Privacy Policy

Daybright Financial Privacy Notice (Revised January 15, 2025)

This notice provides the Daybright Financial privacy policy regarding the nature, purpose, use, and sharing of any Personally Identifiable Information (PII) collected via this website. Our privacy policy explains our information practices when you provide PII to us, whether collected online or offline, or when you visit us online to browse, obtain information, or request additional information from us.

This privacy policy applies to all Daybright Financial websites that link to this policy. Specific websites that we used to provide transactional services or to fulfill our obligations to you or your employer may have different privacy policies. We encourage you to review the privacy policy for each website you use to communicate with Daybright Financial.

As used in the policy, Personally Identifiable Information (PII) may include: your name, email, mailing and/or home address, phone numbers, or other information that identifies you personally. We do not require you to register or provide personal information to visit our website.

The PII you provide on a Daybright Financial website will be used only for its intended purpose. We will protect your information consistent with the principles of all relevant laws and regulations. Daybright Financial does not sell any information that it collects to third parties, however information may be shared with third parties while fulfilling the services provided to you. If we share information to fulfill services we provide to you, we will identify this information in a separate Privacy Policy for that specific service.

Personally Identifiable Information

As a general rule, Daybright Financial does not collect PII about you when you visit our public website, unless you choose to provide such information to us. Submitting PII through our website is voluntary. By doing so, you are giving Daybright Financial your permission to use the information for the stated purpose. However, not providing certain information may result in Daybright Financial’s inability to provide you with the service you desire.

If you choose to provide us with PII on a Daybright Financial website, through such methods as completing a web form or sending us an email, we will use that information to help us provide you with the information or service you have requested or to respond to your message. The information we may receive from you varies based on what you do when visiting our site.

Generally, the information requested by Daybright Financial will be used to respond to your inquiry or to provide you with the service you request. When this information is requested, the reasons for collecting it, a description of Daybright Financial’s intended use of the information, how to grant consent to use mandatorily provided information, and how to grant consent for other uses will be fully described in a separate customized “Privacy Notice.” This customized Privacy Notice will either appear on the web page collecting the information or be accessible through a hyperlink (link) prominently displayed immediately above or below the information request.

Email

Many of our programs and websites allow you to send us emails. We will use the information you provide to respond to your inquiry. We will only send you general information via email. You should be reminded that email may not necessarily be secure against interception. Therefore, we suggest that you do not send sensitive personal data (such as your Social Security number) to us via email. If your intended email communication is very sensitive, or includes information such as your bank account, credit card, or Social Security number, you should instead send it by U.S. mail. Another alternative may be submission of data through a secure web page or another secure method. Please inform your contact at Daybright Financial if you would prefer to utilize a secure method of communication, and they will make one available to you. You should not send information by way of an encrypted file or attachment, as that cannot be processed by our systems.

Electronic mail messages received by Daybright Financial are covered under our document retention policy and cannot be deleted or destroyed. This means that emails you send us will be preserved and maintained for varying periods of time if those emails meet the definition established in our document retention policy. Electronic messages are deleted when no longer needed or when their retention classification expires.

Categories of information Daybright Financial Collects on its websites are further described below.

Automatically Collected Information

We collect and temporarily store certain information about your visit for use in site management and security purposes only. We collect and analyze this information because it will help us to better design our website to suit your needs. We may also automatically collect information about the web content you view in the event of a known security or virus threat. This information includes:

  • The Internet domain from which you access our website (for example, “xcompany.com” if you use a private Internet access account, or “yourschool.edu” if you connect from an educational domain).
  • The Internet Protocol (IP) address (a unique number for each computer connected to the Internet) from which you access our website.
  • The type of browser (e.g., Firefox, Internet Explorer, Chrome) and any browser extensions that are in use when you access our site.
  • The operating system (e.g., Windows, Mac OS, Unix) used to access our site.
  • The date and time you access our site.
  • The Universal Resource Locators (URLs), or addresses, of the pages you visit.
  • Your username, if it was used to log in to the website.
  • If you visited this website from another website, the URL of the forwarding site.

