If you are a California resident you have certain rights related to the collection, use and disclosure of your personal information under the California Consumer Privacy Act of 2018 (“CCPA”).  

Collection, Use, and Disclosure of Personal Information

We collect, use and disclose the following personal information as identified under each category of personal information, for business purposes identified and with the third parties identified below:

• Registration Information: When you register for the Envestnet | Yodlee Services, you will be asked for basic registration information, such as a username and password that you choose, name, address, demographic information (such as age and income), and an e-mail address for Envestnet | Yodlee Customer Service. Additional information may be required to utilize value-added features of the Envestnet | Yodlee Services, such as Auto-Registration and Password Reset, or to access specific third party Internet services using the Envestnet | Yodlee Services. This information may include your passwords and user names for the third party web sites and Internet services. We will use this information for providing the services you requested and accessing the web sites you select on your behalf, so that we can present the requested information to you, but such information is not required to register for the Envestnet | Yodlee Services.
• Information on Your Use of the Envestnet | Yodlee Services: As with most online businesses, Envestnet | Yodlee logs information about your access and use of the Envestnet | Yodlee Services web sites, including (i) your transactions conducted on the Envestnet | Yodlee Services web sites, including the use of Internet cookies (discussed below), (ii) the IP addresses from which you came to the site, and (iii) your communications with the Envestnet | Yodlee Services and web sites.
• Information from Third Party Web Sites: In order to display information to you through the Envestnet | Yodlee Services, the Services must collect, on your behalf, your account and other personal information from third party web sites and Internet services that you register on the Envestnet | Yodlee Services. For example, if you register your credit card account through the Envestnet | Yodlee Services, the Service will collect the transactional and payment information regarding your credit card account to display it to you on that Envestnet | Yodlee Service’s web site.
• Information from Envestnet | Yodlee Services’ Partners: Envestnet | Yodlee may arrange for one or more services on the Envestnet | Yodlee Services web sites to be provided to you in whole or in part by a third party partner. For example, Envestnet | Yodlee may arrange for a third party partner to provide electronic funds transfer services to you on the Envestnet | Yodlee Services web sites. The services of these third party partners are governed by their privacy policies, not the Envestnet | Yodlee Services Privacy Notice. This third party partner may share information with Envestnet | Yodlee on your transactions with them, for display on the Envestnet | Yodlee Services web sites and for purposes permissible under this Privacy Notice.
• Information from Security, Fraud and Risk Service providers: Envestnet | Yodlee may arrange for one or more service providers to provide background information on you if you are performing financial transactions on the Envestnet | Yodlee Services web sites. Such providers may include federal authorities and watch list providers (e.g., OFAC) and may also include third party audit services that will protect Envestnet | Yodlee and you from account takeovers, phishing, and other schemes designed to fraudulently use your account.

We limit the use of your personal information we collect to the purposes for which the information was collected, or for other compatible or related purposes.

Your personal information will not be sold, shared, rented or traded with any affiliated or unaffiliated third parties, except (i) to provide you with the Envestnet | Yodlee Services, (ii) pursuant to joint marketing arrangements described below, or (iii) as required or permitted by law. For example, in order to provide you with the Envestnet | Yodlee Services, Envestnet | Yodlee may disclose your username and passwords to third party web sites, such as web sites operated by a credit card company or a bank, in order to obtain the information that you requested be aggregated and displayed through the Envestnet | Yodlee Services. When you register for the Envestnet | Yodlee Services, you are deemed to authorize disclosures by Envestnet | Yodlee to provide the Envestnet | Yodlee Services. Envestnet | Yodlee may disclose registration information and information on your use of the Envestnet | Yodlee Services (excluding information regarding transactions on your aggregated accounts) to companies that perform marketing services on our behalf, or to other financial institutions with whom Envestnet | Yodlee offers you products and services pursuant to joint marketing agreements. For example, Envestnet | Yodlee may share your personal information with a nonaffiliated third party to offer you a new service on the Envestnet | Yodlee Services web sites that is provided jointly by Envestnet | Yodlee and an unaffiliated company. Envestnet | Yodlee reserves the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on Yodlee. If Envestnet | Yodlee is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. For marketing information, the user may change the opt-out choice at any time by selecting Edit Personal Profile. 

Sources of Personal Information

We have collected the above categories and types of personal information from  

• Information provided by the consumer as part of user registration on the Envestnet | Yodlee Financial Data Platform,
• Information provided by the consumer (directly or indirectly) to link his or her accounts and the data we retrieve on their behalf, with the consumer’s explicit permission, about the consumer’s financial accounts.

Sale of PI

We have not sold the personal information of CA residents in the preceding twelve months. We do not sell the personal information of minors under the age of 16 years of age. 

Your Rights as a California Resident

If you are a California resident you have the rights described below, with respect to the personal information we have collected, sold or disclosed about you as a consumer.  To exercise your rights please see the section below: 

Right to Know and Right to Request Information

You have the right to request that we disclose what personal information we collect, use, disclose or sell.  You have the right to request information about the personal information we’ve collected about you within the last twelve months.  You may request to know if we have collected, sold or shared with third parties for a business purpose the following information:

• The categories of personal information we have collected about you
• The categories of sources of personal information we collected about you
• Our business or commercial purpose for collecting or selling personal information about you
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we have collected about 
• Whether we have sold your personal information and if so the categories of personal information that each category of recipient purchased; and
• Whether we have disclosed your personal information for a business purpose and if so, the categories of personal information that each category of recipient received

You may request this information no more than two times per year.

Right to Request Deletion 

You have the right to request that we delete your personal information Under certain circumstances we may be unable to delete your personal information, for example, to comply with legal obligations, or to complete a business transaction that you have requested.  

Right to Non-Discrimination

You have a right not to receive discriminatory treatment for exercising your privacy rights as identified in this section of the privacy notice as conferred by the CCPA.

To exercise the rights above you may make the request in the following ways:

• By filing a Data Subject Access Request at Yodlee Privacy Access Request portal.
• You can also mail your questions to

Envestnet | Yodlee
Attn: Legal
999 Baker Way, Suite 100
San Mateo, CA 94404

• Call us at 650 980 3600, between 8 am – 6 pm pacific time

When you submit a request, we may request you verify your identity through a government ID that shows name, date of birth, and current address as proof of identity. This can include passport or photo identification such as a driver's license, national identification number card. Identify information will be used for verification only, and Envestnet | Yodlee will not store your identity information. You may designate an authorized agent to make a request to know or a request to delete your personal information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly.  We will deny any requests from agents that do not submit proof of authorization.

January 1, 2020