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Privacy Policy

Last Update / Effective Date: August 17, 2021

This Privacy Policy (“Policy”) describes how Wealth Enhancement Group, LLC and its affiliates (“WEG,” “we,” “us,” or “our”) collects Personal Information through the www.wealthenhancement.com website (the “Site”), and how it uses and shares that Personal Information.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 12 BELOW FOR ADDITIONAL PROVISIONS THAT MAY APPLY TO YOU.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. All changes will be effective immediately upon posting to the Site. We will conspicuously post on the Site if we make material changes to this Policy.

We may collect personal non-public information (“Non-Public Information”), which includes information we may receive from account forms, your investment transactions, and product sponsors with whom we have selling or arrangement agreements. This Policy does not apply to the access and use of such Non-Public Information. Please see our Advisory Services Privacy Policy found here and our Trust Services Privacy Policy found here for further information about the collection and use of Non-Public Information.

1. Categories of Personal Information Collected and/or Disclosed for Business Purposes in the past 12 months. WEG has collected and/or disclosed the following categories of Personal Information for the following business purposes in the past 12 months:

  • Identifiers (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);
    • This information is collected for the purposes of:
      • Relationship management with existing and potential clients and other interested parties
      • Communicating with interested parties
      • Providing services to our clients
      • Job applications
      • Employment with WEG
  • Personal Information Categories Listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e))(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);
    • This information is collected for the purposes of:
      • Relationship management with existing and potential clients and other interested parties
      • Communicating with interested parties
      • Providing services to our clients
      • Job applications
      • Employment with WEG
  • Characteristics of protected classifications under California or federal law (Race, age (40 years and older), 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);
    • This information is collected for the purposes of:
      • Relationship management with existing and potential clients and other interested parties
      • Communicating with interested parties
      • Providing services to our clients
      • Job applications
      • Employment with WEG
  • Commercial information (Records of personal property (e.g. jewelry, vehicles), services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
    • This information is collected for the purposes of:
      • Relationship management with existing and potential clients and other interested parties
      • Communicating with interested parties
      • Providing services to our clients
  • Internet or electronic network activity(Browsing history, cookie data, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
    • This information is collected for the purposes of:
      • Monitoring the use of WEG systems by our personnel
      • Analyzing and improving WEG systems, including our website
      • Marketing to you
      • Serving targeted advertisements to you
  • Biometric Information(Physiological, biological or behavioral characteristics, from which an identifier template can be extracted, such as a finger print)
    • This information is collected for the sole purpose of:
      • Employment with WEG
  • Professional or employment related information(Current and/or past employment history including performance evaluations);
    • This information is collected for the purposes of:
      • Relationship management with existing and potential clients and other interested parties
      • Job applications
      • Employment with WEG
  • Education information(Education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records);
    • This information is collected for the purposes of:
      • Job Applications
      • Employment with WEG
  • Inferences from the foregoing.
    • This information is collected for the purposes of:
      • Communicating with interested parties
      • Providing services to our clients
      • Establishing and maintaining employment with WEG

2. How We Use Personal Information. We use the categories of Personal Information listed above and other data we collect from you for the following purposes:

a.To Communicate With You, Respond to Your Requests and Contract With You. We use Personal Information as requested or consented to by you. We use Personal Information we collect from you to respond to your questions, comments, or complaints. We use your Personal Information to provide customer support and assistance and to send newsletters or information about our new services. We use Personal Information to provide service and technical updates.

b.To Operate our Business: We use Personal Information to operate our business, to inform our business strategies, to improve our services, to develop new services, and to notify you of changes to the Site or our Policy. We use Personal Information to provide customer support or assistance, process a job application, and to provide our services and technical updates.

c.To Request a Meeting or Assessment Evaluation. We use your Personal Information to respond when you request a meeting through the Site inquiring about WEG services and obtaining an initial assessment evaluation.