We may share the above information with our employees or representatives with a “need-to-know” in the performance of their duties, our marketing and web design providers, and other providers of technology or cybersecurity services to Daybright Financial. This information is only used to help us make our site more useful for you. Raw data logs are retained temporarily as required for security and site management purposes only.

Third-Party Websites and Applications

Daybright Financial uses social media websites and other kinds of third-party websites. Daybright Financial uses social media websites to interact with customers, potential customers, and the public at large. Social media websites are used to publicize Daybright Financial activities and events and engage with members of the public.

Daybright Financial uses web measurement and customization technologies to measure the number of visitors to our social media platforms, related websites, and their various sections and to help make our websites more useful to visitors. In such cases, the third-party application may request an email address, username, a user selected password, and geographic location (e.g., State, region, or ZIP code) for account registration purposes. Daybright Financial does not use third-party websites to solicit and collect PII from individuals. Any PII passively collected (i.e., not solicited) by the third-party website will not be transmitted or stored by Daybright Financial; and no PII will be disclosed, sold, or transferred to any other entity outside Daybright Financial, unless required for law enforcement purposes or by statute.

Daybright Financial uses various types of online surveys to collect opinions and feedback from a random sample of visitors. Primarily, surveys will be requested through either website banners or messages, or through email. Daybright Financial uses Microsoft Forms as our survey tool. Microsoft Forms is covered under the Microsoft Privacy Policy ( https://privacy.microsoft.com/en-us/privacystatement) and all data collected through Microsoft Forms is covered under this Privacy Policy or a specific Privacy Policy attached to a specific survey performed through Microsoft Forms. Daybright Financial will never request PII or any information such as passwords, account numbers, or Social Security Numbers through a Microsoft Forms survey.

Marketing Materials such as Newsletters and Requested Resources from our Website

Some Daybright Financial websites offer the opportunity to subscribe to recurring newsletters, research reports, or other materials that will be delivered to you via electronic means, physical U.S. Mail, or via a personal visit with a member of the Daybright Financial team (Marketing Materials). With your consent, you may subscribe to these optional services. The Marketing Materials will be described in the declaration of consent at the time we collect the information to deliver the Marketing Materials.

When you sign up for Marketing Materials on our website, we use the double-opt-in procedure for the application to our Marketing Materials, meaning that following your application we send you an email to the indicated email address, in which we ask you to confirm that you requested subscription to the Marketing Materials. This means that after you have registered, we will send you an email to the email address you provided, in which we ask you to confirm that you wish to receive the Marketing Materials. If you do not confirm your application within 24 hours, your information will be blocked and erased automatically after one month. In addition, we store the IP addresses used and the time of your application and confirmation. The purpose is to have proof of your application and if necessary to be able to clarify a possible misuse of your personal data.

The only obligatory information for the subscription to our Marketing Materials is your email address. The provision of additional, separately marked data is voluntary and is used in addressing you personally. After your confirmation, we will store your email address along with any data provided optionally for the purpose of sending you the Marketing Materials.

You may withdraw your consent to the subscription of the Marketing Materials at any time and you may cancel the Marketing Materials at any time. You may confirm the withdrawal by clicking on the link provided in each e-mailed communication regarding the Marketing Materials or by sending a message to the contact data indicated in the Marketing Materials.

We use the following external service providers to send Marketing Materials. In each case we have signed a separate third-party processing contract with the service provider to ensure the protection of your personal data.

When we send Marketing Materials through third-party external service providers, we continue to be the controller of the data, and the third-party external service provider is the processor. As the controller we are responsible for providing you with the opportunity to control the use of your personal information. We do this by providing instructions and an opportunity to manage your communication preferences as part of every communication.

