The information we collect depends on the service level or stage of engagement.

For Website Visitors and Webinar Attendees:

We collect basic IP and cookie information for tracking and internal marketing analysis. We do not use this information to send unsolicited communications. If a visitor fills out a form, we will store the data the form asks (usually name and contact information as well as questions about their current needs). This is for internal use and appropriate follow-up. You may be asked if it okay to for us to communicate to you by text. If you opt-in, this will be texts sent directly to you in basic human-to-human communications, not part of a mass marketing campaign.

For those simply interested in the service and making inquiries, we’ll collect your name and the contact information you wish to share. We may collect or retain other information, such as service interests, needs, and the problem areas you share with us for our internal notes and reference.

We sometimes offer partner blog, videos, podcasts or other media resources on the website, in particular blogs or content our staff have authored or participated in (such as a video webinar panel where a staff member was a panelist). If the content is hosted on another platform, such as through a i-frame or YouTube or other plug-in, your browsing data, IP address, and other information, such as cookies, may be collected by that third party. We make reasonable effort to denote when such content is hosted by parties outside of our direct control.

To render services, we will need:

We will need basic name, demographic, and contact information including email, mail, phone, and other appropriate ways to contact you.

For the most basic of daily money management services, which is bill paying facilitation and account reconciliation, we would need online access to information about your accounts, at the very least data feeds and statements.

This access can take the form from the basics of you providing us a copy of your statements each month, through giving us electronic access to download data. The specifics will depend upon our service agreement and your level of comfort.

For more in-depth services, such as acting as a liaison with medical providers and government agencies, we may require more sensitive information such as your social security number, date of birth, etc., as well as signed “Release of Information” or “HIPAA Releases” that give permission for other companies or agencies to release information to us.

For full-service DMM work, which includes household electronic file management, concierge services, and other services where we would provide extensive financial case management, such as contacting insurers or financial institutions, we will require an extensive amount of information, such as insurance cards, driver’s license or official IDs, credit card information, and the like. This gives us the information we need to do tasks for you plus serves as a backup in case these cards get misplaced or stolen so that you can get new cards issued more easily.

If you ask us to prepare “Life Binder” services in conjunction with my daily money management duties, we will need access and copies of all of your sensitive data including those mentioned above and others such as Military discharge/service records, lists, and locations of assets, and the like.

In general, we do not ask you to share sensitive information unless it is necessary to perform tasks for you; however, for our full-service clients, this may be considerable. If we are given such data, we offer appropriate security regarding its protection. (See How this Information is Stored below)

None of this information is shared, sold, rented, or distributed to third parties unless agreed to by you or used to conduct tasks related to our Service Agreement. (See Data Access and Sharing.)

Our company does not use Text, SMS, or MMS for any type of marketing campaign. If you get a text from us, it’s probably because you sent a text to a staff member and they are responding. We generally do not initiate a text message unless we are told explicitly that text is acceptable, if not preferred. 

Inbound SMS Number: This is the mobile number of your Account Manager and is printed on their business card and listed in your onboarding packet. 

If permitted to use text, we use it to communicate:

a) Automated or manual messages verifying or confirming meeting times.

b) For two-factor authentication for clients or trusted contacts to access secure client areas (such as the portal).

c) General communications with clients, trusted contacts, or other external stakeholders who have either messaged us or have communicated that text is a valid and sometimes preferred method of communication.

We remind clients that data and messaging rates may apply and that they can inform us at any time if they wish to discontinue the use of text/SMS to communicate.

Physical Documents:
Unless absolutely necessary, and even then for only a brief period of time (for example, to make copies and return originals to you), we will not take or store original copies of statements, forms, or other documents. For these physical documents, we can help you develop a home filing system and if necessary help you maintain it as necessary or make other recommendations (for example, a will should be in a Trust’s safe deposit box). We do not provide physical document storage services to clients.

Any physical copies we make that are later converted to electronic copies are shredded, unless the client requests their return or if the documents are notarized, court or documents with seals, government originals (birth or death certificates, marriage certificates, etc.) or have medallion signatures. These types of official documents are returned intact to the client or stakeholder.

Electronic Data: 
The general process is for us to work from electronic copies of information. This permits us to restrict access to this information to only authorized parties within our company.

All of this is kept stored and accessible through a client portal or equivalent safe alternative, to which you (and others you give permission) will have unique login credentials. This portal, powered by ZPortals, is secure and safe for protecting sensitive financial and medical information.

You, or others you designate, will have 24/7 access to the portal using a unique login and password combination.  ZPortals supports two-factor authentication.

To learn more about our portal (via ZPortals), and its data security practices ask us to share their privacy practices document.

Electronic information, such as bank data files (if we do not have access to retrieve them on your behalf), can be securely uploaded to the portal for us to access and use or we can provide a secure link. This is preferred over sending files over email.

Tax Returns:
Tax returns and anything with your social security number will be stored zipped with a password.  This password will be kept as agreed to through LastPass or another mutually agreed upon secure password protector.

Storage and Backups:
The portal will also be the repository of any data files, reports, budgets, and notes that you can access at any time. It may be that you’ll have a physical filing system at home for original copies and electronic copies of it (and the other records we produce) in the portal. Backups are made automatically once per week and are stored on an encrypted physical hard drive.

Emails: As a rule, we will send sensitive information through encrypted email that requires an authentication code. This code is sent in a separate email. 

Access Granted to Us:  To perform many of our services, you will need to grant or provide us information, including that of a sensitive nature. This information is kept confidential. Employee access is restricted to need to know and limited access to information essential to perform the tasks outlined in the Service Agreement. For example, those who do Quickbooks categorization and reconciliations would only have access to the information they need, such as bank feeds or statements, to perform these services. They would not have access to other things, such as insurance, logins or transactional abilities.

We use third-party online software to store, process and compile the information into useful reports, perform tasks, or for electronic filing. These services do not use your information in any capacity other than to provide the services per contract. We also use automation tools, such as Zapier, Zoho Flow, or custom scripting (programming language varies) to help manage and automate tasks. These tools do not store or retain any information.

Access Granted to Others:  Data sharing is never for marketing purposes.  As company policy, we do not Share, Sell, Rent, or otherwise collaborate to share any contact information to unrelated third parties. 

However, in order to perform many of our tasks, we may have to communicate with outside stakeholders and provide some of your information so that they may be able to do work for you. This may include accountants, attorneys, financial planners, and other vendors or professionals you have retained. For example, your CPA would need to have your name, contact information, and key documents and reports in order to prepare you taxes. Information is only shared within the  scope of the Service Agreement and only with outside stakeholders that you have permitted us to share this information. 

This is your life and your data. We are simply providing a service.

You have the right to access your portal or alternative secure viewing method at any time to view all documents.

If you do not want portal access and are hesitant about keeping your data online, we can keep your data offline and on a secondary, encrypted hard drive, however this may limit some service delivery or add billing time. We do not have physical room to keep physical copies of records, so there must be some electronic storage of some type, especially if multiple staff assist with your account activities.

If you elect to terminate services, or we can no longer provide services, we will provide a zip file download of your files and give them to you.

This will include pdf files, reports, Quicken/Quickbooks data files or anything obtained or generated during my service.

That said, online archives are kept for only 5 years. Anything 6 years or older are zipped and given to you or another designated by you.

We will keep your data for one year beyond our service date as a courtesy and to assist with wrapping up any remaining business. You may, in writing, request we delete all data and files after we provide them to you.

We have Business Associate Agreements (BAA) with service providers that may come in contact with Private Health Information (PHI) or sensitive Financial information or documents (especially those with social security numbers or account numbers on them). I use two-factor authentication wherever it is available.

This information is restricted internally to staff by access levels. Your Daily Money Manager Account Manager would have full access to your information as they are the lead in providing services. Staff bookkeepers and other support would have access limited to what was needed to perform their job duties.

As a rule, we do not share such documents via email and encourage clients and their representatives to do the same. We will provide secure links to allow for file uploads.

For offline files, we keep them on an encrypted hard drive. Computers, such as laptops, require biometric and/or 2-Factor identification to log in.

All data and information regarding a client are never disclosed unless agreed to in writing or as otherwise required by law, a court order, or other legally compelling reason.

Even if services are paid for by someone other than the client (however guardianship or similar type of arrangements are excluded), the client has full rights and say-so over who gets access and to what degree.

During the onboarding process for each client, regardless of life circumstances, we address directly what is the course of action if the client is engaging in erratic or negligent spending that can threaten their financial stability and provide necessities. The client has the right to say we can do nothing; other times they may give us the name of a trusted individual to contact if outlined intervention steps have not worked.

Intervention Steps:  To re-iterate, how the client chooses to spend their money is not our business. We do not judge but will provide good advice to help them keep within a budget and achieve their goals. However, continued erratic behavior or overspending that impacts our ability to do our job can result in service termination unless the client agrees to additional support. Example: A client with diminishing capacity due to dementia who then agrees to have someone appointed Power of Attorney.

If the client has agreed to let us contact another if things have gotten too far out of hand, we will have at least done the following:

* Gave repeated (3) notifications that spending is jeopardizing their budget.

* Discussed with them their spending and suggested ideas to assist (such as a capped limit or prepaid card).

Exceptions: The only time we will make exceptions is if there are multiple, documented examples of Financial Abuse. In that case, I will alert the trusted contact before the intervention steps or authorities as appropriate.

As much as possible and to the greatest extent possible, we prefer to NOT share client’s passwords to accounts, but rather establish “Accountants” and/or “Convenience Signer” access through separate logins. However, that is not always feasible or offered by financial institutions.

If we must resort to password/account sharing in order for us to get the data needed to complete our work, we will use a password “locker” to share these passwords (LastPass – the free version is fine). You, or another you’ve delegated, will have full access and ability to change passwords as you wish and these changes will be automatically, and securely updated.

As policy, we update passwords every quarter, if able, unless required to do so more frequently. Again, these updates will be shared automatically so that you’re never “locked out” of your accounts.

That said, we will not have the passwords/login credentials for your (or others if you’ve given permission) portal or other client account access venues.

If you have neither internet access nor have a trusted second person who does, we can make other arrangements, such as you having a written copy (stored in a locked or safe location) while we use the online “locker” and provide you with updates as needed.

We do not share, rent, or sell data to any party for the purpose to be added to a list. Permissions granted to us are not extended to your professionals or vendors without written permission from you.

There are third party services, such as Calendly, Zoho, Google Workspace, Quickbooks and others who may receive your data in order to perform a service, such as scheduling or meeting reminders. They do not have the authority to harvest or repurpose your data for any other use other than to provide support functions for the company or for you.