Privacy Policy

This is not the current Privacy Policy. It is retained here for historical comparison purposes. Click here to view the current Privacy Policy.

Last modified: December 12, 2022

Advis Network, Inc. (“Advis Network”, “Advis”, the “Company”, “we” or us”) provides a Software-as-a-Service website (“Website”) for financial advisors and wholesalers to connect and better share information about financial products. We offer a subscription-based service (monthly or yearly) for certain features, in particular more granular data about financial advisors who might be interested in their products (lead generation) (“Service”).

Today, our Website is available in its entirety to all who visit. Over the next few months, as we develop and launch new features and benefits on our Website, visitors will be required to register to access some of those new features and benefits. We will continue to expand our Website and offer more exclusive features and benefits to those who subscribe to our Website and Service. In time, only those who subscribe to our Service will have full access to the features and benefits of our entire Website (See Terms of Use). Unless otherwise defined in this Privacy Policy, terms used in this policy have the same meanings set forth and used in our Terms of Use.

This Privacy Policy describes our privacy principles which we implement on our website and in providing our Service:

Notice. Our Policy informs you of the types of Personal Data collected, and how it is collected, used, and shared.
Choice and consent. Our Policy informs you of your choices regarding how your Personal Data is used or disclosed and where and when we need to obtain your consent if it is used for purposes unrelated to our business purpose or our business interaction with you.
Access. We also describe in our Policy how you can access, correct, and remove any Personal Data collected by the site.
Security. Finally, this policy describes the steps taken by us and our site operator to protect Personal Data.

Introduction

At Advis Network, we respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy describes the types of information we may collect from you or that you may provide when you visit the website Advis.Network (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by us or any third-party; or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

By which you may be personally identified, such as your first and last name, nick names, postal address, work e-mail address, telephone number, employer, job title, and other optional identifiers you provide such as your LinkedIn profile URL, Twitter username, financial user type (individual investor, financial advisor, research professional, etc.), user website URL or any other identifier by which you may be contacted online or offline (“Personal Data”);
That is about you but individually does not identify you, such as IP Address, Browser, Browser Version, current URL, device type, OS, initial path name, referrer URL, referring domain. We also collect usage data, including information such as which pages and products of our website you visit, what products interest you, when you log in and out of our site, how long you are on our site, click usage information, such as which pages you visit and how long you visit on each page and/or
About your internet connection, the equipment you use to access our Website, and other usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Advis Network may Process your Personal Data because:

It’s necessary for us to perform the Services subject to our contract with you.
You have given us permission to do so, through authorizing us to perform as a Data Controller on your Personal Data.
We have a legitimate business interest in doing so in order to provide the Services to you, and is only overridden if you opt out and terminate your use of the Service.
We must process the data as described in this Policy in order to comply with applicable law.

Our Legitimate interests are:

To improve and personalize your experience with us and our Website and to tailor communications to you;
To monitor and improve the performance of our products and Services for administrative, security and fraud prevention purposes;
For our own internal functions, management and corporate reporting, and internal research and analytics; and
To enforce compliance with our terms of use and other policies or otherwise in connection with legal claims, compliance, regulatory and investigatory purposes as necessary.

We may require and rely on your consent:

Where we share your information with other users using the service;
Where you ask us to send marketing information (e.g., newsletter updates);
Where you give us consent to place cookies or similar technologies;
On other occasions where we ask for your consent, for the purpose we explain at the time.

Information You Provide to Us

The information we collect on or through our Website may include:

Information that you provide by filling in forms on, or other responses you provide to, our Website. This includes information provided at the time of Subscribing or otherwise registering to use our Website, register to receive newsletters or email updates, submitting a Service request, frequency in use of each of our Services, requesting additional Services, accessing or downloading materials created by us or by others, accessing or using social media buttons and connections, or using an access point on our site to link out to third-party site or services. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys or other questionnaires that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website, the scope of your subscription and the features and benefits that interest you most. You may be required to provide financial information before placing an order through our Website which uses Stripe to process all Subscription other payments, if applicable.
Your search queries on the Website.

