Privacy Policy

Policy Effective Date: August 23, 2018

Your trust is our priority, and we are working hard to protect your privacy. We will keep your information secure and confidential and will only use it for the purpose of creating an account. We created this Privacy Policy to be as clear and direct as possible about how we gather and use your personal information.

This Privacy Policy sets forth how personal information is collected and used, that is provided on the website located at www.u-nest.com and our mobile application “U-Nest.” Unless indicated otherwise, this Privacy Policy only applies to personal information collected through U-Nest’s Technology by U-Nest or any of our respective affiliates. By using our Technology, you automatically agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future in order to be transparent about our information use.

Personal Information Collected

We collect the following personal information from you:

  • Contact information such as name, email address, mailing address, phone number
  • Billing information such as credit card number, and billing address
  • Financial information such as bank or brokerage account numbers, types of investments
  • Social Security number
  • User name, account number, password
  • Demographic information such as age, gender, and zip code
  • When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier

While we do collect information on the beneficiary of your accounts created, we want you to feel completely comfortable with sharing this information considering it may pertain to your young children. We want to reassure you that this shared information is only used for account creation, maintenance, and growth statistics. It will never be shared with third parties.

Security

The security of your personal information is very important to U-Nest. When you enter information, such as a bank account number or financial information, on our forms, we encrypt it and only use it for set up and maintenance, both automatic and requested, for your account. U-Nest uses a bank-level security to keep your sensitive financial data safe. We use the strongest browser encryption (265 bit) and secure servers monitored 24/7.

U-Nest takes reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free therefore, we cannot guarantee the security of any information you transmit to us.

Information Regarding Children

Due to the nature of our business, Services and benefits are not marketed to minors. Except for beneficiary information as described above, U-Nest does not knowingly solicit Personal Information from children under the age of 18.

If you are under the age of 18, please do not submit any Personal Information to U-Nest. If we learn that we have collected Personal Information directly from a minor, we will remove such information from our files.

If a parent or guardian becomes aware that their child under the age of 18 has provided us with Personal Information without his or her consent, they should contact us at
info@u-nest.com and we will delete such information from our files.

Other Ways We Collect Information

Other means by which we collect Personal Information include the following:

  1. Anonymized or aggregated Information. U-Nest’s Site and App automatically record certain information about your use or evaluation of our Service. Anonymized or aggregated information is used for many things, including the measurement of Users’ interest in and use of various features of the Site. This information is not personal information, and we may use such information to internally analyze and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  2. Cookies and Pixels. Similar to other technology platforms and services, U-Nest uses cookies, which enable our Web servers to “identify” Users, each time an individual initiates a session on our website. A cookie is set in order to identify you and tailor the Site for your personal experience. Cookies do not store any of the personal information that you provided to us; they are simply there for means of identification. You may delete cookie files from your own hard drive at any time. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.
  3. Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
  4. Site and App Activity. U-Nest may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site and App.
  5. “Do Not Track” Technology. We do not collect personal information about your online activities over time and across different web sites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect personal information about your online activities over time and across different web sites or online services.

User Personal Information

We use your personal information to help you evaluate our service, offer you new products or services, and enhance our service. We may also use your personal information a number of ways, including research, internal analysis, and analytics.

Client Personal Information

U-Nest stores, processes, and maintains personal information related to you in order to provide client support, offer new products or services and provide our service to clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a client.

Additionally, we may share the information required to become a client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide services to you.

Mobile Computing

U-Nest provides websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of our Site may require that you log in with an account. In such cases, information about use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools can and may transmit personal information to U-Nest to enable you to access your account information and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Privacy Policy or in other notices we provide.

Information Sharing and Onward Transfer

We will not sell, rent, or trade your personal information (whether you are a current or former client) to any non-affiliated third parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, or situations involving potential threats to the physical safety of any person.

There are certain circumstances, in which we may share your personal information with non-affiliated third parties without further disclosure to you. For example, from time-to-time, we hire third-parties to perform certain business and technology related functions (e.g., mailing information, database maintenance and payment processing). In the event we hire a third party to perform a function of this kind, we aim to only provide them with the minimum information they need to perform their specific function and to require these third parties in order to safeguard your personal information.

Your Choices and Opting Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

You may decline to provide personal information to U-Nest. Declining to provide personal information may disqualify you for U-Nest services and Site features that require certain personal information.

Opting-Out – Obtaining and Withdrawing Consent

Where you have consented to U-Nest’s use of your personal information, you may withdraw that consent at any time and opt out by contacting us by email or phone via the contacts indicated in Section X below. Additionally, before we use personal information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

Prior to disclosing sensitive personal information to a third-party or processing sensitive Personal Information for a purpose other than its original purpose or the purpose authorized subsequently by you, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of personal information is otherwise required by law or contract, we will have to comply with the aforementioned law or contract.

We will only use Employee personal information only for employment-related purposes. If we intend to use this Employee personal information for any other purpose, we will provide the Employee with an opportunity to opt-out of these uses.

Retention and Deletion

U-Nest retains the personal information we receive as described in this Privacy Policy for as long as you use our Sites or App or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

You may request deletion of Personal Information by contacting us at
info@u-nest.com and providing us enough information to identify your account and prove that you are the owner of the identified account. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any personal trading data unless required by regulators or other government bodies.

