Privacy Policy

Doing business with Total Wealth Inc. (“TWI”, “we” or “us”), using our website, www.totalwealthtracker.com and/or any and all “Total Wealth” branded URLs and other URLs which may be used by us from time to time and all components thereof (collectively and each, the "Website") and receiving and using products and services from us (including but not limited to our TOTAL WEALTH TRACKER software application) involves providing information about yourself.  We take our users’ privacy seriously – and our users have control over how their information is collected, used and disclosed by us.   

We also recognize that the growth of software as a service “(SaaS) and other online services, including Internet services generally, have created additional privacy concerns, particularly for consumers.  We maintain strict privacy policies in an effort to safeguard personally identifiable information (“Personally Identifiable Information” or “PII”) and communications from unauthorized intrusions.  Online privacy concerns focus primarily on the protection of PII which an individual or another customer reasonably expects to be kept private.  As the term suggests, PII is information that, when associated with an individual identifies that individual, for example, a customer’s name, address, telephone number, e-mail address or credit card number.

The products and services offered by us include those offered through the Website and all other products services, programs and materials we provide through the Website and/or otherwise, including but not limited to our TOTAL WEALTH TRACKER software application (collectively, the "Deliverables", which term also includes the Website generally).

The following is our privacy policy (this "Privacy Policy"), which forms part of our End-User License Agreement (the "EULA") and is an integral part thereof.  By using the Website and/or the Deliverables (including but not limited to browsing the Website and/or downloading software and/or other materials from/through the Website and/or elsewhere), you agree to be bound by this Privacy Policy and the EULA.
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What this Privacy Policy Covers

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• This Privacy Policy covers our treatment of the information we collect when users (also referred to herein as “you”) visit the Website and/or when you receive and/or use the Deliverables.
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• This Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage, including without limitation, any of our affiliates and business partners.
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Information Collection and Use

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• When you create an account with us (a “Client Account”) and/or receive and/or use the Deliverables, we may require and retain certain information, including but not necessarily limited to your name, phone number, email address and/or credit card information.
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• When you use the Deliverables, we may require and retain certain confidential financial information, including but not necessarily limited to banking and investment details.
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• If you create an account with us, your activity history may be retained in your Client Account.
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• We may automatically receive and record non-PII (i.e. information that does not identify you personally) on server logs from your browser, including your IP address, cookie information and the page you requested.  User IP addresses may also be recorded for security and monitoring purposes.
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• We and/or our third-party service providers may use collected/provided information for the following general purposes: 
  
  (a) to fulfill your requests for certain services, information and/or materials; and
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  (b) to protect you, us and/or other users from error, fraud and unauthorized access to and/or use of the Website and/or the Deliverables.
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Information Sharing and Disclosure by TWI

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• We will not share PII or confidential financial information about you to other companies or persons except when: 
  
  (a) We have your consent to share the information;
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  (b) We need to share the information with individuals and/or companies who work with and/or on our behalf to provide to you the Deliverables that you request;
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  (c) We reasonably believe it is necessary to share PII:
  
  -to investigate, prevent or take action regarding potentially illegal activity or activity that threatens the network or otherwise violates the EULA, 
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  -to investigate, prevent or take action regarding situations involving potential threats to the physical safety of any person, or
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  -for risk management purposes;
  
  (d) We are required to disclose PII and/or confidential financial information by reasons of a court order, subpoena, search warrant, or other legal process or in the case of imminent physical harm to you, us or others, or 
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  (e) to establish or exercise our legal rights or defend against legal claims.
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Technical Allowances / Software Installation

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• You understand and acknowledge that the technical processing and transmission of the Deliverables may involve (i) transmissions over various networks and/or (ii) changes to conform and adapt to technical requirements of connecting networks or devices.
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• We and/or our third-party service provider(s) and payment processor(s)may perform technical functions necessary to offer the Deliverables.  You agree to allow us to perform such technical functions and that such technical functions may include the installation of software on your device.
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• You agree to allow us to install any software selected by you through the Website, the Deliverables and/or other sources on your computer and/or mobile device.
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Cookies and Usage Data

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• When you access the Internet, the computers that host websites you visit (“web servers”) automatically receive some anonymous information. This “usage data” may include a record of which pages a web browser has visited.  The Website’s servers receive usage data when users visit the Website and possibly when users visit other sites as well.  We, our service provider(s) and payment processor(s), and our respective advertisers may use various kinds of software devices to collect information about Internet use.
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• We may use cookies and other tools to customize the content and advertising you receive based on the information you provide to us.  The information used for this feature does not provide your PII or identify you as an individual to third parties but will involve the processing of certain related data such as IP addresses.
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• Small files called “cookies” may be attached to your Web browser, computer and/or mobile device.  You may be able to configure your browser/computer/device to accept or block all or some cookies, or notify you when a cookie is set.  Each browser/computer/device is different, so check the "Help" menu of your browser/computer/device to learn how to change your cookie preferences.  Note: Disabling cookies may mean that we may not be able provide certain Deliverables which may be of use to and/or requested by you.
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• We may also use "web beacons" to access our / the Website’s cookies inside and outside the Website and in connection with the Deliverables.
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Links & Third Party Applications