d.To Create a Client Portal Account. We collect your Personal Information when you register for and create a Client Portal account. You are also required to choose a password which you should keep confidential. Please note, the Site may link to, or be linked to, other portals or accounts managed by third parties including but not limited to qualified custodians, who are not owned, controlled, or affiliated with WEG. This Policy does not apply to any such third-party portals or accounts or to any data that you provide to these third parties. You should read the privacy policy for each third party portal or account that you visit.

e.To Operate our Site. We use Personal Information to help us manage the Site, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

f. When You Apply for a Job. We use Personal Information you provide when you apply for a job to evaluate your application. When you apply for a job, you will be redirected from our Site to a website operated by Arcoro Inc. You may be required to create an account with that service provider. We encourage you to review the terms and privacy policy posted on that service provider’s website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with WEG. Your submission of an application or inquiry does not in any way require WEG to review your information or consider you for employment.

g.To Market to You. We may use Personal Information to send you advertising, to notify you of new services and for other similar communications. We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. We may use third-parties or service providers to deliver these communications to you. To opt-out of such communications (e.g., postal marketing and telemarketing), please contact us as set forth in the “Contact Us” section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.

h.To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including bringing a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site.

3.Categories Of Sources. We may collect contact information or information regarding your internet activity from the following categories of sources:

Source: We Collect Personal Information Directly From You. We collect Personal Information that you provide directly to us. For example, we collect Personal Information when you contact us via email, phone, contact us to Request a Meeting, when we receive or respond to a request from you, and when you respond to communications from us (e.g., forms and surveys).

Source: We Collect Personal Information Automatically. We automatically collect certain information from you when you access our Site using the following technologies.


Cookies and Website Usage Tracking Technologies.

What are Cookies? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site. A cookie is a small text file containing a unique number that our Site sends to your web browser when you visit our Site. Cookies allow the Site to remember your actions and preferences and recognize you or your browser.


How Cookies are Used: We, our on-line service providers, on-line advertisers and social media sites use Cookies to help our Site function properly, provide personalized experiences, tailor interactions with you, optimize our marketing efforts, provide us information regarding Site usage and to help us improve our Site.

We use Cookies to collect information about the devices you use to visit our site (IP address, device ID number, approximate geographic location (zip code), your operating system and browser history). We also collect information about how you use the Site such as the date and times you visited the Site, the amount of time spent on the Site, the pages you visited, your search requests on the Site and the websites you access before and after visiting our Sites.

We may combine information from Cookies with Personal Information, including data obtained from other sources.

Can I Disable Cookies? Most browsers automatically accept Cookies. You can disable this function by changing your browser settings, but disabling Cookies may impact your use and enjoyment of the Site. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.


Third Party Analytics. We use third-party data analytics companies such as Google Analytics to collect and process information about your use of the Site. These companies set Cookies on your browser or device and then your web browser will automatically send information to that analytics company. The analytics provider uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.

We may also implement additional add-on services to Google Analytics, such as Demographics and Interest Reporting, Remarketing with Google Analytics, and Google Display Network Impression Reporting.

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.



Targeted Advertising.

We use certain advertising network services to engage in targeted advertisements. These advertising network services use data they collect from multiple sites and sources to target personal content and advertisements to you about our products. The data collected may be associated with your personal information. The targeted advertisements may appear on the Site and on other websites and may be sent to you via email.

For example, we use Google Ads, Bing Ads provided by Microsoft, and Facebook Custom Audience to serve ads on our behalf across the internet and on the Site. Google Ads, Bing Ads, and Facebook Custom Audience use cookies, web beacons and other storage technologies to collect data about your visits to the Site and your interaction with our products and services to provide us measurements and generate targeted advertisements to you on other websites that you visit across the internet. To opt-out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site. To opt out of remarketing advertising provided through Facebook, you can use the following mechanism for exercising such a choice: https://youradchoices.com/control. If you wish to prevent Bing Ads conversion tracking, visit the following link:http://choice.microsoft.com/en-US/opt-out. Further information about Microsoft’s privacy practices can be found on the Microsoft website at https://privacy.microsoft.com/en-us/privacystatement. To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may occasionally still see our ads.