California Privacy Rights

California law permits Users and Clients who are California residents to request and obtain from us once a year, free of charge, a list of the third- parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. U-Nest does not share Personal Information with third-parties for their own marketing purposes

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our practices. If we make changes we will notify you by email or by means of a notice on our website or mobile app prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.

Contact Information

Do not hesitate to contact U-Nest with any questions or concerns you may have with our Privacy Policy. We want you to feel completely safe using our services, so we encourage communication on both ends.
support@u-nest.com

Disclosure

College Savings Calculator is a hypothetical tool that demonstrates how monthly contributions, age-based asset rebalancing, and tax savings may impact the long-term value of your account, and do not take into account a portfolio’s underlying investment management fees. Calculations assume the private institution cost inflation is 2.8%, public out of state cost inflation is 3.9%, public in state cost inflation is 2.7%. Portfolio is assumed to have only stocks and bonds. Monthly equity returns are based on the historical data from the 10-year track record of the stock market (SPY). Monthly fixed income returns are based on the historical data from the 10-year track record of the bond market index (AGG). The current college expenses are provided by the collegeboard.org. Actual account performance may differ due to market fluctuations, changes in recurring investments, and asset allocation. The information provided here is for illustrative purposes only and does not represent actual or future performance of any investment option and is not intended to predict or project the investment performance of any security or index.

Ksenia Yudina, CFA, MBA

Founder and CEO

Ksenia is the Founder and CEO of U-Nest, the first mobile app that makes it easy for families to save for college. As an entrepreneur and finance professional, Ksenia has focused on alleviating the impact of student debt on families across the economic spectrum. Previously, Ksenia was a Vice President atCapital Group/American Funds, the largest 529 provider in the U.S. In this role, she played a leadership role in helping parents plan and manage their finances, with a focus on the future well-being of their children. Prior to Capital Group/American Funds, she was founder of a residential real estate company. Ksenia earned her bachelor’s degree in finance from CaliforniaState University Northridge, and an MBA from UCLA’s Anderson School of Management.

Mike Van Kempen

Chief Operating Officer

Mike joined U-Nest in September 2019 as COO. He was previously at Acorns, a financial wellness platform, where he spearheaded the analytics and growth initiatives. Mike successfully expandedAcorns’ paid acquisition strategy, adding over 4.5 million investment accounts. Mike began his career in strategy & analytics at Belly, a Chicago-based loyalty startup in 2012. At Belly, Mike led projects that fueled growth across all aspects of the business, growing the customer base from1,000 to over 11,000 merchants, and accumulating a membership of over 2 million customers.Mike holds a B.B.A. in Finance from Loyola University of Chicago.

Steve Buchanan

Chief Technology Officer

Steve has over 20 years of experience in delivering digital innovations in the financial sector. Steve previously orchestrated product architecture and innovation as a Solutions Architect/ Fintech consultant at Union Bank. Prior to Union Bank, he was Chief Architect and Director of Engineering at Calypso, a Silicon Valley startup, where he architected and built multiple financial solutions. He was also Head of Global Integrations at Globe One in Vietnam where he integrated its Peer-to-Peer lending products into core banking solutions. Steve also built the first ever electronic Equities &Equity Options trading systems for Scottish stock brokers Wood Mackenzie (acquired by CountyNatWest). He is a graduate of Edinburgh University.

Peter Mansfield

Chief Marketing Officer

Peter has built an impressive track record in multiple financial industry segments including payments, credit/prepaid cards and lending. He has played an instrumental role at a succession of financial industry leaders, co-founding companies such as Brand3 (acquired by American Express) and PropertyBridge (acquired by Moneygram), and, as the early stage marketing lead at Marqeta (where he was team member number two), BillFloat and WallabyFinancial (acquired by Bankrate).He has helped fast-growth companies reach an aggregate market value of close to $8 billion. Peter holds a bachelor’s degree in economics from the University of Angila, UK.

Sonya Kidman

Client Relationship Manager

Sonya Kidman is a Customer Success professional with a decade of experience in advocating for consumer through user research and genuine empathy. Sonya specializes in user behavior and regularly attends national and global training sessions in wellness and people analytics tools. Sonya is a true global citizen was born in Russia, grew up in Israel, lived and worked in Canada and NewZealand. That global expertise along with an undergraduate degree in Sociology from Tel AvivUniversity have helped to shape a bullet-prof Sonya's framework to develop a winning customer strategy.

Frank Mastrangelo

Board Member

One part banker and one part technologist, Frank spent his early days with the Annenberg Foundation and PNC Bank. His career path led him to Jefferson Bank, where he led the build-out of its electronic banking platforms, and where he would forge a powerful alliance with The Bancorp co-founder Betsy Z. Cohen. As President and COO of The Bancorp from its inception in 1999 Frank played a critical role in helping the organization become an industry bellwether for branchless financial services and a global leader in payments. For this, he has become a widely respected fintech expert, and thought-leader. Frank was recognized in 2013 by Banking Innovation, a leading industry journal, as an “Innovator to Watch.” and as one of the innovators shaping the future of banking. Frank is a graduate of West Chester University of Pennsylvania.