‌Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, UIDs or URLs that could be used to identify you, traffic data, logs, and other communication data and the resources that you access and use on the Website. Once a visitor “opts in”, our website will collect.
Information about your computer and internet connection, including your IP address, operating system, and browser type, such as your Browser, Browser Version, OS, IP Address, Initial Browser, Initial Browser Version, Initial Current URL, Initial Device Type, Initial OS, Initial Path Name, Initial Referrer URL, and Initial Referring Domain.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Although you must opt-in for most tracking, See Choices About How We Use and Disclose Your Information for how you can opt-out of behavioral tracking on this website, after you have already opted-in, and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically, directly or indirectly, includes Personal Data, or we may maintain such information or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns;
Store information about your preferences, allowing us to customize our Website according to your individual interests;
Speed up your searches; and
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We use cookies and similar technologies to perform certain website functions. Although most browsers now automatically accept cookies by default, where optional, our Website requires that any visitor, registered user or Subscriber “Opt-In” by clicking the applicable button. Cookies can also be set so that you may choose to enable or disable some or all of these cookies, and even decide on a case-by-case basis, but disabling some of them may affect your experience with the site, including losing your access to certain parts of our Website. You may disable the cookies by activating the appropriate setting on your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- “Necessary” cookies are required to enable the basic features of this Website, such as providing secure login, providing support, or adjusting your consent preferences. Necessary cookies are always stored as they are essential for enabling the basic functionalities of our Website. You may not opt out of these cookies and still use our Website. A necessary cookie, for example, tracks whether you opt-in to Functional Cookies.
- “Functional” cookies are used to understand how visitors interact with the Website, to help us improve the product, and to deliver personalized content, sometimes referred to as online behavioral marketing (“OBA”). You would Opt-in to this feature to maximize your Website experience.
Web Beacons. Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have opened an email and for other related statistics.

We do not collect Personal Data automatically. We may, however, tie the information we do collect automatically to Personal Data about you that you provide to us, or that we collect from other sources.

How We Use Your Personal Data and Other Information

We use information that we collect about you or that you provide to us, including any Personal Data:

To present our Website and its contents to you.
To administer access to your accounts, including provide you with notices about your account, Subscription, including expiration and renewal notices, and even your Personal Data.
To manage our customer relationships and provide you with customer support.
To process orders, provide our products and Services and send you related communications.
To provide you with information about Services the you request from us.
To fulfill any other purpose for which you provide it.
To notify you about changes to our Website or any products or the Services we offer or provide though it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To allow you to participate in interactive features, to the extent we provide such features on our Website. In any other way we may describe when you provide the information.
For any other purpose with your consent.

Disclosure of Your Personal Data and Other Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

To contractors, service providers, and other third parties we use to support our business. All such third-parties are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them and on terms consistent with this Policy. This includes, for example, contractors who host our Service and those that provide customer support to our customers, like you. Specific contractors with whom we share your Personal Data include:
Amazon Web Services (AWS) who hosts our Service on the internet to make it available to you (you can find Amazon’s privacy policy at https://aws.amazon.com/privacy/). You may also find our agreement with AWS to provide hosting services at https://aws.amazon.cm/agreement/);
Stripe, Inc. who provides our payment processing services (you can find Stripe’s Privacy Policy at https://stripe.com/privacy);
Intercom, Inc., who provides customer support to our users and Subscribers as well as other interactions (you can find Intercom’s privacy policy at https://www.intercom.com/legal/privacy ); and
Sentry, Inc. who provides us technical assistance such as error tracking in our Website performance (you can find Sentry’s Data Security and Privacy Policy here https://sentry.io/security/#data-security-and-privacy); and
Posthog, Inc. who provides Website product analytics we use to improve our product (you can find Posthog's Privacy Policy at https://posthog.com/privacy); and
Microsoft, through its Microsoft Office 365 product line provides us support in infrastructure and communications, and other Processing activities. You can find Microsoft’s data privacy policy and statement at https://privacy.microsoft.com/en-us/privacystatment.
To third parties to market their products or services to you, if you have consented to such disclosures by opting in. We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use Your Personal Data and other Information.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” or “refer a colleague” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
For any other purpose disclosed by us when you provide the information.
With your consent.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Advis Network’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Advis Network about our Website users is among the assets transferred.

We are not responsible for how any third-party treats your Personal Data and other information where they obtained your Personal Data and other information independently from us. To learn and understand how those third parties treat your Personal Data, you must visit each of their websites and review each of their privacy policies.

We may also disclose your Personal Data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Advis Network, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information. When you register as a user on our Website, we ask you whether you want to opt-In to marketing and advertising on our Website and through our Website. You signify your choice by clicking “Accept All” on the Cookie Consent Popup. If, however, you should change your mind while you are a registered user or Subscriber on our Website, you may signify your change of choice as follows:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible to you or not function properly. In particular, by disabling “Functional” cookies, you would lose access to some Website benefits and features.
Disclosure of Your Information for Third-Party Advertising. We do not share your Personal Data with unaffiliated or non-agent third parties for promotional purposes. If you do not want us to share your other information (e.g. usage data, etc.) you can choose to not opt-in to such sharing and usage of your information by either (i) clicking on the applicable button located on “Customize Cookie Preferences” modal or (ii) indicating your choice on the registration form on where you provided and we collected your Personal Data. You can also always change your choice and either opt-in or choose to not opt-in to certain disclosures and information sharing by logging into the Website and adjusting your user preferences in your account profile, including checking or unchecking the relevant boxes or by sending us an email with your request to support@advis.network.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website (https://thenai.org/).

