Privacy Policy

1. Introduction

PlanForge Consulting ("PlanForge," "we," "us," or "our") provides retirement plan administration technology and participant portal services. Ideology Wealth Advisors, LLC ("Ideology"), a Registered Investment Advisor, provides investment advisory services through the PlanForge platform.

This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use the PlanForge 401(k) Participant Portal, mobile application, and related services (collectively, the "Portal").

2. Information We Collect

Personal Information

We collect information you provide during enrollment, account setup, and portal usage:

• Name, date of birth, and contact information (email, phone, address)
• Social Security Number (for account opening and tax reporting)
• Employment information (employer, hire date, employment status)
• Financial information (income, assets, investment experience, deferral elections)
• Beneficiary designations
• Risk tolerance questionnaire responses
• Banking information (for contributions and distributions)
• Electronic signatures on plan documents

Planning and Calculator Inputs

When you use our planning tools and calculators, we store the inputs you provide so your plan is personalized, your projections are consistent across sessions, and your advisor can help you interpret the results. This includes:

• Retirement goals, target retirement age, and expected lifestyle in retirement
• Hypothetical deferral scenarios you explore in Money in Motion
• Budget entries (income, expenses, custom categories) in the Budget Planner
• Outside account balances, debts, and net worth entries you add
• Savings goals and priority rankings in the Goals tool
• Risk tolerance questionnaire responses and assessment results

Messages and Support Data

• Messages you send to your advisor or to Alexis, our AI assistant
• Bug reports, feature requests, and other feedback you submit from the Profile page, including any screenshots you attach
• Device information included with feedback (platform, app version, screen size) to help us reproduce issues

Automatically Collected Information

• IP addresses and login location data (for security monitoring)
• Device information and browser type
• Portal usage patterns and feature interactions (which tools you open, not what you enter into them)
• Push notification device tokens (for app users)

3. How We Use Your Information

• Administering your 401(k) plan enrollment, contributions, and distributions
• Providing personalized investment recommendations through your advisor
• Processing account opening documents and e-signatures
• Sending notifications about your account (documents, deadlines, portfolio updates)
• Facilitating secure messaging between you and your plan advisor
• Generating AI-assisted responses from Alexis using Anthropic's Claude API (see Section 6)
• Detecting and preventing unauthorized access to your account
• Complying with regulatory requirements (SEC, FINRA, ERISA, IRS)
• Generating aggregate analytics for plan sponsors (no individual PII shared)
• Improving the portal through review of anonymized tool usage and approved feedback

4. How We Share Your Information

We do not sell your personal information and we do not share it for cross-context behavioral advertising. We share information with the following categories of recipients, each bound by contract to use the data only to provide services to you:

Advisory and Plan Administration

• Your plan advisor (Ideology Wealth Advisors, LLC) for investment advisory services and account management
• Your recordkeeper (Employee Fiduciary) for plan recordkeeping, Form 5500 filing, and participant account administration
• Custodians (Charles Schwab or as disclosed on your account statements) for account opening, trading, and asset custody
• Your plan sponsor (your employer) receives only aggregate plan statistics, not individual financial details

Technology Service Providers (Subprocessors)

• Neon (database hosting, United States)
• Vercel (application hosting and delivery, United States)
• Brevo (transactional email: account notices, document delivery, enrollment reminders)
• Twilio (SMS messaging: two-factor codes, daily digest, consented text alerts)
• Anvil (secure e-signature for plan documents)
• Anthropic, PBC (AI processing for Alexis responses; see Section 6)
• Google / Firebase (Android push notification delivery)
• Apple (iOS push notification delivery via APNs)
• Cal.com (advisor appointment scheduling)
• Slack (internal operational alerts; message content is included only for advisor-facing channels, never in public ones)
• Stripe (payment processing for Ideology Services fees if applicable; card and bank details are held by Stripe, not us)

Each subprocessor is under a data processing agreement that prohibits using your data for their own purposes. Anthropic, under our enterprise agreement, does not train their models on your data.

Legal and Compliance

• Regulatory authorities when required by law (SEC, FINRA, IRS, DOL, state regulators)
• Law enforcement in response to valid legal process (subpoena, court order, or statutory requirement)
• Successor entities in the event of a merger, acquisition, or sale of business assets, subject to equivalent privacy protections

Family Hub Sharing (Participant Controlled)

If you invite a spouse or family member to your Family Financial Hub, they receive access to the specific data categories you enable when sending the invite. You control what they see, you can revoke their access at any time from Family Hub settings, and inviting a family member does not grant them access to your login credentials.

5. Data Security

We implement multiple layers of security to protect your data:

• All data transmitted via TLS 1.2+ encryption
• Database encryption at rest (AES-256)
• Session authentication with automatic timeout after 15 minutes of inactivity
• PIN-based identity verification for sensitive operations
• Login anomaly detection (new location alerts)
• Append-only audit logging for all PII access
• Rate limiting on authentication endpoints
• Content Security Policy (CSP) headers on all pages

6. Artificial Intelligence (Ask Alexis)

Our Ask Alexis feature uses Anthropic's Claude API to generate AI-assisted replies for certain categories of questions. When you send a message that Alexis handles with AI, the following information is transmitted to Anthropic:

• Your message text
• A limited set of plan context (your plan's match formula, enrollment dates, fund lineup)
• Recent conversation history within the same Alexis thread (up to 10 prior messages)

We do not send to Anthropic:

• Your Social Security Number
• Your bank account or routing numbers
• Your PIN or password
• Your home address or phone number

Under our enterprise agreement with Anthropic, your data is not used to train Anthropic's AI models. Many questions are handled by keyword-matched template replies that do not invoke the AI at all; those do not transmit anything to Anthropic. Any answer that requires human judgment is routed to your advisor (Nick Moore) and answered personally. You can opt out of AI-assisted replies at any time by asking your advisor directly.

