This Privacy Policy governs the manner in which OneEleven, Inc. (collectively, “OneEleven,” “we,” “our,” or “us”) collect, use, maintain and disclose information collected from users (a “user,” as well as “you,” “your” and similar terms) through our website, as well as any other online services that we operate and that link to this Privacy Policy (collectively, the “Services”).

By using the website or any of the Services, you signify your acceptance of this Privacy Policy.  If you do not agree to this Privacy Policy, please do not use the Services.

What Information Do We Collect and How Do We Collect It?

OneEleven strives to be fair and open about the way we collect information about you and what we intend to do with the information.

If you choose to use the Services, we may collect all or any of the following information:

  • Personal Information.  “Personal Information” is information and documentation that you provide to us that can be used to identify you, members of your family, or other dependents. We collect Personal Information from you that you voluntarily provide to us or permit us to obtain when you contact or interact with us, to request or utilize our services and, more generally, in connection with other activities, services, features or resources we make available through the Services, or otherwise, from time to time.  In addition, we may receive Personal Information about you, your family members and dependents from other entities that share such information with us.In order to provide you with our services, OneEleven may collect any or all of the following information (without limitation) either directly from you or from other sources with your consent:
    • Contact information (e.g., name, address, phone number, e-mail address, IP address)
    • Date of birth, credit score, financial dependents
    • Financial account information, including account balances and retirement savings contributions
    • Employment or other professional information
    • Demographic information, including gender and relationship status
    • Geo-location information
    • Information regarding income and expenses

Finally, Personal Information also includes financial account information, such as bank account or credit card information, that you may voluntarily provide to us if you are purchasing our Services, including a subscription service. Providing such information to us is governed by our Terms of Service.  We do not maintain or store any such financial account information; instead, when you provide that information to purchase our Services, the payment information is processed through a third-party provider.  We only use providers that we understand adhere to appropriate industry standards (such as Payment Card Industry Data Security Standards, or PCI-DSS).

  • Aggregate Information.  “Aggregate Information” is information that cannot be used to identify you, such as the type of browser and computer or mobile device you are using, technical information about your means of connecting to our Services (e.g., the operating system and the Internet or mobile service providers utilized), information about other websites you have recently visited, your site activity, and the time and date of your visit, and other similar information. Aggregate Information may be collected when you visit or interact with our Services, independent of any information you voluntarily enter.
  • Cookies.  A cookie is a data file placed on a device (such as your computer or smartphone) when it is used to visit our Services. Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove cookies on your device, some parts of our Services might not function properly, and that when you revisit our Services your ability to limit cookies is subject to your browser settings and limitations.

What Do We Do With the Information We Collect?

  • Personal Information.  We use Personal Information only as permitted or required by law, for the purposes of providing our Services to you (which Services may be provided by us or by a service provider acting for us), and communicating with you. We will not use your Personal Information for any other reason, except to the extent that you consent for us to do so, and in any event only as provided pursuant to this Privacy Policy. We limit access to Personal Information only to those individuals whose responsibility it is to address the user’s specific request.  We may use third party processor to process any financial account information you provide to us, although some features allow for you to process financial account information directly without the use of third party providers.  When any such financial account information is accessed or processed by third parties, third parties only access or process your information to provide the services you have requested.

We may also analyze your personal information for analytical purposes and to improve our algorithms in order to both improve the Services we provide you and to market additional Services that may be relevant to you.

  • Aggregate Information.  We use Aggregate Information for a variety of purposes, such as to understand how our users as a group use the Services, to improve the Services, to personalize user experience, and to process transactions. We also use Aggregate Information to track numbers of visitors to our site and numbers of visitors to various sections of our site for the purpose of determining trends and user needs. Aggregate information is analyzed and used as input to help us improve our site. No personally identifiable information is available or used in this process.

When Do We Provide Information to Third Parties?

  • Service Providers.  We may use third party service providers to perform certain services on our behalf on the Services, such as hosting the Services, tracking the Services’ activities and analytics, and performing other administrative services. We also use a third party processor to process any financial account information you provide to us if you purchase our Services, for the purposes of fulfilling the transactions you have requested, and to assist us in analyzing your personal information so we can improve our Services and market Services that may be relevant to you.  We may provide these service providers with access to user information, including Personal Information, solely to the extent necessary to carry out the Services they are performing. These third party service providers are not authorized to retain, share, store or use the Personal Information for any purposes other than to provide the Services they have been hired to provide.

In some circumstances, you may provide your information to OneEleven through our partners. Please note that you are subject to any applicable terms of use that our partners may employ, and that your personal information is also subject to the terms of their applicable privacy policies. OneEleven makes no representations regarding partner terms and policies, and takes no responsibility for their terms. If you have any questions or concerns regarding the terms of use or privacy policies of our partners, please contact them directly.

OneEleven uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using our Services, you grant OneEleven and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy, available at

  • Analytics. We use analytics services to help us understand how users use our Services, so that we may improve and market our Services.

Without limiting the above, we may access, use, preserve, transfer and disclose your Personal Information to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.

We reserve the right to disclose and transfer all user information: (a) to a subsequent owner, co- owner or operator of the Services or applicable database; or (b) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

Do You Retain and Delete My Data?

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. In some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information. We will retain, destroy, or dispose of your data in accordance with our data retention policy, consistent with applicable law.

How Do I Change My Information And Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us. You may provide updates and changes by contacting us at If so, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. 

Please note that we reserve the right to send you certain communications relating to use of our Services, such as administrative and service announcements, and these messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about your Privacy Policy or practices described in it, you should contact us by e-mail at

What About Children?

We do not knowingly collect any Personal Information from individuals younger than the age of eighteen (18). We will delete any Personal Information collected that we later determine to be from a user younger than the age of eighteen (18). If you are a parent or guardian of a child under the age of eighteen (18) and believe he or she has disclosed Personal Information to us, please contact us at

What About Security?

OneEleven is deeply committed to the integrity and security of your and your client’s Personal Information. OneEleven uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Personal Information. However, we cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use Personal Information for improper purposes. You acknowledge that you provide Personal Information at your own risk.

What If I Am a California Resident?

Although OneEleven does business in California, as of the date of this Privacy Policy we are not subject to the California Consumer Privacy Act (CCPA).

Nevertheless, if you are a California resident, please be advised that we do not sell your information (as the word “sale” or “sell” is defined under the CCPA). Further, we will honor the following rights, subject to reasonable limitations consistent with our lawful and legitimate business needs and interests:

  • Your request for access to Personal Information that we possess that pertains to you;
  • Your request that we delete any Personal Information that pertains to you.

To request access to your Personal Information or deletion of your Personal Information, please contact Once we have received your request, we will respond to you promptly to confirm your request and to advise you of the actions we will take in response to your request.

We honor “do not track” signals and do not track, use cookies, or use advertising when a “do not track” mechanism is in place.

We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies.

What If I Am in the UK, the European Union, or Switzerland?

OneEleven does not have an establishment in the UK, the European Union or Switzerland; it does not monitor data subjects in those jurisdictions; and it does not market its Services in those jurisdictions.  OneEleven is thus not subject to the General Data Protection Regulation (GDPR) or any other data protection law in these jurisdictions.

Nevertheless, individuals from these jurisdictions should be aware that any data provided to us is transmitted to and processed in data centers located in the United States.

Although we are not subject to these (or any non-U.S.) data protection laws, if you are a resident in these jurisdictions, we will honor the following rights, subject to reasonable limitations consistent with our lawful and legitimate business needs and interests:

  • Your request for an accounting of all Personal Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
  • Your request that we correct or update any Personal Information that pertains to you;
  • Your request that we delete any Personal Information that pertains to you; and
  • Your full or partial withdrawal of your consent to the collection, processing, and/or transfer of your Personal Information.

To request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information, please contact Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Will This Policy Change?

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued use of the Services following the posting of revisions to this Privacy Policy will be deemed your acceptance of such revisions. We encourage users to frequently check the email account that they use in connection with the Services, as well as this Privacy Policy, to stay informed about any changes to this Privacy Policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically. The date at the bottom of this Privacy Policy will be updated for each revision.


This Privacy Policy will be governed by and construed in accordance with the laws of the State of New York, USA, without regarding to conflicts of law principles. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Questions or Concerns

You may direct any questions or concerns regarding the use or disclosure of your information, or any other matter related to this Privacy Policy, to

Last Updated:  September 1, 2021