Legal

Privacy Policy

Effective Date: September 1, 2015

Commas (“Commas”, “Company”, “we”, or “us”) respects your privacy and is committed to protecting it through compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you use https://www.usecommas.com (the “site”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. Use of the site is governed by the laws of the United States.

When you provide us with information, you acknowledge that the information will be stored and processed on servers located in the United States.

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 site. By downloading or using this site, you agree to this privacy policy.

This policy may change from time to time. Your continued use of this site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Investing with Commas

You may invest using Commas’ services by clicking on the “Invest Now” or “Log In” buttons. That link will take you to our advisor-branded site onhttp://www.betterment.com. The investment relationship, and the information you provide through that link, are not governed by this Privacy Policy or this site’s Terms of Use. They are instead governed by our Client Engagement Agreement, Privacy Policy Statement, and Betterment’s Privacy Policy, all of which will be presented to you when you sign up.

2. Children Under The Age Of 13

Our site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this site or on or through any of its features, register on the site, make any purchases through the site, use any of the interactive or public comment features of this site, if any, or 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. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us atclaire@usecommas.com.

3. Information We Collect About You And How We Collect It

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

• By which you or others may be personally identified, such as name, postal address, email address, and phone number (“personal information”).
• That helps us connect with one another, such as meeting location and anything else you want to share.
• About your internet connection, the equipment you use to access our site and 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 device information collected through cookies, web beacons, and other tracking technologies.

4. Information You Provide To Us

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

• Information that you provide by using the scheduling functionality of the site. We may also ask you for information when you fill out a survey or when you report a problem with our site.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your search queries on the site.

5. Automatic Information Collection

When you download, access, and use the site, we may automatically collect certain details of your access to and use of the site, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the site. We use the following technologies to collect this information:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our site. 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 site.

Web Beacons. Pages of the site may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, and single-pixel gifs) that permit us to do things like count users who have visited those pages, record the popularity of certain site content, and verify system and server integrity.

6. How We Use Your Information

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

• To present our site and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide 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 notify you about changes to our site or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our site.
• To market our products or services to you.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

7. Disclosure Of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• 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.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Commas, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

8. Accessing And Correcting Your Personal Information

You may send us an e-mail atclaire@usecommas.comto correct or delete any personal information that you have provided to us through this site. 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.

9. Choices About How We Use And Disclose Your Information

If you do not wish to have us use your email address to promote our own products or services, you may opt out by contacting us atclaire@usecommas.com. You may also unsubscribe by using the link in any email message you receive. We may, however, still use your email address to contact you regarding your use of our service.

10. Data Security

We have implemented measures designed to secure your personal information 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.

The transmission of information via the internet is not completely secure. While we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our site.

Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the site.

11. California Privacy Rights

We do not comply with requests under California Civil Code Section § 1798.83 because we do not disclosure your personal information to third parties for their direct marketing purposes. We also do not respond to Do Not Track browser signals.

12. Contact Us

Please send your feedback, comments, requests for technical support, notices of copyright infringement and other communications to us atclaire@usecommas.com