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request on our website advis.network/privacy or email a request to support@advis.network . However, please know we do not currently sell any data that would trigger that statute’s opt-out requirements.

Legal Basis for Processing Personal Data Under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), the legal basis for our collecting and using your Personal Data, as described in this Privacy Policy, depends on the type of Personal Data we collect and the specific context in which we collect it. If you wish to be informed what Personal Data we hold about you, and if you want it corrected, amended, limited or removed from our systems, please contact us at support@advis.network. The EU General Data Protection Regulation ((EU) 2016/679) (GDPR) and EU Privacy and Electronic Communications Directive (2002/58/EC) (E-Privacy Directive) govern the Collecting, Controlling, Processing, storing, using and disclosing of the Personal Data of any person who is part of the EU.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible and within your account settings, you can access, update or request deletion of your Personal Data directly. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. If your Personal Data is inaccurate or incomplete in our Service, you have the right to have that information rectified.
The right to object. You have the right to object to our Controlling and or Processing of your Personal Data. If you do object, you must terminate your use of our Service.
The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
The right to data portability. You have the right to be provided with a copy of your Personal Data and other information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time. Please note that we may ask you to verify your identity before responding to such requests. Where Advis Network relied on your consent to process your Personal Data and provide you the Service, you may not be able to access the Service after your consent is withdraw.

The design of our Service requires Processing of Personal Data. If you choose to withdraw your consent or otherwise prohibit us from serving as your Data Controller with respect to your Personal Data provided to our Services, or processing your Personal Data, you must terminate the Service.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Accessing and Correcting Your Information

You can review and change your Personal Data by logging into the Website and visiting your account profile page.

You may also send us an email at support@advis.network to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Data to or on the Website. We do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, nor should you register on the Website, subscribe to our Service, provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use, nor should you use any of the interactive features of this Website, should any be made available. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@advis.network.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All of your Personal Data is collected, Processed, and stored in the United States. We further safeguard your Personal Data by using encryption keys. All Personal Data will be encrypted at rest. All payment transactions and related Personal Data is encrypted at all times. Protection of your Personal Data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee the absolute security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Your continued use of our Service constitutes your consent to the risks involved if any of your Personal Data were to be exposed while being transmitted, Processed or stored through our Service.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of our home page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Definitions

Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person who can be identified from such data (or such data and other information either in our possession or likely to come into our possession). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Usage Data

“Usage Data” is data collected automatically through use of the Service or from the Service infrastructure itself (for example, the duration of a page visit), on a de-identified basis, where it is aggregated, Processed and stored on a limited basis.

Data Controller

“Data Controller” means the natural or legal person, public authority, agency or other body which who (either alone or jointly or in common with other persons) determines the purposes, means and manner for which any Personal Data are, or are to be, collected, processed, used and stored.

Data Processor

“Data Processor” means any natural or legal person who is authorized to Process Personal Data on behalf of the Data Controller, including a Data Owner or Data Subject.

Data Owner (or User)

Data Owner is any living individual who is using our Service and is the owner, or legal guardian of the owner, of the Personal Data.

Processing

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction,

Cookies

Cookies are small pieces of data collected and stored on your device (computer or mobile device). Some cookies are necessary to use our Service and Website and some cookies are functional.

For the purpose of this Privacy Policy and our Terms of Use found at https://advis.network/terms, your use of our Website and our Service operates as your consent to permit us to serve as a Data Controller of your Personal Data which will be collected, stored, used and other wise Processed by our Website and or Service as described in this Policy. If you do not so consent to our serving as your Data Controller, and the Processing of your Personal Data, you must terminate your use of the Service.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Advis Network, Inc.

202 S. Cook Street, Suite 210

Barrington, IL 60010

support@advis.network

Appendix A: List of Cookies

Cookie Name	Category	Purpose	Duration	Description
ph_phc_[app_id]_window_id	Persistent, functional	Unique anonymous identifier	6 months	Anonymous visitor cookie.
posthog_csrftoken	Persistent, necessary	CSRF protection cookie, required to validate any POST request	6 months
CognitoIdentityServiceProvider.[app_id].[user_id].[sub]	Persistent, necessary	Required to maintain logged-in sessions	Varies	Local storage, refreshed as needed to maintain the logged-in session
intercom-id-[app_id]	Persistent, necessary	Unique anonymous identifier	9 months	Anonymous visitor cookie.
Intercom-session-[app_id]	Persistent, necessary	Keeping track of Intercom messenger sessions	1 week	Identifier for each unique browser session.
ck-consent	Persistent, necessary	Tracks user’s cookie preferences	1 year	The cookie is set to remember the visitor's consent settings.
ck-functional	Persistent, necessary	Tracks user’s functional cookie preferences	1 year	The cookie is set to remember the visitor's consent settings.

Appendix B: Changelog

December 12, 2022: Added Posthog to the list of data processors. See previous version.