Last Updated: 3/18/2019
Wealth Dynamics inc. dba Recode Marketing and its affiliates (collectively, "Recode Marketing," "our," "us," or "we") operate websites, provide products and services through mobile and other applications, and develop software. We refer to these as "site(s)," "service(s)," or "our sites and services."
This privacy policy applies to our sites and services on which we display or post a direct link to this privacy policy. This privacy policy does not apply to those sites and services that do not display or link to this privacy policy, or that have their own privacy policies. However, we often acquire new companies to expand our business. Some acquired companies may operate under their own privacy policies until we integrate their privacy practices with ours.
This privacy policy applies to all users of our sites and services and covers what information we collect and why we collect it, how we use the information we collect, and the choices you have to access and update that information. Please familiarize yourself with our practices and let us know if you have any questions. By using our sites and services, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this privacy policy. Each time you use our sites and services, the current version of this privacy policy will apply. If you do not agree to this privacy policy, please do not use our sites or services.
For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”), the Data Controller is Wealth Dynamics inc. registered in the State of Utah, United States of America with a registered address at 9890 S 1300 E ste 325, Cottonwood Heights, UT 84047.You can contact our Data Protection Officer by sending an email to privacy@recodemarketing.com or by writing to:
Wealth Dynamics inc.Attn: Legal Department9890 S 1300 E ste 325, Cottonwood Heights, UT 84047 U.S.A.
Personal information is information that can be used to identify, locate, or contact an individual, and includes other information that may be associated with personal information. When you interact with our sites and services, depending on the site or service, we may collect the following personal information directly from you:
We or our third-party service providers may collect and store certain technical information when you use our sites and services. For example, our servers receive and automatically collect information about your computer and browser, including, for instance, your IP address, browser type, domain name from which you accessed the site or service, device size and other software or hardware information. If you access our sites and services from a mobile or other device, we may collect a unique device identifier assigned to that device (UDID), type of device, general GPS location, or other transactional information for that device in order to serve content to it and to improve your experience in using the sites or services.In addition, we or our third-party service providers may collect information about how you use of our sites, including but not limited to, the date and time you visit the sites, the areas or pages of the sites that you visit, the amount of time you spend viewing the sites, the number of times you return to the sites, visits to sites outside our network, preferred language, and other click-stream data.
2.1 CookiesWe or our third-party service providers may use cookies and other tracking technologies (including browser cookies, pixels, beacons, mobile application identifiers, and Adobe Flash technology) to help us recognize you across different sites and services, improve your experience, increase security, measure use and effectiveness of our services, and serve advertising. You can control cookies through your browser settings and other tools. For more information about our use of cookies, please read our Cookie Policy.By visiting our sites and services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this privacy policy and our Cookie Policy.
2.2 Do Not TrackYou can opt-out of being targeted by certain third party advertising companies online by visiting the Network Advertising Initiative, Omniture, Aperture, PrivacyChoice, and/or Digital Advertising Alliance.We currently do not respond to "Do Not Track" browser signals. Accordingly, your navigation on our sites and services may be tracked as part of our efforts to gather user information described above. If you arrive at our sites and services by way of a link from a third-party site that does respond to “Do Not Track” browser signals, such “Do Not Track” browser signal recognition will end as soon as you reach our sites and services.
We will only collect and process personal information, including sharing it with third parties, where we have a legal basis for such collection and processing. We rely on a number of legal bases, including:
4.1 Personal Information that You Provide to UsWe may use the personal information that you provide in one or more of the following ways:
4.2 Other Information We Automatically Collect Through Cookies and Other TechnologiesWe may use information collected from you through cookies and other tracking technologies in one or more of the following ways:
We may share your personal information with third parties in the following circumstances:
You may choose to publicly disclose personal information about yourself and others in the course of (i) contributing user generated content (for instance articles, blogs, surveys, reviews, ratings, or podcasts), (ii) communicating with others in our online forums, communities, or chat rooms, (iii) creating user profiles for public view, or (iv) posting images, photos, or videos. Be aware, information that you voluntarily disclose in any of these areas of our sites or services is unencrypted, public information and, therefore, there can be no expectation of privacy or confidentiality, except if the terms of use of the site or service specifically limit use of the content (for example, we may let you know how such survey and rating responses will be used and if anonymity is an option). Any personal information you submit in the course of interacting in these public activities can be read, collected, or used by other users. Prior to posting in these areas, we encourage you to read the specific site's or service's terms of use, as we are not responsible for the personal information you choose to make public in any of these areas and strongly recommend against sharing any personal health or other sensitive information that could directly or indirectly be traced to any individual, including yourself.
