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Privacy Policy

Last updated: June 21, 2024

WE TAKE YOUR PRIVACY AND THE SECURITY OF INFORMATION ABOUT YOU SERIOUSLY. THIS PRIVACY POLICY DESCRIBES HOW WE COLLECT, USE, DISCLOSE, RETAIN, SAFEGUARD, AND PROTECT INFORMATION ASSOCIATED WITH AN IDENTIFIED OR IDENTIFIABLE INDIVIDUAL (REFERRED TO IN THIS PRIVACY POLICY AS “PERSONAL DATA”) AND WHAT CHOICES YOU HAVE AROUND THIS ACTIVITY.

Please read this Privacy Policy (as defined below) carefully.

By clicking a box indicating your acceptance, by using or by registering for the Services, you acknowledge that you have read, understand and agree to be legally bound by the terms of this Privacy Policy and are consenting to RK Sterling, LLC’s practices related to your information and this Privacy Policy. Your continued use of this Site or Services after RK Sterling, LLC makes a change is deemed to be acceptance of those changes. You represent and warrant that (i) you are 18 years of age or older, (ii) you are a resident of the United States and (iii) you have read and understood the terms of this Privacy Policy. If you do not agree with this Privacy Policy and practices, do not use, visit, register or otherwise access the Site, the Services and content contained on the Site or Services.

Please also read carefully RK Sterling, LLC’s Terms of Service at https://www.rksterling.com/legal/terms-of-service or any successor URL (the “Terms of Service”)A Notice**.

Applicability of This Privacy Policy

This Privacy Policy applies to RK Sterling, LLC’s financial-planning software (the “Services”) and other interactions (e.g., customer-service inquiries, user webinars, user conferences, etc.) you may have with RK Sterling, LLC. If you do not agree with this Privacy Policy, then do not access our Services. For the avoidance of doubt, this is the only privacy policy that applies to RK Sterling, LLC.

Customer means the organization (e.g., your financial advisors, your broker-dealer, your firm, or another entity or person) that entered into the Agreement with RK Sterling, LLC, and the Customer controls the instance of the Services and any associated Personal Data.

Information We Collect

Information You Provide to Us

When you register for and use the Services, we collect information that you provide directly to us, including:

  • Account Information – name, email address, phone number, professional credentials, and login credentials
  • Business Information – firm name, address, website, regulatory registrations, and other business details
  • Client Information – information about your clients that you input into the Services for analysis or advice generation purposes
  • Payment Information – credit-card details, billing address, and other payment information
  • Communications – information you provide when you contact us for support or communicate with us

Information We Collect Automatically

When you access or use the Services, we may automatically collect information about you, including:

  • Usage Information – how you use the Services, the features you access, frequency of access, and other usage patterns
  • Log Data – IP address, browser type, operating system, referring URLs, and pages viewed
  • Device Information – hardware model, operating system, and unique device identifiers
  • Cookies & Similar Technologies – cookies and similar tracking technologies that capture interactions with the Services

How We Use Your Information

We use, share, or combine your personal information—together with data we receive from third-party sources—as follows:

  • Account creation and authentication
    Enable you to register for an RK Sterling Account and securely authenticate your computer or mobile device.

  • Platform operation and improvement

    • Provide, improve, develop, troubleshoot, or maintain the Platform, Site, and any new features or versions.
    • Perform accounting, auditing, legal, billing, and other internal functions.
    • Engage third-party service providers (e-mail, payments, hosting, CRM, analytics, support, etc.) and, where permitted, our affiliates and subsidiaries.

  • Third-party integrations you request
    Sync, link, or connect products and services you choose to use with the Platform; such third parties will handle your data under their own terms and privacy policies.

  • Financial-institution connectivity
    Access the credentials you supply (e.g., user name, password, security questions) to retrieve, sync, update, and maintain balances, holdings, and transactions from the banks or brokerage accounts you designate.

  • Information and marketing requests
    Fulfil inquiries, send requested materials, and deliver promotions when you opt in.

  • Relationship management and communications
    Manage our business relationship with you—including administrative, billing, maintenance, renewal, support, and collection notices—via email, text message, push notification, mail, or other channels.

  • Product and service offerings
    Offer or inform you about additional RK Sterling products, services, or feature changes, and notify you of updates to the Platform, Site, Terms of Service, or this Privacy Policy.

  • Research, analytics, and reporting
    Conduct market research, user-behaviour analysis, data analytics, trend compilation, and customized reporting (including push notifications and texts) to enhance the Platform.

  • Fraud, security, and risk management
    Detect, prevent, and protect RK Sterling, you, and other users against errors, fraud, security breaches, technical issues, or criminal activity; assess, mitigate, and manage related risks.

  • Legal claims and compliance
    Respond to allegations that posted content infringes third-party rights; enforce our Terms of Service and this Privacy Policy; and satisfy applicable laws, regulations, legal processes, or enforceable governmental requests when we believe in good faith that disclosure is required.

  • Corporate transactions
    Share or transfer information to a buyer, successor, affiliate, or service provider as part of—or during negotiations for—any merger, acquisition, financing, divestiture, bankruptcy, or other reorganization of RK Sterling, LLC.

  • Other purposes disclosed or permitted
    Any additional purposes disclosed at the time of collection or otherwise allowed by this Privacy Policy or applicable law.

How We Process Client Information

PII Detection, Redaction, and Large-Language-Model (“LLM”) Processing

RK Sterling, LLC recognizes the extraordinary sensitivity of client data and employs commercially reasonable, state-of-the-art technical and organizational measures—including automated pattern-matching, token masking, and heuristic filters—designed to identify and redact personally identifiable information (“PII”) prior to routing any content to third-party large-language-model (LLM) providers that contribute to our Services.

Despite these safeguards, no automated or manual process can guarantee perfect removal of PII in every circumstance. Accordingly:

  1. Customer Pre-screening Obligation. You agree to review and, where necessary, manually remove or obfuscate PII (including but not limited to names, Social Security numbers, account numbers, dates of birth, postal addresses, e-mail addresses, telephone numbers, and any data classified as “non-public personal information” under GLBA, “personal data” under GDPR, or “personal information” under the CCPA) from all prompts, documents, and data sets submitted to the Platform.
  2. Residual-Risk Acknowledgement. You acknowledge that residual PII may nonetheless be transmitted to LLM providers, that such providers operate under their own security controls and privacy terms, and that RK Sterling, LLC does not exercise direct control over their internal processing environments.
  3. Regulatory Compliance. You represent and warrant that your use of the Services—including any transfer of client information to RK Sterling, LLC or its subprocessors—complies with all applicable federal, state, and foreign privacy, data-security, and consumer-protection laws (e.g., GLBA, SEC Regulation SP, HIPAA, GDPR, CCPA/CPRA, and any successor statutes or regulations).
  4. No Warranty; Limitation of Liability. RK Sterling, LLC provides its PII-redaction functionality “as is” and “as available,” without warranty of any kind, express or implied; RK Sterling, LLC expressly disclaims any warranty that the functionality will detect or remove all PII or that third-party LLM providers will not re-identify, store, or otherwise process PII. To the maximum extent permitted by law, RK Sterling, LLC shall not be liable for (a) any failure to remove PII, (b) any act or omission of an LLM provider, or (c) any resulting damages, losses, fines, penalties, or regulatory actions.
  5. Indemnification. You agree to defend, indemnify, and hold harmless RK Sterling, LLC, its officers, directors, employees, and agents from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys’ fees) arising out of or relating to (i) your failure to remove or anonymize PII, (ii) your violation of applicable data-protection laws, or (iii) your use of the Services in a manner inconsistent with this Privacy Policy or the Terms of Service.

By continuing to use the Platform, you expressly accept and agree to the foregoing terms and acknowledge that you retain primary responsibility for safeguarding client privacy.

Data Storage and Security

All client information is stored on encrypted servers that employ industry-standard security measures. We implement appropriate technical and organizational measures designed to protect your information against unauthorized access, accidental loss, or destruction.

Information Sharing and Disclosure

We do not sell personal information (yours or your clients’). We may share information:

  • With Service Providers – vendors, consultants, and other providers who need access to carry out work on our behalf
  • For Legal Reasons – when disclosure is required by law or necessary to protect rights, safety, or property
  • Business Transfers – in connection with a merger, acquisition, financing, or sale of all or a portion of our business
  • With Your Consent – when you explicitly agree to such sharing

Data Retention

We retain information as long as necessary to provide the Services and fulfill the purposes outlined in this Privacy Policy, taking into account the amount, nature, and sensitivity of the data and applicable legal requirements.

Your Rights and Choices

Depending on your jurisdiction, you may have rights to:

  • Access personal information
  • Correct inaccuracies
  • Request deletion
  • Restrict or object to certain processing
  • Data portability
  • Withdraw consent

Contact us (see “Contact Us” below) to exercise these rights.

Security

We implement reasonable security measures, but no system is impenetrable, and we cannot guarantee absolute security.

International Data Transfers

We are based in the United States. By using the Services you consent to the transfer, processing, and storage of your information in the U.S.

Children’s Privacy

The Site and Services are not directed to, intended or designed for children under 18 years of age (“Children”), and no Children should provide any personal information through the Site, the Services or any application. RK Sterling, LLC does not knowingly collect information from Children and does not allow them to register. If RK Sterling, LLC discovers that it has inadvertently gathered any such information from any Children, RK Sterling LLC will take steps to promptly delete any such information and close the account, if any.

Changes to This Privacy Policy

We may update this policy periodically. Material changes will be announced via email (if provided) or within the Services. Continued use after changes take effect constitutes acceptance.

Contact Us

If you have questions or requests about this Privacy Policy or our privacy practices, contact us at:

RK Sterling, LLC
Email: cdevlin@rksterling.com
Phone: 434-401-7468