial situation (e.g., investment risks and returns, financial ratios) relative to aggregated user data to enable you to better understand your financial situation;
• Communicate with you about our Services, including updated features, feedback you may provide about our Services, or maintenance activities related to providing you with our Services;
• Monitor system performance and data accuracy for optimization and user experience;
• Personalize your user experience with our Services;
• Provide you with customer support, and respond to and resolve your inquiries and requests via e-mail or by phone;
• Publish trends and analysis for our user base, such as geographical financial patterns, but only in aggregated and anonymized form so that none of your Personal Information is identifiable;
• Notify you about service offerings and offer you additional services available from us or our affiliates;
• For any purpose for which you permit us to use your Personal Information; and
• When the Personal Information is an image of a check you want to remotely deposit, to process it for clearing.

With Whom Do We Share or Disclose Your Personal Information and Data?

Except as set forth in this Privacy Statement, we do not share your Personal Information and Data with anyone.

We may share your Personal Information and Data:

• Within Stifel Wealth Tracker;
• We may provide your data (including your Personal Information and any of your data supplied to us in connection with your use of the Services, whether provided directly by you or transferred to us from your third-party financial institutions) (“Your Data”) to those affiliates and/or third-party service providers who assist us in operating Wealth Tracker and/or providing the Services;
• If you opened your Wealth Tracker user account through an invitation from a financial representative registered with Stifel Financial Corp. or any of its affiliates (including by accessing Wealth Tracker through a hyperlink or other form of invitation (electronic or otherwise), or if you otherwise request to speak with a financial representative or consent to receive wealth management services of any kind from Stifel Financial Corp. or any of its affiliates, then we will share Your Data with Stifel Financial Corp. or its affiliates to facilitate such entity’s conversation with or provision of services to you;
• To comply with the laws, regulations, and rules by which we are governed;
• We may use the e-mail address and other contact information that you provide to us to send you surveys as part of our marketing activities. Responding to those survey solicitations is completely voluntary;
• We may share the e-mail address and other contact information that you provide to us with third parties with whom we contract to conduct the surveys just mentioned above on our behalf. If we do so, our agreements with those third-party contractors will prohibit them from using your e-mail address or other contact information for any other purpose or from sharing that information with other third parties;
• We may share information with any successor to all or part of our business. For example, in the event of a merger, divestiture, change of control, or sale of all or substantially all of our assets (or in anticipation of such event), we may share your information as part of that transaction;
• We may disclose your Personal Information in any manner that you expressly permit; and
• When the Personal Information is an image of a check you want to remotely deposit, we may forward it to a third-party clearing intermediary.

Security of Personal Information

Beyond this Privacy Statement, we provide additional security measures, including the use of administrative and technical safety measures that are intended to protect your Personal Information. To further protect your information, we utilize a number of controls and safeguards, including the use of multi-factor authentication upon initial enrollment into Wealth Manager and subsequent logins from unrecognized devices. Additional verification factors also work behind the scenes to provide a seamless and secure experience.

You will have a unique set of Credentials, selected by you, and which will be encrypted while transmitted to or from our servers. As a final safeguard, you will be notified when changes are made to your account security settings.

How Can You Review and Update Your Personal Information?

You can view and update your Personal Information by using the tools provided within Wealth Tracker. The usefulness of Wealth Tracker or the Services to you is dependent on your provision of accurate and up-to-date information about yourself, including your investment goals as they may change from time to time.

How Long Do We Retain Your Personal Information?

Unless you request otherwise, we will retain the Personal Information we collect from you indefinitely or as long as we deem necessary.

Stifel Wealth Tracker, as a registered investment adviser, must comply with certain legal and regulatory requirements pertaining to record retention. As such, even if you close your user account, we may be required to retain all or part of your Personal Information in order to comply with applicable laws and regulations.

However, once your account is closed, any accounts at third-party financial institutions that you previously linked will be de-linked, and Wealth Tracker will no longer be able to access them or receive any data from those institutions about those accounts.

Stifel Wealth Tracker’s Statement Regarding “Do Not Track” Signals

Most browsers can be set to send signals to third-party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, Stifel Wealth Tracker, its third-party service providers, and other third-party websites and online services may indeed track and collect Personal Information about your online activities over time while navigating to, from, and on Wealth Tracker or the Services and across those third-party websites and online services, notwithstanding any “do not track” signals we may receive.

Protecting Children’s Privacy Online

Stifel Wealth Tracker is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through the Services. We do not knowingly collect information from children under 13 without parental consent.

Modifications to Our Privacy Statement

We may change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy Statement and we will post the revised document on our website at www.stifel.com/tracker/privacy.

Privacy Questions, Comments, or Feedback?

Please contact us.

By E-Mail:
wealthtracker@stifel.com

By Mail:
Attention: Privacy
Stifel Wealth Tracker
501 North Broadway
St. Louis, Missouri 63102

www.stifel.com/tracker