We are not a lender or a broker. When you submit a loan request form using our services, we may share your loan request and related information with one or more consumer finance lending institutions and/or other lenders and dealers to evaluate your loan request in accordance with their loan terms and requirements. You authorize those consumer finance lending institutions and other lenders or dealers to access your credit report in order to evaluate your credit history and loan request and to verify the information in your loan request.We may also share the information you provide through a loan request using our services to a third-party broker, aggregator, or other referral service that will send your information to other lenders and/or dealers in connection with your loan request and in accordance with their privacy policies.
7.1 Lender Specific InformationYour loan request and information submitted using our services may be shared with one or more third party consumer finance lending institutions, other lenders, or dealers and you consent to be contacted by these third-party consumer finance lending institutions and other lenders or dealers in connection with your loan request, including by autodialer, text messaging, and/or prerecorded messages.
7.2 Consent to Electronic Signatures, Records and DisclosuresWhen you submit a request using our services to send your information to a third party lender in connection with obtaining a loan, such lender needs your consent to use and accept electronic signatures, records and disclosures related to your loan transaction and other communications with the lender. Below are your rights when receiving such electronic signatures, records and disclosures. By submitting your loan request, you are acknowledging receipt of this disclosure and consent to conduct transactions with the third party lender using electronic signatures, records and disclosures.
7.3 Fair Lending Practices – Regulation B Disclosures
7.4 Opting-Out
We encourage you to keep your personal information up-to-date and accurate. The methods for accessing, viewing, correcting, and deleting your personal information will depend on which sites or services you use and their features. You have several choices; for instance:
We retain your personal information while your account is active or as needed to provide you services. Additionally, we may retain personal information even after your account has been closed if retention is reasonably necessary to comply with our legal or regulatory obligations, resolve disputes, prevent fraud and abuse, enforce our Terms of Use or any other contract entered into between you and us, or if it is not technically feasible to delete your personal information.
Our sites and services may allow us or other users to communicate with you or other users through our in-product instant messaging services, service-branded emails, SMS, and other electronic communication channels.
10.1 Text MessagingWe may make available text messaging services in which you can receive messages from us and send messages to us on your mobile phone, which will be governed by our Text Messaging Services Policy.
10.2 Opting Out of Requested CommunicationsRequested communications include, for instance, email newsletters and software updates that may be expressly requested by you or which you consented to receive. After you request such communications, you may "opt-out" of receiving them by using one of the following methods: 1. selecting the email "opt-out" or "unsubscribe" link, or following the opt-out instructions included in each email communication; 2. returning to the web page(s) where you originally registered your preferences and following the opt-out instructions; or 3. filling out our Privacy Contact Form.
10.3 Opting Out of Transactional or Relationship CommunicationsCommunications that are sent by or on behalf of a user are indicated as being from that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists. Either type of communication may be "real time" communications or communications triggered automatically upon the occurrence of certain events or dates, such as appointment reminders. Email communications received from users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders, and cancellations. You may not be able to opt-out of receiving certain email messages, although our services may provide a means to modify the frequency of receiving them.