Alexis answers are generated by an AI system and may contain inaccuracies. Always verify material financial decisions with your advisor.

7. Data Retention

We retain your data for as long as necessary to provide services and comply with regulatory requirements:

• Signed documents and audit logs: 7 years (SEC Rule 17a-4 / FINRA Rule 4511)
• Account session records: 7 years for compliance audit trail
• Notifications and delivery logs: 90 to 180 days, then automatically purged
• Login security records: 1 year
• Cancelled session data: 90 days, then automatically purged

8. Your Rights

You have the following rights regarding your personal data:

• Right to access: Request a copy of all personal data we hold about you
• Right to deletion: Request deletion of your personal data (subject to regulatory retention requirements)
• Right to correction: Update or correct inaccurate personal information through your profile
• Right to portability: Export your data in a structured, machine-readable format
• Right to opt out: Manage notification preferences (push, email, quiet hours) in your profile settings

To exercise your data rights, visit the Privacy section in your profile settings or contact your plan advisor. Data export and deletion requests are processed through secure, authenticated endpoints within the portal.

9. State Privacy Rights

Several states give residents additional rights on top of the general rights in Section 8. These include the right to know what we collect, the right to delete (subject to retention requirements), the right to correct, the right to data portability, and the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising (which we do not do).

California (CCPA / CPRA)

California residents may also request disclosure of the categories of sources from which data was collected and the business or commercial purpose for collection. We do not sell or share personal information for cross-context behavioral advertising. We honor the Global Privacy Control (GPC) browser signal as a valid opt-out request.

Texas (TDPSA / HB 4)

Texas residents have rights to access, correct, delete, and obtain a portable copy of their personal data, and to opt out of targeted advertising, sale of personal data, and certain profiling. We do not engage in any of those activities. You may exercise your rights through the methods described in Section 8.

Virginia, Colorado, Connecticut, and Utah

Residents of Virginia, Colorado, Connecticut, and Utah have similar rights under their respective comprehensive privacy laws. We process requests from residents of these states the same way we process CCPA and TDPSA requests.

How to Exercise Your Rights

Submit requests through the data export or account deletion features in your profile settings, or email your advisor (Nick Moore, nick@planforge401k.com). We will respond within 45 days (Texas, Virginia, Colorado, Connecticut, Utah) or 45 days with one permitted 45-day extension (California). If we deny a request, we will explain why and you may appeal by replying to the denial email.

10. Push Notifications

Push notifications on iOS and Android are delivered via Apple Push Notification service (APNs) and Firebase Cloud Messaging (FCM) respectively. The push payload contains only the notification title and a short body (for example, “New message from Nick” or “Your quarterly statement is ready”). We do not include sensitive data like account balances, account numbers, SSNs, or detailed financial information in the push payload itself. To see details, you must open the app and authenticate.

You can turn off push notifications at any time from your device settings, or manage category-level preferences (documents, statements, reminders, partner updates) from the Notifications tab on your Profile page.

11. Beta Testing Program

If your plan participates in our beta testing program (marked with a “Beta” badge on the dashboard), you are helping us evaluate pre-release features before they ship broadly. During the beta:

• Your advisor reviews tool usage and calculator inputs more frequently to identify issues, confusing experiences, and opportunities to improve the product
• Feature requests and bug reports you submit are evaluated case-by-case. Approved submissions earn raffle entries toward prizes (including a monthly $100 Stillwell's Steakhouse gift card drawing for qualifying participants)
• Some features may be labeled as unavailable or in-development. Your feedback helps us prioritize which ones to finish first
• Your data is treated the same way as non-beta participants for security, retention, and sharing. Beta is an intensity-of-review difference, not a reduction in privacy protections

You can opt out of the beta program at any time by contacting your advisor. When you opt out, we stop the heightened product-improvement review; we do not delete your data or remove you from the portal. Raffle entries earned during beta participation remain eligible.

12. Cookies and Local Storage

The Portal uses essential cookies for session management and security. We do not use advertising or tracking cookies. The cookies we use include:

• Session cookie: Maintains your authenticated session (httpOnly, secure)
• PIN verification cookie: Tracks identity verification status (httpOnly, secure)
• Activity timestamp cookie: Enforces session timeout for security (httpOnly, secure)

13. Children's Privacy

The Portal is not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The version and last-updated date are shown at the top of this page. For material changes, we will notify you through the Portal notification system or via email, and you will be asked to acknowledge the updated policy on your next login before continuing to use the Portal. Non-material changes (clarifications, typo fixes, expanded examples) take effect when posted without a re-acceptance prompt.

15. Contact Us

If you have questions about this Privacy Policy or our data practices, contact your plan advisor: