Privacy policy

Last Updated March 18, 2024

Introduction

Vanilla Technologies Inc. ((“Vanilla,” “we,” “our” or “us”) respects the privacy of its customers and other users of its website located at https://www.justvanilla.com (the “Site”), and any other Vanilla websites, mobile applications, products, services, communications, or other interactions with us (collectively, the “Services”). This Privacy Policy (the “Privacy Policy”) explains how Vanilla collects your information, how Vanilla handles and protects that information, and what you can do to help protect that information. This Privacy Policy does not apply to Vanilla’s collection and use of information relevant to employees, whether prospective, current or separated. 

Vanilla reserves the right, at its discretion, to change, modify, add or remove portions of this Privacy Policy at any time by posting the amended Privacy Policy on the Site. You should review this policy periodically, and especially before you provide any Personal Information. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements.  Your continued use of the Services after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to our privacy practices as described in the modifications. Except as otherwise stated, all amended terms shall automatically be effective thirty (30) calendar days after they are initially posted.

By using the Services, you agree to the collection and use of your information in accordance with this Privacy Policy.

Information We Process on Behalf of Vanilla Licensed Customers

Vanilla customers who purchase licenses to use Vanilla’s SaaS platform — typically investment advisers, RIAs, other financial institutions, and law firms (the “Vanilla Licensed Customers”) — may choose to use the Services to process information about their clients. The information that we process through the Services for the Vanilla Licensed Customers is controlled by the Vanilla Licensed Customers. We process that information at the direction of the Vanilla Licensed Customers and our privacy practices governing the processing of that information will be in accordance with contracts that we may have in place with the Vanilla Licensed Customers.

If you have any questions or concerns about how such information is handled or would like to exercise your rights, you should contact the Vanilla Licensed Customers who have contracted with us to use the Services to process your information. The Vanilla Licensed Customers determine how and for what purpose the information collected on their behalf should be processed. We will, however, provide assistance to address any concerns you may have, in accordance with the terms of our contract with them. 

Information We Process on Behalf of the Clients of Vanilla Licensed Customers or Users of Vanilla Document Builder

Our Vanilla Licensed Customers may choose to invite their clients to use the Services, and such use may include providing data directly to Vanilla. The data that the Vanilla Licensed Customers’ clients provide through the Services is processed in accordance with the Vanilla Terms of Service and this Privacy Policy.

Information We Collect

We collect information about you when you use the Services. The types of information we collect depends on the services and the features you use on the Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services features.

Information You Provide Directly to Us

When you engage in certain activities on the Services, such as inquiring about or utilizing the Services, contacting customer service or providing feedback, or signing up for email updates or other promotional materials, we may ask you to provide certain information about yourself, which may include your name, e-mail address, address, and phone number, as well as other information you may supply us in connection with a financial product or service, such as your demographic information, investment preferences, or location information.

The Services may also prompt Vanilla Licensed Customers to disclose information of their clients in the course of utilizing the Services. Any Vanilla Licensed Customer that provides Vanilla with any personal information of any client or other third party represents and warrants that such user has been authorized by such client or other third party to provide such information to Vanilla, and that such client or third party has consented to Vanilla’s use of such information in accordance with this Privacy Policy.

Vanilla uses a third party payment processor to process payments made through the Site or any other part of the Services. In connection with the processing of such payments, we do not retain any financial information such as credit card numbers. Rather, all such financial information, together with any personal information that you provide in the payment process, is provided directly to our third party processor, Stripe. The third party processor’s use of your financial information and any other personal information that you provide in the order process is governed by the processor’s privacy policy, which may be viewed at https://stripe.com/privacy.

Vanilla maintains integrations with third party data providers, such as Orion and Addepar. By using the Service and enabling these integrations, you grant Vanilla and such third parties the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

We may also collect information from you when you sign up for webinars or interact with us at conferences.

Information We Collect Automatically

Log Data.  When you use the Services, we may collect information such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your use of the Services, the specific pages, buttons, images, links, and forms that you access while visiting the Services, the type of device you use to access the Services, and your mobile carrier and/or Internet Service Provider. 

Cookies and Similar Technologies.  When you access the Services, we, or third parties we hire to track how the Services is used, may place small data files called “cookies” on your browser or other access device. Cookies are pieces of data stored on your device and are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server.

A “session cookie” may be sent to your computer or other access device when you sign into the Services. This type of cookie recognizes you if you visit multiple pages on a site during the same session, so that you do not need to be prompted for your password on each page. Once you sign out or close your browser, this cookie expires and no longer has any effect. “Persistent” or longer-lasting cookies can be used for other purposes, such as to record user experience preferences when you use a website and to inform you about Vanilla’s products and services during and after you visit the Services, a process known as remarketing. These cookies do not expire once you sign out or close your browser. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of the Services.

We and our third party service providers may also use technologies similar to cookies to track your interaction with the Services. Some of these technologies include web beacons, pixels, and tags. As with cookies, you are free to decline such technologies if your browser permits. You should refer to your browser’s instructions to remove cached history and images from your device. 

We may also embed web beacons, tags, and pixels in the emails we send to you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email.

Device/Usage Information. We and our third-party service providers, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) Internet Service Provider or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to know when users have accessed the Site from a paid advertiser, an affiliate website, or a strategic partner website, to assist in determining relevant advertising (both on and off the Services), to evaluate the success of our advertising campaigns, and as otherwise described in this Policy.

Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address).