10.4 Opting Out of General or Promotional CommunicationsGeneral communications provide information about products, services, and/or support and may include special offers, new product information, or invitations to participate in market research. You may opt-out of receiving these general communications by using one of the following methods:
To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect, we deploy a wide range of technical, physical, and administrative safeguards, including: Transport Layer Security (TLS), firewalls, system alerts, and other information system security technologies; housing health data in secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information technology systems, facilities, and information collection, storage, and processing practices. We use reasonable and appropriate administrative, physical, technical, and data security procedures and controls to safeguard your personal and protected health information against unauthorized access, disclosure, loss, misuse, and alteration. Under applicable law, we are required to apply reasonable and appropriate measures to safeguard the confidentiality, integrity and availability of Protected Health Information (“PHI”), as such term is defined by the Health Insurance Portability and Accountability Act, the Health Information Technology for Economic and Clinical Health Act (collectively referred to herein as HIPAA), residing on and processed by our sites and services.We use third-party service providers to manage credit card and payment processing. These service providers are not permitted to store, retain, or use billing Information except for the sole purpose of credit card and payment processing on our behalf. When you enter payment information to be processed by our third party service providers, we encrypt the transmission of that information using transport layer security (TLS) technology and do not store it on our systems.It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our services. We cannot assume responsibility or liability for unauthorized access to our servers and systems. When disclosing any personal or protected health information, you should remain mindful of the fact that it is potentially accessible to the public and, consequently, can be collected and used by others without your consent. Accordingly, you should carefully consider if you want to submit sensitive information that you would not want disclosed to the public and should recognize that your use of the Internet and our sites and services is solely at your risk. You are ultimately responsible for maintaining the secrecy for all your personal information, including your protected health information. Except as provided in a Business Associate Agreement between us and a healthcare provider, we have no responsibility or liability to anyone for the security of your personal or protected health information transmitted via the Internet.
Our sites and services may link to other sites or services operated by our affiliates or third parties, and may carry advertisements or offer content, functionality, newsletters, contests or sweepstakes, or applications developed and maintained by third parties. We do not exercise control over third party sites or services. We are not responsible for the privacy practices of any such third parties. Once you leave our sites or services via a link, enable a third-party service, or click an advertisement, you should check the applicable privacy policy of the third-party's site or service. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third party nor is it an endorsement of their privacy or information security policies or practices.We may also provide social media features on our sites and services that enable you to share personal information with your social network(s) and to interact with our sites and services. Depending on the features, your use of these features may result in the collection or sharing of personal information about you. We encourage you to review the privacy policies and settings on the social media site(s) with which you interact.
Our sites and services may collect, disclose, use, and store PHI that you submit to your healthcare provider or that your healthcare provider submits to us. Our collection, disclosure, use, and storage of PHI, is governed by HIPAA.
13.1 Use and Disclosure of Your Protected Health Information
When you use certain services (for example, appointment request) the PHI that you submit is used and disclosed by us as a Business Associate, as defined by HIPAA, according to the terms of the Business Associate Agreement between us and your healthcare provider. Accordingly, we may only use and disclose your PHI on behalf of, or to provide services to, your healthcare provider according to the terms of the Business Associate Agreement. There are exceptions to this use and disclosure restriction. Under such exceptions, we may use and disclose your PHI (i) for our internal management and administration; (ii) to carry out our legal obligations; and (iii) to perform data aggregation services for your healthcare provider and other healthcare providers; provided that, any disclosures for our internal management and administration or to carry out our legal obligations are either required by law or made after we obtain reasonable assurances from the party to whom the PHI is disclosed that such PHI will be held confidentially and used or further disclosed only as required by law or for the purpose for which it was disclosed to such party. We may subcontract some of our services. In doing so, we require our subcontractors to comply with the same terms and conditions for PHI that apply to us as a Business Associate.As a Business Associate, we may be permitted to de-identify your PHI. We de-identify PHI in accordance with the criteria prescribed by HIPAA. We may use and disclose any such de-identified information in the same manner as personal information under this privacy policy.This section does not provide you with any right under this privacy policy, HIPAA, or any other law or regulation.
