1. Overview
Habits, Inc. (“Habits,” “we,” “us,” or “our”) operates a technology platform that helps consumers discover, evaluate, and connect with independent financial advisors through our website, mobile applications, and related services (collectively, the “Platform”).
Habits is not an investment adviser, broker-dealer, or fiduciary. We do not provide financial, investment, tax, or legal advice, do not manage assets, and do not recommend or endorse any financial advisor. This Privacy Policy explains how Habits collects, uses, shares, and protects personal information in connection with the Platform.
2. Information We Collect
Habits collects personal information in several ways, including information you provide directly, information collected automatically through your use of the Platform, and information collected for identity verification and fraud prevention.
Information You Provide
When you interact with the Platform, you may voluntarily provide personal information such as:
Identity verification may involve the use of trusted third-party providers (such as Plaid or similar services) and may include verification of identifying information you provide during registration.
KYC information is used only for:
- Name, email address, and mobile phone number
- City, state, or ZIP code
- Financial topics of interest (for example, investment management, financial planning, tax planning, or retirement planning)
If you use the Platform’s website to complete a Quick Match intake, you may also provide:
- Estimated household income ranges
- Estimated household asset ranges
- Preferences related to the type of financial advisor you wish to explore
This information is used to facilitate onboarding, follow-up communications, and access to Platform features.
If you create an account through our web or mobile application, you may be asked to provide additional identifying or profile information. Certain Platform functionality may require account registration.
3. Identity Verification and Fraud Prevention
To help protect users, advisors, and the integrity of the Platform, Habits performs identity verification (“Know Your Customer” or “KYC”) for registered users.
Identity verification may involve the use of trusted third-party providers (such as Plaid or similar services) and may include verification of identifying information you provide during registration.
KYC information is used only for:
- Identity verification
- Fraud prevention
- Platform security and compliance
Habits does not use KYC information to provide financial advice, make suitability determinations, or evaluate eligibility for advisory services.
4. Financial Account Aggregation (Optional)
The Platform may allow users to link external financial accounts through secure third-party integrations. Participation in account aggregation is optional and initiated by the user.
If you choose to link financial accounts:
- Account data is used to help you view and organize your financial information
- Data may support filtering and evaluation tools within the Platform
- Linked account information is not shared with advisors unless you explicitly choose to do so
5. Automatically Collected Information
When you access or use the Platform, Habits automatically collects certain technical and usage information, including:
- IP address
- Device type, browser type, and operating system
- Approximate location derived from IP address
- Pages viewed and interactions with the Platform
This information is collected using cookies and similar technologies and is used for Platform functionality, analytics, performance monitoring, security, and fraud prevention. It is not used to make automated decisions with legal or similarly significant effects.
6. How We Use Personal Information
Habits uses personal information for legitimate business purposes, including to:
- Operate and maintain the Platform
- Facilitate discovery, filtering, and connection between users and advisors
- Support onboarding and customer assistance
- Communicate with users regarding their account of Platform features
- Improve Platform functionality and user experience
- Comply with legal, regulatory, and contractual obligations
Habits does not use personal information to provide personalized investment advice, recommend advisors, or make suitability determinations.
7. Communications and Customer Support
If you submit information through the Platform, Habits may contact you via email, phone, or text message to provide onboarding assistance, customer support, or information about Platform functionality. Our customer success team may assist you in completing account registration or understanding available features.
You may opt out of non-essential communications at any time.
8. Information Sharing With Financial Advisors
Habits shares personal information with financial advisors only when you affirmatively choose to initiate contact or request a connection through the Platform.
Information shared with an advisor may include:
- Your name and contact details
- Preferences or context you voluntarily submitted
- Any message or inquiry you send
Habits does not sell personal information, does not provide bulk access to user data, and does not share financial account data with advisors unless explicitly directed by the user.
Financial advisors using the Platform are independent third parties. Once information is shared, advisors are responsible for their own data handling practices and compliance obligations, and their privacy policies govern their use of your information.
9. Platform Neutrality and Advisor Compensation
Some financial advisors or advisory firms may compensate Habits for platform access, visibility, or enterprise technology services.
Such compensation:
- Is not contingent on whether you become a client
- Is not tied to investment outcomes
- Does not affect your ability to evaluate or select advisors
Habits does not recommend, endorse, or rank advisors based on quality or suitability.
10. Third-Party Service Providers
Habits uses third-party service providers to support Platform operations, including cloud hosting, identity verification, financial account aggregation, analytics, customer communications, and CRM services.
These providers may process personal information only as necessary to perform services on our behalf and are subject to contractual confidentiality and data protection obligations.
11. Data Retention
Habits retains personal information only for as long as reasonably necessary to provide the Platform, maintain security and fraud prevention controls, and comply with legal, regulatory, and recordkeeping obligations. Information is deleted or anonymized when no longer required.
12. Data Security
Habits implements commercially reasonable administrative, technical, and organizational safeguards designed to protect personal information. No system is completely secure, and users are responsible for maintaining the confidentiality of their login credentials.
13. Privacy Rights
Depending on your jurisdiction, you may have rights to access, correct, or delete personal information, or to opt out of certain communications. Habits does not discriminate against individuals for exercising privacy rights.
Requests may be submitted to
support@usehabits.com.
14. California Privacy Notice
Habits does not sell personal information as defined by the California Consumer Privacy Act and California Privacy Rights Act. California residents may exercise applicable rights by contacting us using the information below.
15. Children's Privacy
The Platform is not intended for individuals under 18 years of age. Habits does not knowingly collect personal information from children.
16. Changes to This Policy
Habits may update this Privacy Policy from time to time. Material changes will be posted on the Platform with an updated effective date.
Appendix A: SEC and Marketing Rule Alignment
Habits operates as a technology marketplace and does not act as an investment adviser, broker-dealer, solicitor for securities transactions, or fiduciary. Habits does not provide investment advice, supervise advisory relationships, or manage client assets.
Financial advisors using the Platform are solely responsible for compliance with the Investment Advisers Act of 1940, including SEC Rule 206(4)-1 (the “Marketing Rule”), and for determining and providing any required disclosures related to testimonials, endorsements, referrals, or compensation. Habits does not verify advisor compliance and makes no representations regarding advisor qualifications, licensing, or services.
Users are solely responsible for conducting their own evaluation and due diligence before engaging a financial advisor.
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