Videos; Embedded Content. The Site may contain videos and embedded content provided by YouTube, Vimeo and other third parties, including visible content and/or feeds scripts embedded in the Site's code. YouTube, Vimeo and such third parties may collect data about how you interact with such content. Specifically, our use of YouTube content requires us to implement certain application programming interfaces (APIs) from YouTube, which allow for data collection, disclosure and use by YouTube pursuant to the Google Privacy Policy available here. In addition, if you are signed into your Vimeo account when you visit our Sites, Vimeo may associate information collected when you visit our Sites with your account. By watching the videos and interacting with such content, you agree to the collection and use of such data. You may revoke YouTube’s access to your data by visiting the Google security settings page available here. Please see Vimeo's privacy policy to learn how Vimeo collects, uses and shares Personal Information.


Source: We Collect Personal Information From Third-Party Sources.We obtain data about individuals from various third-party companies and public sources and we may combine that data with Personal Information or other data we collect. This enhances our existing information about our users (e.g., updating address data), improves our ability to contact you, and enhances our marketing capabilities.

We have collected Personal Information from all of these sources for our business purposes in the past 12 months.


4. Purpose For Collecting Personal Information. We may collect your contact information and information about your Internet activity for the following business purposes:



a. To Respond to Your Requests. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or concerns.


b. Administration. We use Personal Information for administrative purposes, such as updating your records, to understand the Site’s demographics and user preferences, to manage our Site, to notify you of changes to this Policy and to evaluate job applications.


c. Marketing and Communications. We may use Personal Information to send you promotions, to serve ads to you and to notify you of new service offerings,


d. For Legal Reasons. We use Personal Information to protect our legal rights or interests, or those of others. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests including from law enforcement or the courts.


5. Categories Of Third Parties And Service Providers With Whom We Share Personal Information.We may share your contact information and information about your internet activity with the following persons and entities:

a.Employees and Other WEG Affiliated Companies. We may share Personal Information with our employees who have a need to know the information for our business purposes. We may also share your Personal Information with other companies owned by, affiliated with, or under common control with WEG.

b.Insurance Companies, Investment Firms, and Banks Who Assist With Service Offerings. We may share Personal Information with non-affiliated companies that provide contracted services in order to more effectively and efficiently service our clients. We ensure contractual restrictions for the use and disclosure of the Personal Information by WEG to nonaffiliated companies which includes mutual fund companies, insurance companies and other product sponsors to effect purchases and sales and allow for the servicing of client accounts, the broker-dealer through whom we execute securities transactions, clearing agencies through whom we clear and settle securities transactions, third-party investment advisory firms with whom we have relationships for the management of client advisory accounts, broker-dealer firms having regulatory requirements to supervise certain activities of representatives who are also registered with a broker-dealer, and banks and other financial institutions with whom we have arrangements for the marketing and sale of our products and services.

c. Service Providers. We may share Personal Information with companies that provide services for us. For example, we may share Personal Information with companies that help us host and manage the Site; companies that provide targeted advertising; our legal, accounting and other business and professional advisors, companies which help us to improve the content and functionality of the Site; companies that perform data analysis and statistical analysis regarding data received through the Site; companies that provide public relations services; companies that provide email services for us; companies that provide data processing services and companies that provide security for the Site.

d. Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, WEG or any other person.

e. Change in Ownership. In the event (a) WEG is subject to a sale or other change of control, (b) the Site changes ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including as part of any due diligence process.



6. Use and Disclosure Of De-Identified Or Aggregated Information.

WEG may collect, use, share, and transfer de-identified and aggregated information that it receives or creates for any purpose in its sole discretion, in compliance with applicable laws. WEG is the sole and exclusive owner of such de-identified and aggregated information, including if WEG de-identifies Personal Information so that it is no longer considered Personal Information under applicable laws.


7.Children.

The Site is not directed at children under 13 years of age. We do not knowingly collect, use, or share Personal Information from children under 13. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.



8.Data Security.

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.


9. Access From Outside The United States.

If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions.


10. Third-Party Websites.

The Site may link to, or be linked to, websites not owned or controlled by us. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.