13.2 How to Access, Change, or Remove Your PHI
Subject to certain exceptions, HIPAA establishes rights with respect to your PHI. These rights generally include the right to restrict the uses and disclosures of your PHI, the right to access and receive a copy of your PHI, the right to amend your PHI, and the right to receive an accounting of the disclosures of your PHI. If you wish to exercise any of these rights, please contact your healthcare provider.Please note that you are not entitled to review the content of another user's account. Accordingly, if you have used our sites and services to share personal information with another user or third-party, you may not be entitled to access, update, or delete the information that you shared. Further, please note that other users may submit information that identifies you, and you may not be entitled to access, update, or delete that information. In either case, certain users, such as healthcare providers, may be required by HIPAA and other applicable laws or regulations to retain such information for extended periods of time.Most of our Business Associate Agreements require us and our subcontractors to either return or destroy PHI received or created pursuant to the business associate relationship upon the termination of the Business Associate Agreement. Accordingly, if the Business Associate Agreement between us and your healthcare provider has been terminated, then any PHI that you submitted to our sites and services, or otherwise maintained by us or a subcontractor in connection with our sites and services, will be returned to the healthcare provider or destroyed by us or such subcontractor.
Children under the age of 13 are not permitted to use our sites and services. We do not knowingly collect personal information from children under the age of 13 or utilize plug-ins or ad networks that collect personal information through child-directed third-party websites or online services. If we learn that we have collected personal information from a child under 13, we will take steps to promptly delete such information.Our sites and services generally require users to be at least 18 years of age. Unless our sites and services contain the "Privacy Rights for California Minors in the Digital World" supplemental terms, our sites and services do not collect age from users under 18. Without limiting the generality of the foregoing, our services may allow users above the age of 18 (such as healthcare providers, parents, and guardians) to submit personal information of minors. Such users assume full responsibility over their submission, use, and transmission of such information.
We are headquartered in the United States. Our sites and services are hosted and administrated in the United States or hosted with cloud service providers who are headquartered in the United States and are intended for users in the United States. If you are located outside the United States, be aware that information you provide to us or that we obtain as a result of your use of our sites and services may be processed in, transferred to, and stored in the United States and will be subject to United States law. The privacy and data protection laws of the United States may be different from the laws of your country of residence.By using our sites and services or providing us with your information, you consent to the transfer of your information to the United States for processing and storage.
FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and you have provided us with your personal information, you may request information about our disclosures of certain categories of your personal information to third parties for direct marketing purposes. To make such a request, please fill out our Privacy Contact Form with “California Privacy Rights” in the subject line and allow 30 days for a response. We will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.FOR RESIDENTS OF CALIFORNIA UNDER THE AGE OF 18. In accordance with Section 22581 of the California Business and Professions Code, you may request and obtain the removal of content or information you have publicly posted. To make such a request, please fill out our Privacy Contact Form with “California Privacy Rights” in the subject line. Please specify the site(s) or service(s) to which your removal request relates, including any URLs where the content or information is posted, and the specific content or information you posted for which you are requesting removal. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
FOR RESIDENTS OF THE EUROPEAN UNION ONLY. Under European data protection law, in certain circumstances, you have the right to:
In addition, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes.You can exercise any of these rights by filling out our Privacy Contact Form or sending an email to privacy@recodemarkering.com with “EU Privacy Rights” in the subject line. If you believe that we have not complied with its obligations under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority.
If you have any questions or concerns about this privacy policy or our practices you can contact us or write to us at Recode Marketing, Privacy Office, 9890 S 1300 E ste325, Cottonwood Heights, Utah 84047 U.S.A. Please be sure to identify the specific website, software, or service about which you have a question or concern and how we can contact you.
We may revise this privacy policy from time to time and, if we do, we will update it on this page and modify the "Last Updated" date. If our information practices change in a significant way, you will be provided notice by means of notice on our sites or otherwise in writing. Because our privacy policy can change at any time, we encourage you to reread it periodically to see if there have been any changes that affect you. If you disagree with any changes to this privacy policy and do not wish your information to be subject to the revised privacy policy, you will need to deactivate your account or terminate your services. Your use of our sites and services following any such change constitutes your agreement that all information collected from or about you through our sites and services after the revised privacy policy is posted will be subject to the terms of the revised privacy policy.