Privacy Policy

Last Modified: November 20, 2023

These terms of use are entered into by and between you and Todd Inc., a Delaware corporation (“Todd,” “Company,” “we,” or “us”). The following terms and conditions, together with any documents they incorporate by reference (collectively, “Terms of Use”), govern your access to and use any Todd software applications, mobile applications, or websites, including the website at https://www.todd.inc/ and including any content, functionality, and services offered on or through https://www.todd.inc/ (collectively, the “Platform”), whether as a guest or a registered user.

Todd respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you use our services or our website, (collectively, the “Platform”), as discussed in our terms of use (the “Terms of Use”), which is incorporated herein by reference in its entirety.

This policy applies to information we collect:

• On this Platform, including on or through any website or software application related to this Platform.
• In email, text, and other electronic messages between you and this Platform.
• Through mobile and desktop applications you download to access this Platform.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using this Platform, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

‍Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to the Platform. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Platform, register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at info@toddcares.com.

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‍Information We Collect About You and How We Collect It

‍We collect several types of information from and about users of our Platform, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Platform, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us  

The information we collect on or through our Platform may include:

• Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Platform.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Platform.
• Your use and interaction with various features of the Platform.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform, or transmitted to other users of the Platform or third parties, including User Contributions, as defined in the Terms of Use. Such material is created or posted at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Platform according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Platform.

As an example, the technologies we may use for this automatic data collection may include or be similar to:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.

• Web Beacons. Pages of the Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Pixels. A pixel is a tiny snippet of code that gathers information about visitors on a website, which may include how you browse, what type of ads you click on, and other behaviors.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

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Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Platform are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

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How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Platform and its contents to you.
• To facilitate requested services by contacting your advisors, attorneys, beneficiaries, next-of-kin and the like.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account or subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Platform or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Platform.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or contact us.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

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Retention of Your Information

Your information is retained while you are a current or potential customer or as needed to provide our services to you. We will retain and use Your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies and as reasonably necessary and proportionate to provide our services and to achieve the purposes discussed herein. We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

You may request deletion of your data by contacting us at hello@todd.inc.

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Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

• To your designated beneficiaries, next-of-kin, advisors, and other third parties (wealth managers, registered investment advisors, certified public accountants, attorneys, estate planners, and the like) to perform the services of the Platform.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Platform users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and any other agreements you may enter into with Todd, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. Where applicable, we may provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Disclosure of Your Information for Third-Party Advertising. If we plan to share your personal information with unaffiliated or non-agent third parties for promotional purposes, we will provide you the option to opt-out by logging into the Platform and adjusting your user preferences in your account profile or by sending us an email with your request to hello@todd.inc.
• Promotional Offers from Company. If we plan to use your contact information to promote our own or third parties’ products or services, we will provide you the option to opt-out by logging into the Platform and adjusting your user preferences in your account profile or by sending us an email stating your request to hello@todd.inc. This opt-out does not apply to information provided to Company as a result of a product purchase, warranty registration, product service experience or other transactions.
• Targeted Advertising. If we plan to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, we will provide you the option to opt-out by adjusting your user preferences in your account profile or by sending us an email stating your request to  hello@todd.inc.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

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Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account profile page.

You may also send us an email at hello@todd.inc to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users.  Proper access and use of information provided on the Platform, including User Contributions, is governed by our Terms of Use.

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Data Security

We have implemented industry standard measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

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Your Rights

As previously described, you may have the right to:

• Access your information;
• Correct your information;
• Delete your information;
• Opt out of certain processing of your information;
• Obtain a portable copy of your information;
• Opt out of sales of your information;
• Opt out of processing of your sensitive data;
• Initiate a private cause of action for data breaches;
• Opt out or control use of automated decision making of your information, and
• Not be discriminated against for exercising one or more of these rights.

Specifically, you may have additional or complementary rights under one or more state or local laws, including but not limited to:

• California Consumer Privacy Act (2018; effective Jan. 1, 2020);
• California Privacy Rights Act (2020; fully operative Jan. 1, 2023);
• Colorado Privacy Act (2021; effective July 1, 2023);
• Connecticut Data Privacy Act (2022; effective July 1, 2023);
• Indiana Consumer Data Protection Act (2023; effective Jan. 1, 2026);
• Iowa Consumer Data Protection Act (2023; effective Jan. 1, 2025);
• Montana Consumer Data Privacy Act (2023, effective Oct. 1, 2024);
• Oregon Consumer Privacy Act (2023; effective July 1, 2024);
• Tennessee Information Protection Act (2023; effective July 1, 2025);
• Texas Data Privacy and Security Act (2023; effective July 1, 2024);
• Utah Consumer Privacy Act (2022; effective Dec. 31, 2023), or
• Virginia Consumer Data Protection Act (2021; effective Jan. 1, 2023).

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European Union’s General Data Protection Regulations (“GDPR”)

European residents may have certain rights under the European Union’s GDPR 2016/679.  The GDPR is a complex regulatory scheme and we do not intend to provide every detail here. The GDPR provides the right, where applicable, to (a) access, (b) publication, (c) erasure, (d) restrict processing, (e) object to processing, (f) data portability, (g) complain to a supervisory authority, and (h) withdraw consent. You may have one or more of these rights if you are a European Resident.To Exercise Your Rights:If applicable, you may exercise any of your rights in relation to your Personal Data by emailing Company at hello@todd.inc.  

‍Changes to Our Privacy Policy

‍It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Platform home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Platform home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

‍Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: hello@todd.inc.

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