What types of information does Pillar collect, how is it collected, and how does it use it?
1. Personal Information
c. “Secure Information” means your private, sensitive, personal information that you privately submit through the Services, including your health and medical information, financial information and legal information. Some of such health and health related information may be considered “Protected Health Information” or “PHI,” as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). While we may know whether and when you submitted a particular type or category of Secure Information, we do not in the course of our standard daily business operations have access to the content or details of any Secure Information you privately submit through the Services because it is encrypted. We will share your Secure Information only with your designated Read Or Write Access Sharer (as defined below) and only pursuant to your, or (if applicable) your Co-Administrator’s, explicit instruction, except when we are required to by law or in other rare circumstances, as described below.
d. “Use Information” means certain high-level information about your use of and access to the Services that may be visible to a financial advisor or Partner Provider if you accepted an Invitation from that financial advisor or Partner Provider, as applicable, to sign up for and access the Premium Services (as defined below) (if applicable), which may include the type of Pillar account you signed up for, the date and time of your last login to the Services, your total number of logins to the Services, and which sections of your Pillar dashboard you completed. We may share your Use Information only with your financial advisor (if applicable).
e. “Public Information” means any personally identifying information you post in any public forum through the Services (e.g., in the comments section below articles). Please remember that any Public Information you post publicly on the Services is not private, and thus may be used or disclosed by any third party who reads such Public Information without our control and without your knowledge, and search engines may index that information. Accordingly, please think carefully before publicly posting any Public Information on the Services.
2. Non-Personal Information
a. In contrast to Personal Information, “Non-Personal Information” does not, on its own, uniquely identify you or anyone else as a specific individual, but rather provides technical data, such as information about your interaction with the Services or about your browser. Non-Personal Information may include Aggregate Information, and Cookie Information, each of which is described in further detail below.
b. “Aggregate Information” means statistical information about how, how often, and when you use the Services and your demographic information. We may use Aggregate Information in order to understand how and how often people use the Services, which in turn allows us to improve them, but never in a way that is personally identifiable.
c. “Cookie Information” means information collected via cookies which enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services. Cookies are small pieces of data that are stored on your computer through your web browser when you access a website. Our cookies by themselves do not contain Personal Information, and we do not combine Cookie Information with your Personal Information to tell us who you are.
i. While many browsers have an option to turn off the cookie feature (which may prevent your browser from accepting any new cookie or may allow you to decide which cookie to accept from any website on a case-by-case basis), we strongly recommend that you leave cookies active because the Cookie Information we derive enables us to provide you with the most advantageous and attractive features of the Services.
3. Information Pillar Typically Does Not Collect (But Sometimes Might)
Does Pillar share the information it collects or receives, and if so, with whom and why?
1. Sharing with Read Or Write Access Sharers
a. We will share your Secure Information only with your designated Read Or Write Access Sharers and only pursuant to and in accordance with your opt-in authorization (“Authorization”) and explicit instruction, including the permissions you set that give any particular Read Or Write Access to only certain designated portions of your Pillar account. If you designate any of your Secure Information as only shareable with Read or Write Access Sharers after you are Declared Dead (the “After Death Sections”), then Pillar will only share such After Death Sections according to the timing and permissions that you have explicitly provided. As part of your use of the Services, you may designate one of your Read or Write Access Sharers as an “Unlocker” of your “After Death Sections.” With your explicit permission, the Unlocker will be able to alert Pillar that you have been “Declared Dead” through their use of the Services, and your “After Death Sections” will be made visible to your Read Or Write Access Deputies according to your Authorization, explicit instructions and permissions.
2. Sharing with Co-Administrators
a. If you are enrolled in a Household Membership, your Secure Information and your Read or Write Access Sharer Information are shared with any Co-Administrators associated with your Household Membership. Co-Administrators can equally view, edit, and administrate all parts of the Pillar account that you are using.
