EFFECTIVE DATE: May 22, 2023
2. INFORMATION COLLECTED. In order for you to gain access to information about the services that we offer via the Cy Platform you were required to create an account on www.wbicy.com (the “WBI Account”). To create this WBI Account you were required to register and provide us with certain information that personally identifies you (“Contact Data”). Contact Data includes information such as name, user name, email and password. In order to purchase a seat license for the use of the Cy Model Portfolio Services available on the Cy Platform you must then provide certain payment information (“Personal Information”). Personal Information is provided via a third party payment processing vendor and includes financial data such as bank account or credit card information necessary to complete payment. Once you establish an WBI Account and purchase a seat license to use the Cy Platform, you will enter additional Contact Data in order to create your account on the Cy Platform (the “Cy Account”). Upon creation of your Cy Account or when subsequently logging into the Cy Platform, you will have the option to enter information (the “Optimization Information”), about the risk profile and rate of return requirements, in addition to other fields, that will inform the optimization engine about which optimized portfolio to display. Certain programs on the Cy Platform require very few pieces of Optimization Information while others allow for a significant amount of client Optimization Information to be entered in order to provide a more customized result. In order to obtain the more customized result, clients will have the opportunity to enter Optimization Information that includes, but is not limited to, current net worth, liquid assets, date of birth, age of planned retirement, current salary, income needs in retirement, etc.
We may collect information from you via the Cy Platform, including your use of, and activities on, the Platform.
The Personal Information and Optimization Information (together the “Information”), including any personally identifiable information, that you provide and that we collect will be stored and maintained by WBI-Cy for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) and the use(s) for which such information was collected, or (b) to comply with applicable laws, contracts, or other rules or regulations.
To provide Services to you;
To generate Cy Processed Data;
To contact you, including via email, to respond to your comments or requests for information;
To troubleshoot problems with the Platform, or any services, as requested;
To improve our products and services and identify, develop or offer new products and services;
To contact you with more information about WBI-Cy and its services;
To generate aggregate statistical studies and conduct research which may be used in marketing our Services to you or to third parties;
To offer you products or services offered by WBI-Cy’s authorized partners; or
To provide any legitimate business service or product.
We may combine personal information about you received from several sources, including without limitation, the information described above for the Subscription Purpose and/or to generate Cy Processed Data. As provided in the Terms of Service, we may share the Cy Processed Data, in an aggregated non-personally identifiable manner with third parties.
3.1. LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.
3.2. PUBLIC INFORMATION. The Cy Platform may contain links to other websites. We are not responsible for the privacy practices or the content of such websites.
5. ASSIGNMENT OR TRANSFER. If WBI-Cy is involved in a transaction such as a merger, stock purchase, bankruptcy or sale of substantially all WBI-Cy’s assets, the Information, including any personally identifiable information may be transferred to the other party in such transaction. You will be notified via email and/or a prominent notice through the Cy Platform of any change in ownership (other than where the new owners are affiliates of WBI-Cy) or uses of your personal information, as well as any choices you may have regarding your personal information.