11. Marketing Communications; Opt-Out.

We use your contact information to send you promotional and other electronic and hardcopy communications. We may use third parties or service providers to deliver those communications to you. You may opt-out of such marketing emails by using the unsubscribe link in the email.

To opt-out of communications other than e-mail (e.g., mail and phone calls), please contact us as set forth below. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your account or transactions.

 

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12. Your California Privacy Rights.
Under the California Consumer Privacy Act (“CCPA”), California residents have additional rights with regard to their Personal Information. We describe those rights and how you can exercise your rights. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for California consumers. Any capitalized terms not defined in this Policy have the meanings set forth in the CCPA. For instance, under CCPA, Personal Information is defined as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The CCPA includes a number of examples of what constitutes Personal Information.

This notice does not apply to Personal Information collected pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations, or the California Financial Information Privacy Act, or certain medical and health information covered by HIPAA.

We Do Not Sell Personal Information. To protect your privacy, we do not sell, share, or rent your Personal Information as such terms are defined under the CCPA.

Subject to exceptions outlined in the CCPA, the rights for California residents are:

Right to Know:
• You can ask us to confirm what Personal Information we hold about you including:
  o The categories of Personal Information we collected about you;
  o The categories of sources from which the Personal Information is collected;
  o The business or commercial purposes for collecting your Personal Information;
  o The categories of third parties with whom we share your Personal Information (if applicable);
  o The specific pieces of Personal Information we collect about you.
• You can ask us for a copy of this information in a readily useable format.

Right to Request Deletion:
• You can ask us to delete the Personal Information collected from you.
• You should be aware, however, that California law allows us to retain your Personal Information under certain conditions, even if you have asked us to delete it, such as when retaining your Personal Information is necessary for us to complete a transaction with you, provide you with a service you have requested, or deletion is otherwise restricted or prohibited by law, rule or regulation. We will notify you of any denial of your deletion request and the reason for such denial.

Right to Nondiscrimination:
• You have the right to not be discriminated against based on your decision to exercise any rights available to you under the CCPA.
• We will not discriminate against you because you have chosen to exercise any of your privacy rights described above.

Making a verifiable consumer request does not require you to create an account with us.

Only you, or someone legally authorized to act on your behalf, may make requests ‎related to your Personal Information‎. You may also make a request on behalf of your minor child.

How To Submit A Request to Access or a Request for Deletion: You can submit your right to access and your right to request deletion by contacting us in one of the following ways:

Calling us at 1(800) 331-2075
Sending a request via email to CCPA@wealthenhancement.com

Depending on the nature of your request, we may need to verify your identity before fulfilling your request.

Verifying your Request: In order to respond to your consumer request and to protect your privacy, we will need to verify your identity before complying with your request.

To verify your identity, we may ask you to provide Personal Information we have previously collected about you. If you are making the request for an entity, we will also ask that you provide some independent evidence that you are a representative of that entity and are authorized to make such request.

We will only use Personal Information provided in a verifiable consumer request or a deletion request to verify the requestor’s identity or authority to make the request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Using an Authorized Agent: You may use an authorized agent to submit a verifiable consumer request or a deletion request. To use an authorized agent to submit a request, you will need to provide written instruction to your agent and verify your identity to us, or provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465. The agent can submit the request as described above.

How We Will Respond to Your Requests: Upon receiving a request to know or a request to delete from you, we will confirm receipt of the request within ten (10) business days and we will provide additional information about how we will process your request. In most cases, we will respond to your requests to know and requests to delete within 45 calendar days of the day we receive your request. In certain circumstances, we may advise you that we will need to take up to another 45 calendar days to respond to your request.

Accessibility: You can receive a copy of this Policy in alternative formats upon request by emailing us at CCPA@wealthenhancement.com.

13. Contact Us. If you have any other questions or concerns about our privacy policies and practices, you can contact us in the following ways:
Attn: VP of Compliance
Phone: 1(800) 331-2075
Email: privacy@wealthenhancement.com
Corporate Address: 505 North Highway 169
Suite 900, Plymouth, MN