Subprocessors

The following is a list of third-party vendors and subprocessors who SmartPath has engaged to provide its services. 

Note: Not all vendors are used for every user's experience and depend upon services provided.

Updated: November 21, 2024

Vendor
Type(s) of Personal Information Disclosed
Reason(s) for Disclosure
Name
To maintain records of attendance for wealth management informational classes
Name, Email Address, Phone Number
To schedule appointments with our Coaches and Advisors
Name, Email, Phone Number, Activity Data
External communications
Name, Email, Phone Number, Date of Birth (at user organization’s discretion), Unique User ID
Secure file transfer from organizations
Name, Call Recordings and Contents
Meeting and call recording transcription and AI summarization services
Session Activity, IP Address, Device Attributes, Device Settings, Network Connection Information
Auto-capture of user activity to streamline support
IP Address, Device Attributes, Device Settings, Network Connection Information
Analysis of underlying data relating to website traffic
Name, Email Address, Phone Number, User Activity, Financial Information (Range only), Age Range (no Date of Birth), Marital Status, Dependent Status, Debt (Type & Range Amount only), Credit Rating / Score, Income (Range), Savings (Range), 401(k) Contributions (Range), Total Assets (Range), Pension, Living Situation, Income Tax Filing 
Cloud hosting to store data on behalf of SmartPath
Name, Email Address, Phone Number, Generated Reports with Financial Information
Email communications, calendar management, document creation
Name, Email, IP Address
Customer support management tool (shared inbox)
Phone Number, Call Recordings
Telephony
Name, Email Address, Phone Number, User Activity, Financial Information (Range only), Age Range (no Date of Birth), Marital Status, Dependent Status, Debt (Type & Range Amount only), Credit Rating / Score, Income (Range), Savings (Range), 401(k) Contributions (Range), Total Assets (Range), Pension, Living Situation, Income Tax Filing
To assist client in retirement planning and strategizing
Name, Email Address
Internal SmartPath team communications
Email Address, Survey Responses
Surveys and intake form information
Name, Email Address, Phone Number, User Activity, Financial Information (Range only), Age Range (no Date of Birth), Marital Status, Dependent Status, Debt (Type & Range Amount only), Credit Rating / Score, Income (Range), Savings (Range), 401(k) Contributions (Range), Total Assets (Range), Pension, Living Situation, Income Tax Filing 
Customer and internal reporting
Name, Email Address, Phone Number, User Activity, Financial Information (Range only), Age Range (no Date of Birth), Marital Status, Dependent Status, Debt (Type & Range Amount only), Credit Rating / Score, Income (Range), Savings (Range), 401(k) Contributions (Range), Total Assets (Range), Pension, Living Situation, Income Tax Filing, Sessions Recordings (Optional)
To assist in client wealth planning
Name, Email Address, Phone Number, User Activity, Financial Information (Range only), Age Range (no Date of Birth), Marital Status, Dependent Status, Debt (Type & Range Amount only), Credit Rating / Score, Income (Range), Savings (Range), 401(k) Contributions (Range), Total Assets (Range), Pension, Living Situation, Income Tax Filing 
Vendor system automation