Further information about our third-party external service providers, their Privacy Policies, and how to manage your data that they may have in their information systems is available on each provider’s website.

Twilio SendGrid  – https://www.twilio.com/en-us/legal/privacy/
ClickDimensions – https://clickdimensions.com/about/privacy-policy/
Intuit Mailchimp – https://mailchimp.com/about/privacy-rights/

Marketing Materials We Send Using Third Party Information or Prior Contact

From time to time, we may send Marketing Materials using information we obtain from third parties or based on prior contact we have had with you. While we try to ensure that all information provided by these third parties is accurate and that you have consented to receive the Marketing Materials, we rely on our contracts with these providers in sending our Marketing Materials.

In order to ensure that we are complying with your wishes in receiving Marketing Materials, we clearly identify our company, contact information, and methods you can use to stop receiving the Marketing Materials in every communication we have with you related to Marketing Materials.

We utilize the following third-party providers of contact information in our delivery of Marketing Materials. In each case we have signed a separate third-party processing contract with the service provider to ensure the protection of your personal data. Further information about the provider and their Privacy Policy is available on the provider’s website.

At this time, we do not utilize any third-party lists.

Information Collected for Tracking and Customization (Cookies)

A cookie is a small file that a website transfers to your computer to allow it to remember specific information about your session while you are connected. Cookies do not damage your computer and do not contain viruses.

We use cookies to make our websites more user-friendly, effective, and secure, and to enable the provision of certain functions. Your computer will only share the information in the cookie with the website that provided it, and no other website can request it.

Our websites utilize two types of cookies:

Session: Session cookies last only as long as your web browser is open. Once you close your browser, the cookie is deleted. Websites may use session cookies for technical purposes such as to enable better navigation through the site, or to allow you to customize your preferences for interacting with the site.

Persistent: Persistent cookies are saved on a user’s hard drive to determine which users are new to the site or are returning, and to save preferences for the site between sessions.

When you visit a Daybright Financial website for the first time, you will have the option to allow all, some, or no cookies from the website. You can set your browser so that you are informed about the settings of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when the browser is closed. You can regularly obtain the procedure for deactivating cookies via the ‘Help’ function of your Internet browser. If cookies are deactivated, the functionality and/or the full availability of this website may be restricted.

You will still have access to all information and resources at Daybright Financial websites. However, turning off cookies may affect the functioning of some Daybright Financial websites. Be aware that disabling cookies in your browser will affect cookie usage at all other websites you visit as well.

Cookies Provided to You by Third Party Service Providers

Some of the cookies that we use on our website are from third parties that help us analyze the effectiveness of our website content and the interests of our visitors, measure the performance and performance of our website, or deliver tailored advertising and other content to our websites or other websites put. As part of our website, we use both first-party cookies (only visible from the domain you are currently visiting) and third-party cookies (visible across domains and regularly set by third parties).

The cookie-based data processing takes place based on your consent to protect our legitimate interests in being able to provide you with a technically optimized, user-friendly and needs-based website and in guaranteeing the security of our systems. You can revoke consent that you have given us at any time, e.g. by deactivating the cookie-based tools/plugins listed in detail in the following overview. You can also object to processing based on legitimate interests by making the appropriate settings.

In detail, the following cookie-based tools/plugins are used on this website:

Google Analytics

We use the web analytics service Google Analytics on our website. Google is a group of companies and is headquartered at Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, and other affiliated companies of Google LLC.

The data processing serves the purpose of analyzing this website and its visitors as well as for marketing and advertising purposes. For this purpose, Google will use the information obtained on our behalf as the operator of this website to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to website activity and internet usage. The following information, among others, can be collected: IP address, date, and time of the page view, click path, information about the browser you are using and the device you are using (device), pages visited, referrer URL (website from which you accessed our website), location data, purchase activities. The IP address of your browser transmitted by Google Analytics is not linked to any other Google data.

