Privacy Policy

Last Updated/Effective Date:  April 19, 2023

This Privacy Policy includes important information about your Personal Information, and we encourage you to read it carefully.

  1. Overview

Nexruto is a provider of virtual premium personal finance education courses including for persons at or approaching retirement age.  Nexruto LLC and its affiliates (“Nexruto,” “we,” “us” or “our”) respect your privacy.  This Privacy Policy describes the processing of Personal Information that we collect, use or share on the sites, applications, social media pages or other platforms that link to this Privacy Policy (collectively, the “Site”).  This Privacy Policy also describes your rights and choices, including the right to object to some uses of your Personal Information by us and how you can contact us about our privacy practices.  

  1. Personal Information That We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes or is reasonably capable of being associated with or linked to you.  The types of Personal Information that we collect may include:

  • Contact Information – If you submit an inquiry, register for an account or provide information on our Site, we may collect certain information about you.  This may include information such as your name, email address, date of birth, gender and phone number.  
  • Demographic Information – If you purchase services through the Site, you may be asked to provide information to confirm your identity, which may include your name, email address, zip code, date of birth and/or phone number.
  • Other Financial and Personal Information – We may collect, on your behalf, financial and other Personal Information from the parties that you have authorized us to share information with and from other parties.  Where required by law, our data providers or otherwise, we will obtain your authorization before seeking Personal Information from such third parties.  Depending on your use of the Site, you also may submit information relating to your spouse, beneficiaries or dependents.
  • Location Data – While navigating our Site, your mobile device or browser may share your location data, both through Wifi and GPS. We will collect this information based on the settings of your phone and browser.  
  • Usage Information – When you use our Site, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site and other such information.
  • Employment Information – If you apply for employment or a consulting position, we will collect your employment and work history, as well as other Personal Information related to your potential engagement. This may include your education and employment history, address and contact information, demographic information and any other information included in your resume or application.  
  • Communication Information – We may collect audio, electronic or visual information, which may include screen sharing views; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with us (whether via e-mail, social media, telephone or otherwise) and inferences that we may make from other Personal Information that we collect.

  1. How We Collect Your Personal Information

  • We May Collect Your Personal Information Directly From You – For example, if you request information from us (including downloading publications or other materials), register for our courses or otherwise purchase products or services from us or complete a contact form on our Site.

  • We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers and search information providers, who may provide us with Personal Information about you.  Such third parties may also include public records databases or other publicly available sources.

  • To Business Partners – We may share Personal Information with our trusted business partners such as course instructors.  These partners may use your Personal Information to, among other things, send you information or contact you directly about their services and products.

  • Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers and similar technologies such as pixels, web beacons and local storage to collect usage and browser information about how you use the Site.  We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization and to help us better understand the features of the Site that you and other users are most interested in. 

Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

  • Through Analytics – We use analytics services (including Google Analytics) to assist us with analyzing our website traffic through cookies and similar technologies.  For more information on Google Analytics’ processing of your Personal Information, please see https://policies.google.com/technologies/partner-sites?hl=en-US.  To learn more about how Google uses data, visit Google’s Privacy Policy at https://policies.google.com/privacy?hl=en-US. You may also opt out of Google Analytics using the “Google Analytics Opt-out Browser Add-on” at https://tools.google.com/dlpage/gaoptout 

  • Your Choices – Most browsers provide you with the ability to block, delete or disable cookies and similar technologies; and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available (or some functionality may be limited or unavailable).  Please review the help pages of your browser or mobile device for assistance with changing your settings.

  1. How We Use Personal Information

To the extent permitted by applicable law, we may use Personal Information to:

  • operate the Site and provide support to our business functions;
  • contact and access Third-Party Sites that you have permitted us to access;
  • fulfill customer requests, such as to create an account or complete purchases initiated by you through our Site;
  • protect against criminal activity, claims and other liabilities;
  • confirm that your account is valid and verify your identity;
  • send you information about our company and its products, services and promotions;
  • respond to reviews, comments or other feedback provided to us;
  • support and personalize the Site and our advertising efforts;
  • protect the security and integrity of the Site and other users thereof;
  • provide customer support;
  • the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
  • meet our contractual requirements and enforce our Terms of Service;
  • comply with applicable legal or regulatory requirements and our policies;
  • respond to inquiries related to employment or instructional opportunities;
  • market, advertise and provide the Site and related products and/or services;
  • provide information to certain authorized third parties with your consent; and
  • the extent necessary for any other lawful purpose for which the Personal Information is collected.

