Wealthfront may track your online behavior across multiple devices and websites and try to connect your phone activity with your computer activity using location and device identifiers.
This analysis describes what Wealthfront's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This type of cross-device tracking creates a detailed behavioral profile that goes beyond account activity and may be used to infer patterns about your financial behavior, location, and interests.
Provision renamed and significantly expanded with concrete examples and specific technical methods (geo-location, device identifiers, browsing pattern analysis) used for cross-device matching.
View full change record →Consumers using both the Wealthfront app and website may have their browsing and location activity linked across devices to build a unified behavioral profile, which is used for service improvement and potentially marketing purposes.
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"Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your computer. To do this, we may analyze your browsing patterns, geo-location and device identifiers to match the information of the browser and devices that appear to be used by the same person.— Excerpt from Wealthfront's Wealthfront Privacy Policy
(1) REGULATORY LANDSCAPE: Cross-device tracking engages FTC guidance on online behavioral advertising and consumer privacy, CCPA's requirements for disclosure of data collection categories and purposes, and the Electronic Communications Privacy Act. The FTC has issued guidance on cross-device tracking practices and their disclosure requirements. California's CCPA requires disclosure of this type of data collection and grants consumers the right to know and, in some cases, to limit use. (2) GOVERNANCE EXPOSURE: Medium. The disclosure is present and specific, which supports compliance with CCPA's disclosure requirements. However, the scope of geo-location data collection combined with device identifier matching may trigger California's sensitive personal information provisions under CPRA amendments to CCPA, which impose additional opt-in requirements for precise geolocation data. (3) JURISDICTION FLAGS: California creates heightened exposure because CPRA designates precise geolocation as sensitive personal information requiring opt-in consent. Illinois and other states with emerging privacy legislation may also impose additional requirements. The policy states that the site does not respond to Do Not Track signals, which is legally permissible under current US law but may become regulated as state privacy laws mature. (4) CONTRACT AND VENDOR IMPLICATIONS: Third-party tracking technologies such as Google Analytics, referenced in the policy, are used for this purpose. Data sharing with Google Analytics should be assessed under CCPA's service provider definition to ensure it does not constitute a sale or sharing of personal information. Vendor data use agreements should confirm that Google and other analytics providers are restricted from using Wealthfront user data for their own purposes. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether precise geolocation collection triggers CPRA opt-in consent requirements for California users and update consent mechanisms accordingly. Cookie and tracking technology disclosures should be reviewed for alignment with state privacy laws in states with active enforcement, including California, Colorado, Connecticut, Virginia, and Texas.
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This type of cross-device tracking creates a detailed behavioral profile that goes beyond account activity and may be used to infer patterns about your financial behavior, location, and interests.
Consumers using both the Wealthfront app and website may have their browsing and location activity linked across devices to build a unified behavioral profile, which is used for service improvement and potentially marketing purposes.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Wealthfront.