Google Analytics uses technologies such as cookies, web storage in the browser and tracking pixels, which enable an analysis of your use of the website. The information about your use of our website generated by the Google Analytics cookies is normally transmitted to a Google server in the USA and stored there. The data transmission takes place based on standard contractual clauses as appropriate guarantees for the protection of personal data. These contractual clauses are available at available at:
( https://policies.google.com/privacy/frameworks )
( https://business.safety.google/ adsprocessorterms/).

Both Google and US government agencies have access to your data. Your data may be linked by Google with other data, such as your search history, your personal accounts, your usage data from other devices and any other data that Google has about you.

You can find more information on terms of use and data protection at:
( https://marketingplatform.google.com/about/analytics/terms/us/ ) or at
( https://policies.google.com/?hl=en&gl=de ) and at ( https://policies.google.com/technologies/cookies?hl=en ) .

Our website also uses Google Analytics reports for performance, based on demographic characteristics and interests as well as reports to impressions in the Google Display Network. You may deactivate Google Analytics for display advertising and set the displays in the Google Display Network by accessing the display settings under this link:
(https://www.google.de/ads/preferences?ac_tld=de&continue=aHR0cHM6Ly9hZHNzZXR0aW5ncy5nb29nbGUuZGUvYW5vbnltb3Vz.)

Google Tag Manager

This website uses Google Tag Manager. Google is a group of companies and is headquartered at Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA and other affiliated companies of Google LLC.

This service allows Daybright Financial to administer website tags centrally via an interface. Google Tag Manager implements only tags. No cookies are used and no personal data are collected.

Google has a suitable privacy policy for such data collection by third-party providers: https://marketingplatform.google.com/intl/de/about/analytics/tag-manager/use-policy/

However, Google Tag Manager does not access these data. If certain domains/websites or cookies were deactivated, it remains in place for all tracking tags provided that they are implemented using Google Tag Manager.

Facebook pixel for creating custom audiences with advanced data matching

Our social media posts and related web site pages may contain a ‘Facebook Pixel’ of the social network Facebook is used in the mode of extended data comparison, which is operated by Meta Platforms (‘Facebook’).

On the basis of their explicit consent, if a user clicks on an advertisement placed by us on Facebook, the URL of our linked page will be appended by Facebook Pixel. After forwarding, this URL parameter is then written to the user’s browser via cookie, which our linked page sets itself. In addition, specific customer data such as the email address, which we collect on our website linked to the Facebook ad for transactions such as purchases, account logins or registrations, is recorded by this cookie (extended data comparison). The cookie is then read by the Facebook pixel and enables the data, including specific customer data, to be forwarded to Facebook.

With the help of the Facebook pixel with extended data comparison, Facebook is able to precisely determine the visitors of our online offer as a target group for the display of advertisements (so-called ‘Facebook Ads’). Accordingly, we use the Facebook pixel with extended data comparison in order to only display the Facebook ads we have placed to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined based on the websites visited), which we transmit to Facebook (so-called ‘Custom Audiences’). With the help of the Facebook pixel with extended data comparison, we also want to ensure that our Facebook ads correspond to the potential interest of the user and are not annoying. In this way, we can further evaluate the effectiveness of the Facebook ads for statistical and market research purposes by understanding whether users were redirected to our website after clicking on a Facebook ad (so-called ‘Conversion’). Compared to the standard version of Facebook Pixel, the advanced data comparison feature helps us to better measure the effectiveness of our advertising campaigns by recording more attributed conversions.

All transmitted data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage guidelines (https://www.facebook.com/about/privacy/). The data can enable Facebook and its partners to place advertisements on and outside of Facebook.

If you wish to object to the use of Facebook’s Website Custom Audiences, you may do so under https://www.facebook.com/settings/?tab=ads .

In addition, we use Customer Match Lists in the context of our Facebook advertising activities, e.g. for ‘Lookalike Audiences’ and remarketing. For the use of Customer Match, lists with encrypted user data are uploaded to Facebook. After uploading the data, the system checks which data are already known and assigns the users to a list. After the preparation of the Customer Match List, the encrypted customer data is again automatically erased. Facebook does not obtain any new addresses in this process (encryption).