Information We Collect from Third Parties

We may gather information, including contact information, demographic, and statistical information, from third parties, such as business partners, marketers, researchers, and analysts. We may also receive information about you if you are referred by another user.  We use this information to improve our records, support administrative operations or market Vanilla and the Services.

Our Use of Your Information

We may use your information to: 

• Provide information, products or services to you, including the Services; 
• Verify your identity when accessing the Services; 
• Respond to your comments, questions, and requests, and provide customer service;
• Facilitate intake procedures with an Outside Attorney (as defined in our Terms of Service) to enable your engagement of that Outside Attorney;
• Enforce our Terms of Use and any other agreements between you and Vanilla; 
• Improve, modify, customize, and measure the Services; 
• Communicate with you about Vanilla’s products, services, surveys, events, content, and other news and information we think may be of interest to you; 
• Personalize and improve the Services and provide content, and features that match your profile and interests, and remember information about your preferences for the Services;
• Compare information for accuracy and verify our records; 
• Detect and prevent fraud or other criminal activities; and
• Carry out any other purpose for which the information was collected.

We may combine information about you that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have.

We may also aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such anonymized, aggregated data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

Sharing of Your Information

Except to the extent that Vanilla believes, determines, or is told by your Outside Attorney or you, that your information is subject to the Attorney Client, Attorney Work Product, or other legal privilege, we may share or disclose your information for the following reasons:

• We may share your information with employees, vendors, consultants, and other service providers who need access to such information to carry out work or perform services on our behalf, such as those who provide data storage, payment, technology support and services, customer service, risk solution provision, analytics, fraud prevention, legal services, and marketing services. 
• Although Vanilla makes every effort to preserve user privacy, Vanilla may need to disclose or provide access to information if Vanilla has a good faith belief that such action is necessary to (i) comply with the law; (ii) comply with legal processes or governmental requests; (iii) prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our website or our network; and/or (iv) to protect the rights, property, safety and security of our employees, our website visitors, and/or the public.
• We may share your information if we believe your actions are inconsistent with our Terms of Use or other policies or agreements with you.
• We may share your information in connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing; between any future parent, subsidiary, and/or affiliated company.
• We may share your information with advertising and analytics partners to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use Cookies in the same way we do, to among other things, track and analyze data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your online activity. For more information about how to manage having your web browsing information used for advertising purposed, please see the Your Choices section below.
• We may share your information with your Advisor and/or an Outside Attorney (if you have elected to use one), so that your Advisor and your Outside Attorney has access to current and up-to-date data in the Vanilla platform. You will enter into a separate engagement letter with your Outside Attorney governing the use of that information.
• We may also share some of your information as otherwise permitted or required by law or as authorized by you. 

Online Analytics and Tailored Advertising

Analytics

We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

Tailored Advertising

We may allow certain third parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites, accessible by the above links.

Do Not Track

Vanilla and the third parties who assist in operating the Services do not respond differently or limit their practices under the terms of this policy when you access those online services with a browser that uses a do not track signal.

Your Choices

• Account Information: You may update, correct, or modify information about you at any time by logging into your account or emailing us at help@justvanilla.com. If you wish to deactivate your account, please email us at help@justvanilla.com, but note that we may continue to retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law.
• Cookies: Most web browsers are set to accept Cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services. 
• Online Advertising Networks: You may opt out of receiving targeted ads based on the information we collect from you. If you do not want to receive such ads, you may opt-out by visiting either of the following sites:
  • NAI – http://www.networkadvertising.org/choices/ 
  • DAA – http://www.aboutads.info/choices/
• Promotional Communications: You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at help@justvanilla.com. If you choose to opt out, we will still send you non-promotional communications, such as those about your account or our ongoing business relations.

Access, Correction, and Deletion:  Certain information may also be exempt from such requests in some circumstances, which may include needing to continue processing your information to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.

If you opt out by exercising any of these choices, you may still temporarily see or receive communications or advertising due to initiatives already underway. You will be removed from any subsequent initiatives.

Storage and Protection of Personal Information

We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. In order to help secure personal information collected from you, including sensitive financial data, the information is protected by SSL encryption when it is exchanged between your web browser and the Services; however, the Internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by Vanilla in connection with the Services or any other service offered by Vanilla. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.

Suspicious Email

It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from Vanilla but you suspect may be from another source and might be fraudulent, please email us at help@justvanilla.com.

Social Media

You may also find additional information on our products and services through our social media sites such as Facebook, LinkedIn, YouTube, Instagram, or Twitter. Please keep in mind that any information you share on these sites may be visible to all site participants and is subject to those sites’ Terms of Use and Privacy Policy. Please review the Terms of Use and Privacy Policy on these social media sites as they are different than our own policies.

Personal Information of Children

The Services are not directed to children under the age of 16 and we do not knowingly solicit or collect personal information from children under the age of 16. If you are a parent or guardian and you learn that your child has provided us with personal information, please contact us. If we discover that a child under the age of 16 has provided us with personal information, we will delete such information from our servers.

Notice to Persons Located Outside the United States

The Services are not intended for use by individuals who are located outside the United States. If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.  Your information may be transferred for processing and storage by Vanilla and our affiliates and third parties If you do not want your information to leave your jurisdiction, do not provide the information to us. By providing information to us, you explicitly consent to the transfer of your information to the United States.

Contacting Us About Privacy Questions

If you have questions or concerns regarding this Privacy Policy, please contact us by email at help@justvanilla.com.