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• We may provide, and the Website and/or Deliverables may contain, links to other websites and/or third-party software and/or content.  Although we strive to only link to third parties that share our high standards and respect for privacy, we are not responsible for the content or practices employed by other websites or parties.
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• Third party applications (such as widgets) created by third party developers may also be available on the Website and/or the Deliverables.  Third party applications are small bits of software, often with interactivity, that can be installed into profiles or shared with other users.  We do not control third party developers and cannot dictate their actions.  When you engage with a third party application, you are interacting with the third party, not with us.  We strongly encourage you to not provide PII to any third party unless you know the third party with whom you are interacting. 
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• If you go to a third website / software portal, including an advertiser’s website (for example by clicking on an advertisement), or request information or enter a contest, be aware that you may be authorizing third party, including an advertising company, to use information you supply.  The collection and use of information by others are subject to the third party’s/parties’ own privacy policies, not this one.  
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• When you leave the Website and/or any Deliverable via a link, access a third party application (such as a widget) or click on an advertisement, you should check the applicable privacy policy of the third party or advertiser to determine, among other things, how they will handle any PII they collect from you.
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Editing and Deleting Information

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• You have the right to access, verify and update your PII and confidential financial information collected and maintained by us at any time, including whether you want us to contact you about specials, new products and/or services and contests.  You may modify or remove any of your PII at any time by emailing us at [email protected]; provided however that to maintain an account you must provide us with an email address.
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• We honour requests from users to review all PII maintained in reasonably retrievable form, and will correct any such information which may be inaccurate.  You may also verify that appropriate corrections have been made. ‍
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Confidentiality and Security

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• We have safeguards to protect your PII and confidential financial information and we use commercially reasonable measures to safeguard PII and confidential financial information in our possession against loss, theft and unauthorized use, disclosure or modification.
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• We use commercially reasonable methods to make sure that PII and confidential financial information is accurate, up-to-date and appropriately complete.
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• We limit access to PII and confidential financial information to people who, as part of their job, we believe need to come into contact with that information to provide the Deliverables to you.‍
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• Despite our high standards, no claim is made as to the impenetrability of our system under unusual circumstances or its resilience to future attacks.  
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Communications

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• By using the Website and/or the Deliverables, and in particular downloading any TWI software through the Website and/or other sources, you agree and consent that we, our partners and/or our affiliates may communicate with you via such methods of communications as may be necessary and/or advisable by us from time to time in our sole discretion, including but not limited to regular mail and email, whether specifically addressed to you or addressed to multiple parties.  
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• You hereby consent to the exchange of information and documents between us electronically over the Internet or by e-mail, including any exchange of information and receiving electronic communications from time to time, including updates, publications, announcements, messages (including marketing messages), and other communications, between any e-mail address which you provide to us and email addresses ending in “totalwealthtracker.com” or any other e-mail address which we may provide to you until such time as you withdraw your consent by notifying us that you no longer wish to receive our electronic communications. 
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• You may withdraw the foregoing consents at any time.  However, we note that we may not allow for communications in paper format or through other non-electronic means and it may be difficult or even impossible to provide access to and/or use of certain Deliverables without such consent.  Therefore, if you withdraw your consent, your use of the Website and/or other Deliverables may be interrupted, limited and/or terminated.  In order to withdraw your consent to direct communications from us to you, contact us at [email protected].
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Changes to this Privacy Policy

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• We will keep this Privacy Policy current and as such may amend this Privacy Policy from time to time.
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• We will inform you of any changes we make by sending a notice to you via email and/or by posting an announcement on my website (as applicable).
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Questions / Suggestions / Concerns

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• If you have questions, concerns or suggestions about us, the Website or the Deliverables, please feel free to email us at [email protected].
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• If you have questions, concerns or suggestions about this Privacy Policy or its implementation, please email us at [email protected].
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• If you notice any unauthorized activity with respect to your account, account name or password, please immediately email us at [email protected].
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DO NOT BE MISLED BY EMAILS THAT APPEAR TO BE FROM US AND ASK FOR YOUR PERSONAL INFORMATION. IF YOU RECEIVE A SUSPICIOUS EMAIL REQUESTING YOUR PERSONAL INFORMATION, PLEASE FORWARD THE EMAIL IMMEDIATELY TO [email protected] SO THAT WE CAN INVESTIGATE THE EMAIL AND, IF NECESSARY, PROVIDE A SECURITY ALERT TO OUR USERS.PLEASE DO NOT SEND CONFIDENTIAL PERSONALLY IDENTIFIABLE INFORMATION SUCH AS PASSPORT NUMBERS, GOVERNMENT IDENTIFICATION NUMBERS, OR CREDIT CARD INFORMATION TO US VIA AN UNSECURED EMAIL MESSAGE.