ZoomInfo

We use ZoomInfo Technologies LLC, a Delaware limited liability company, and its affiliates. for helping us find and contact potential customers as well as to identify specific information that visitors find interesting on our website. ZoomInfo utilizes third-party cookies on our website to provide these services.

ZoomInfo provides us and other companies with non-sensitive data, in a business context, for business purposes. We connect sellers and marketers with their next customer and recruiters with their next hire. We do this by offering the type of data you typically see on a business card or resume.

ZoomInfo maintains a complete privacy policy and customer information center at Trust Center | ZoomInfo ( https://www.zoominfo.com/trust-center ) as well as a trust center hosted by Vanta at https://trust.zoominfo.com/.

Postalytics

We use Postalytics, Inc. to send physical postal mail advertisements to help us find and contact potential customers. These advertisements may contain links, either visible or embedded in “QR Codes” which identify the specific individual that the advertisement was sent to. Postalytics uses technology solutions to provide us with information on who responded to a specific advertisement.

Information provided is limited to name, postal address, and the specific advertisement or offer that is being responded to.

Postalytics maintains a privacy policy at https://www.postalytics.com/legal/privacy-policy/.

Security

Daybright Financial takes the security of all PII very seriously. We take precautions to maintain the security, confidentiality, and integrity of the information we collect at this site. Such measures include access controls designed to limit access to the information to the extent necessary to accomplish our mission. We also employ various security technologies to protect the information stored on our systems. We routinely test our security measures to ensure that they remain operational and effective.

We take the following steps to secure the information we collect:

Employ internal access controls to ensure that only personnel who have access to your information are those with a need to do so to perform their official duties.

Train appropriate personnel on our privacy and security policies and compliance requirements.

Secure the areas where we retain paper copies of the information we collect online.

Perform regular backups of the information we collect online to ensure against loss.

Use technical controls to secure the information we collect online including, but not limited to:

  • Secure Socket Layer (SSL)
  • Encryption
  • Firewalls
  • Multifactor Authentication
  • Password protections

Periodically test our security procedures to ensure personnel and technical compliance.

Employ external access safeguards to identify and prevent unauthorized access by outsiders that attempt to “hack” into, or cause harm to, the information contained in our systems.

We hold our contractors and other third-party providers to the same high standards that we use to ensure the security, confidentiality, and integrity of personal information they may have access to in the course of their work completed on behalf of Daybright Financial.

Interaction With Children Online

Daybright Financial is committed to the protection of children’s online privacy. The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing personal information from a child under age 13.

Generally, Daybright Financial does not provide services to or request information from children under the age of 13. Data regarding children under the age of 13 may be processed in relation to data regarding their parent or legal guardian in connection with providing services to the parent or legal guardian. Any data regarding children under the age of 13 is provided to Daybright Financial by the parent or legal guardian of the child under the age of 13.

If a Daybright Financial website intends to collect information about children under 13 years old, COPPA-required information and instructions will be provided by the specific web page that collects information about the child. The web page will specify exactly what the information will be used for, who will see it, and how long it will be kept.

Visiting Other Websites

Our website contains links to government agencies, private organizations, and some commercial entities. These websites are not within our control and may not follow the same privacy, security, or accessibility policies. Once you link to another site, you are subject to the policies of that site. We encourage you to carefully consider the Privacy Policies of all sites that you visit and understand what information you provide to those sites and how it will be managed.

Privacy Policy Contact Information

We welcome feedback if you have any questions regarding our privacy policy or the use of your information. For additional information about our Privacy Policy, please contact us at privacy@daybright.com or via U.S. Mail at:

Daybright Financial

Privacy Office

99 Wood Avenue South, Suite 501

Iselin, NJ 08830