Facts: What does Hadley do with your personal information?
This notice applies to any Hadley Investment Co. (“Hadley”) customer with a registered account who seeks financial advisory services, including advice related to 529 savings plans and other financial services through Hadley’s platform.
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect, and share depend on the product or service you have with us. This information can include:
Your contact details, demographic information, and date of birth
Income
Current 529 investment portfolio, including account number
Account balances, transactions, and transaction history
Tax-related information
Your contact list
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Hadley chooses to share its customers’ personal information, and whether you can limit this sharing.
Reasons we can share your personal information
Does Hadley share?
Can you limit this sharing?
For our everyday business purposes–
such as to process your transactions, provide you with the services you request, maintain your account(s), respond to court orders and legal investigations
Yes
No
For our marketing purposes–
to offer our products and services to you
Yes
No
For joint marketing with other financial companies
No
We do not share
For our affiliates’ everyday business purposes–
information about your transactions and experiences
Yes
No
For our affiliates’ everyday business purposes–
information about your creditworthiness
No
We do not share
For affiliates to market to you
No
We do not share
For nonaffiliates to market to you
No
We do not share
The Hadley App uses your Contact List to help you find other Hadley users who have linked 529 Plan accounts. This allows you to make contributions to the 529 Plans of friends and family.
This privacy policy is being provided by Hadley Investment Co. d/b/a “Hadley.”
What we do
How does Hadley protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We use encryption in the transmittal of your sensitive personal information between your systems and ours, and we use firewalls.
How does Hadley collect my personal information?
We collect your personal information, for example, when you
open an account
sign up for services
solicit 529 account advice
Use your credit or debit card, or bank account, to facilitate transactions
communicate with us through your account
We also collect your personal information from others, such as credit providers, affiliates, or other companies."
Why can’t I limit all sharing?
Federal law gives you the right to limit only
sharing for affiliates’ everyday business purposes – information about your creditworthiness
affiliates from using your information to market to you
sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.
We currently do not have affiliates, but we reserve the right to share information with our affiliates as described on page 1 of this notice.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates we share with may include data processors and others as may be directed by you (e.g., credit providers, 529 plan administrators, family members and philanthropic entities which may provide funds to individual 529 accounts).
Joint marketing
Hadley does not have agreements with nonaffiliated financial companies to market financial products or services to you.
Other important information
NV:
If you are consumer with a Nevada mailing address, and you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by contacting us at [email protected]. You may also contact the Nevada Attorney General's office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: 1-702-486-3132; email [email protected] or [email protected].
VT:
If you are consumer with a Vermont mailing address, we will not share information we collect about you with companies outside of Hadley, unless the law allows. For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.
CA:
If you are a consumer with a California mailing address, we will not share information we collect about you with companies outside of Hadley, unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits to which you are entitled."