 

  1. Sharing of Personal Information

We will not sell, publish or share your Personal Information without your permission, except as specifically described in this Privacy Policy.  We may disclose your Personal Information in the following circumstances:

  • To Provide Our Services – We may disclose your Personal Information to our affiliates and other related companies, including, but not limited to, our partners, vendors, consultants and professional advisors, trusted affiliates, independent contractors and business partners who will use the information only as necessary for them to perform or provide the services advertised on the Site and for the specific purposes for which the information was collected.  We will not share the specific information you add without your consent as described in this Privacy Policy.

  • To Third Parties for Marketing Purposes – We may share your Personal Information with third parties for their marketing purposes. This may include third parties in whose services we believe you may be interested or who may be interested in providing you with services.

  • For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Service, (c) detect, prevent or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions or (e) protect the rights, property or safety of Nexruto, its users or the public against harm.

  • In the Case of a Merger or Sale – If we are involved in a merger, acquisition or any form of transfer or sale of some or all of our business (whether as a going concern or as part of bankruptcy, liquidation or similar proceeding), Personal Information may be transferred along with the business. Where legally required, we will give you prior notice and (if you have a legal right to do so) an opportunity to object to this transfer.

  • To Service Providers – When we hire a service provider to help operate our business, we may give access to Personal Information as necessary to perform such services.  This may include service providers that provide instruction advertised on the Site, send our communications or run our promotions.

  1. Anonymized, De-Identified or Aggregated Data

We may share or make available anonymous, de-identified or aggregate information that cannot be used to identify you individually. This anonymous, de-identified or aggregate information is not Personal Information and we may use anonymous, de-identified or aggregate information for any purpose allowed by law.

  1. How Long Do We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected (as outlined in this Privacy Policy) or any longer retention period required by law.  

If you choose to initiate a transaction for a financial product or service with an Authorized Third Party, we may retain the information associated with such transaction for the period required by any applicable agreement with such Authorized Third Party.

  1. How We Protect Your Personal Information

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process.  However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

  1. Your Choices and Controls

Depending on where you live, you may have the right to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. To opt out of marketing communications please email us at privacy@nexruto.com or by following the instructions included in the email or text correspondence.  

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing (or if you choose not to provide certain Personal Information), we may be unable to provide some or all of our services to you.

To exercise other rights with respect to your Personal Information, please see Section 13.

  1. International Use of the Site

The Site is hosted in the United States. If you are visiting this Site from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected or processed in the United States, where our data center and servers are located and operated.

  1. Children’s Privacy

We do not knowingly collect or solicit any Personal Information from children under the age of 18.  In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacy@nexruto.com or contact us using the information listed in Section 15.

  1. Links to Third-Party Websites

Our Site may contain links to third-party websites and services that are not owned or controlled by us. We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

  1. Exercising Your Individual Privacy Rights

We will only disclose your Personal Information with your consent or as otherwise described in this Privacy Policy.  You may opt-out of future disclosures at any time by contacting us at privacy@nexruto.com.  

If we disclosed Personal Information to a third party with your consent, you should contact such third party directly if you want to exercise your rights for the disclosed Personal Information.

To exercise your privacy rights under applicable data protection law, please submit a request to us by emailing us at privacy@nexruto.com. 

Verification: We must verify your identity before fulfilling your requests.  If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.  

        

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. 

We may deny certain requests (or only fulfill some in part) as permitted or required by law.  For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes

  1. Changes to this Privacy Policy  

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Site.  

  1. Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us at privacy@nexruto.com.  You may also write to us at:

Nexruto LLC

159 Forest Trail Drive

Landsdale, PA 19446

        

88988066.5