California Privacy Framework Disclosures

Last Modified November 7, 2023
Overview

The Independent Adviser Corporation is committed to your privacy.  To help California consumers make informed privacy decisions and compare practices across businesses, the State of California has created a common framework for businesses to talk about privacy.

We use that framework here to describe, for each category of personal information and sensitive personal information under California law, whether we collect that personal information or sensitive personal information or discloses it for a business purpose. We don't sell or share your personal information, as those terms are defined under California law. We also do not use or disclose sensitive personal information for any purposes that would require a user to exercise a right to limit according to California law. The framework disclosures on this page are intended to assist California customers but they apply equally to every state as we provide a single service of our web sites. 

Identifiers

We collect information that identifies you to provide you with services that you request. For example, we process your name, email address, and address to process transactions and to connect you with Fee-Only professionals that are closest to geographic proximity to you. And we process your mobile phone number or other provided number to communicate with you. We disclose this information to our service providers and third-party companies who process the information on our behalf to help us perform a particular business purpose in accordance with our instructions. We also provide this to Fee-Only professionals that are in our network. In some cases, we may provide this information to third parties for the business purposes requested by you, such as when we provide your name and certain information about your service to vendor to set up an account for billing purposes. Under California law, certain personal information in this category, such as social security number, driver’s license, state identification card, or passport number, may be considered sensitive. 

Characteristics of protected classifications under California or federal law

California and federal laws provide protection against discrimination if you belong to a protected class. Under California law, certain personal information in this category may be considered sensitive. Protected classes include groupings based on race, ethnicity, or national origin; religious or philosophical beliefs; sexual orientation; genetic information; family status; and whether you have a disability. We do not take steps to infer your actual family status or protected class based on your feature use.

Commercial Information

We collect and maintains a record of your transactions with us, such as the products or services that you have purchased, and the web pages you have visited on our affiliated web sites. We disclose this information to our service providers for our business purposes, for example, to process transactions that you have requested and to our network of Fee-Only professionals that you are interested in. We also share certain commercial information with third parties, such as credit card companies, in order to process your transactions. Under California law, certain personal information in this category may be considered sensitive.

Biometric Information

Under California law, biometric information includes any physiological or behavioral characteristics that can be used to establish your identity, such as a fingerprint or an image of your face from which a faceprint can be created. Under California law, certain personal information in this category may be considered sensitive. If you choose to provide or post any photos on our web sites, you may include in those photos an image of your face from which a faceprint could be made. We do not create or store faceprints of our customers and, as a result, we do not consider photos stored on our web sites or elsewhere by us to be biometric information.

Network Activity Information

We collect certain information about user activity on our electronic networks, such as how visitors interact with our websites. We use this information to help determine what pages or features are popular or where our products and services could be improved. We may also use such information for marketing purposes with your consent or other applicable legal basis.

Geolocation Data

We consider Geolocation data as data that describes a consumer’s precise location. Under California law, precise location data may be considered sensitive. We may collect information about your location to provide you services that you request, such as Connect with a Fee-Only professional. where data is stored on our servers to process your request. We also use such information to comply with laws and regulations related to securities and financial services. 

Audio, electronics, visual, thermal, or olfactory information 

We do not collect information about your senses.

Employment information 

We collect any professional or employment information that you share with us or direct others to share with or make available to us, such as the institutions that you attended, any professional degrees or certifications, or union membership.

Inferences from your personal information to create a profile about your preferences  

If you choose to personalize your services or communications when you search for a Fee-Only professional, we will use information that we collect so that we can offer you those personalized services or communications. 

Personal information described in Section 1798.80(e)  

The California Consumer Privacy Act requires that we tell you whether we collect any personal information that is described in California Civil Code Section 1798.80(e). The Code section includes a broad variety of categories of personal information, such as name, contact information, physical characteristics, credit card or billing information, and more. Under California law, certain personal information in this category, such as financial information, health information, sex life, social security number, driver’s license, state identification card, or passport number, may be considered sensitive. We collect personal information described in Section 1798.80(e). Some of this information is already described in the categories above. For a full description of how we collect and handles your personal information, we encourage you to review our Privacy Policy.

Any personal information that we hold may also be used to comply with applicable law.

Your Privacy Questions 

If you have questions about our Privacy Policy or privacy practices including where a third-party service provider is acting on our behalf, or you wish to submit a complaint, you can contact us at by completing this Privacy Related Concern Form.