3. Sharing with Financial Advisors or Partner Providers
a. If you signed up for the Services using an Invitation you received from your financial advisor or a Partner Provider, then we may share your Use Information with such financial advisor or Partner Provider, all of whom are contractually bound to protect the confidentiality of your Personal Information. For the avoidance of doubt, we don’t share any of your Secure Information with Financial Advisors or Partner Providers unless you have designated them as a Read or Write Access Deputy for the particular Secure Information you have chosen to share.
4. Sharing with Agents
a. We may share certain of your Basic Information with certain partners or service providers we use to perform, facilitate or improve the Services (collectively, “Agents”), but only in order for Pillar to be able to provide you the Services. All of our Agents are contractually bound to protect the confidentiality of your Personal Information.
b. We may also share non-personal Aggregate Information with our Agents so that they understand how and how often people use our Services and their services, which in turn allows both us and them to improve.
c. We do not share your Secure Information with Agents.
5. Sharing with Acquirers
6. Sharing pursuant to applicable law
a. Other than sharing with Read Or Write Access Sharers, Agents or Acquirers as described above, we can only share Personal Information, including your Secure Information, in the limited circumstances described below relating to your abuse or misuse of the Services or legal process.
b. If we believe that you have misused or abused the Services or the Personal Information of any other user, or have attempted to interfere with or harm the Services, we will investigate and cooperate with appropriate law enforcement officials, which may include sharing your Basic Information with them in order to protect our rights or property or that of other users, Read Or Write Access Sharers, Agents, and others. We will give our full cooperation in any legal process or criminal investigation into any misuse or abuse of the Services.
c. We may also share your Personal Information solely to the extent required by law to comply with a subpoena or analogous legal process or governmental request; while this may include certain of your Secure Information, rest assured that we will never willingly share any of your Secure Information unless required by law. We may also share your Personal Information as otherwise necessary to protect our rights or property or that of other users, Read Or Write Access Sharers, Agents and others.
d. We will promptly notify you if we receive any request for your Personal Information or Secure Information from any governmental entity or other third party pursuant to a subpoena or analogous legal process before sharing any such requested information, unless we are legally prohibited from so notifying you or we have a good faith reason to believe that such sharing is or may be necessary to protect someone’s life, avoid serious physical injury or property loss or damage, or to prevent or investigate any ongoing crime.
How does Pillar protect, safeguard and secure the information it collects?
The security, privacy and confidentiality of your Personal Information is of utmost and critical importance to us, which is why we have implemented a variety of industry standard (or better) administrative, physical and technical protections to safeguard the security, privacy, confidentiality and integrity of your Personal Information, including without limitation your Secure Information.
For starters, your password is encrypted and not stored in a readable fashion. Moreover, our technology uses encryption algorithms of the same quality relied on by banks, the military and the U.S. government. When we collect, maintain, access, use, or disclose your Personal Information, including without limitation your Secured Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA. Accordingly, your Secure Information is stored in a HIPAA-compliant hosting provider that has 24/7 physical and biometric protections, firewalls, intrusion detection systems, and an array of other technological safeguards and security certifications.
Nevertheless, no website operator can guarantee that its security measures or safeguards will be 100% effective, and Pillar cannot guarantee absolute security of any of your Personal Information, including without limitation your Secure Information. PILLAR SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION, INCLUDING WITHOUT LIMITATION SECURE INFORMATION.
If we discover a security incident that compromises your Secure Information, we will let you know about it in accordance with applicable law. Please notify us immediately of any suspected or unauthorized use of your password or account or any other such incident by contacting us through our help center.
What are the privacy rights in California?
Pillar Technology Inc.79 Madison AveNew York, NY 10016
How does one delete a Pillar account?
If you wish to delete your account, you may do so by emailing us at firstname.lastname@example.org. When you delete your account, all of your Secure Information will be deleted or (if applicable) transferred to a Co-Administrator. Please note that we may keep your Non-Personal Information and any of your Personal Information other than your Secure Information even after your account deletion.
Any questions or concerns?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to please contact us through our help center. We will make all commercially reasonable efforts to resolve your concerns.
Effective Date: 08/11/2020
Last Update: 08/11/2020