MyWallSt Disclosure Policy
Last Modified: May 22nd, 2018
At Rubicoin t/a MyWallSt, when it comes to matters of money, we believe in transparency and accountability. Day in and day out, we dedicate ourselves to delivering responsible investing ideas and sound financial education. That's why, when it comes to talking about stocks, we think it's important that you know exactly where we're coming from. With this in mind, we have developed a company-wide disclosure policy to guide our business and communications. We invite you to take some time to read through it, and hope it helps inform your experience with MyWallSt.
Investors Communicating With Investors
MyWallSt is a company that represents investors teaching and learning from other investors. Many financial publications do not permit their writers and editors to own stocks. MyWallSt not only permits, but also encourages its staff to invest in common stock. Why? Two reasons.
First, we strongly believe the most effective way to create wealth is through the long-term ownership of stocks. The stock market has compounded 10% average annual returns over the last century. We believe in using the stock market as a savings bank, and we strongly encourage treating money management as a lifelong endeavor. Therefore, we think it'd be downright mean of us to close that avenue of investment to our employees.
Second, and more important, we don't consider our employees to be journalists, but rather communicators and teachers of financial matters. It's a subtle but critical difference that affects our entire service -- from our online site at mywallst.com, to our investment apps, to our podcasts and ebooks. As a company, we utilize every available medium to teach people of all ages, all income levels, all backgrounds, and all genetic codes about money and its applications in modern life. Therefore, we believe our staff's involvement in managing their own money is critical to their learning more about the subject and their succeeding in their own lives. And who better to write about investing than those who do it themselves?
MyWallSt writes about stocks in both free and paid content. We make stock recommendations in our MyWallSt app and hold all of these shares in our own personal portfolios. We will disclose our recommendation or ownership until we cease to recommend the stock, or we sell our entire position. Of course, in both free and paid content we will continue to disclose whether the author has an interest in the stocks mentioned.
Internally, MyWallSt has always strived to operate with the highest levels of integrity and transparency. As such, here are the key components of MyWallSt’s disclosure policy:
• When a writer writes about a stock that he or she has a position or beneficial interest in, that fact is disclosed at the end of the article.
• All MyWallSt employees are required to publicly disclose their current individual positions
• Affiliates of MyWallSt may provide individualized investment advice and investment products. These companies may recommend or hold securities mentioned in our publications. Editorial personnel have no knowledge of any affiliates' holdings and/or specific recommendations, and the affiliates' personnel have no knowledge of any editorial content before it is published. Our affiliate companies may also have their own disclosure policies, which they may make available on their respective sites.
In addition to the above disclosure requirements, MyWallSt employees work under additional trading restrictions and guidelines. These restrictions require that they:
• Must hold any stock they own for at least 10 days. (No day trading allowed -- as if we'd want to!)
• Cannot write about a stock in the period of 2 market days before to 2 market days after purchasing or selling the stock.
• Must notify our compliance department every time they buy or sell a stock, regardless of whether they have written about it.
Business and Technology Partners
We have business relationships with an ever-changing assortment of companies, including technology vendors, leasing companies, data providers, banks, distribution channels, advertisers, landlords, accountants, and legal advisors. Many of these companies are public companies operating in industries that we follow. There may be instances in which one of our services recommends a company with whom we have a business relationship. These occurrences are unintentional and coincidental, as the business end of MyWallSt has no input or influence on the editorial side of things.
We have designed our disclosure and trading guidelines to serve our community, our customers, and our employees fairly. As always, though, you should remember to consider every piece of investment information you receive, here at MyWallSt or elsewhere, not as a de facto recommendation, but as an idea for further consideration. Even the strongest disclosure policy in the world does not excuse individuals from taking responsibility for their own decisions. Due diligence, critical thought, and use of the most extraordinary device in the world (the human brain) are crucial to your financial success.
FINRA has provided its own insights into how to invest carefully in this new, electronic world and NASAA also provides tips on how not to fall prey to online investment schemes. The SEC, FINRA and the NASAA maintain outstanding websites at http://www.sec.gov and http://www.finra.org, and http://www.nasaa.org respectively.
The fundamental concept is that you should NOT rely upon the information or opinions you read. Rather, you should use what you read here as starting points for doing independent research on companies and investing techniques. Then judge for yourself the merits of the material that has been shared in our forum.
MyWallSt is not here to give you hot "tips," to make "buy" or "sell" recommendations, or to tell you what to do with your money. We're here to help you to learn how to make investment and personal finance decisions for yourself, and to have fun.
You are responsible for your own investment decisions. MyWallSt will not be responsible for any errors or omissions in articles or postings, for hyperlinks embedded in messages, or for any results obtained from the use of such information. MyWallSt will not be liable for any loss or damage caused by a reader's reliance on information obtained in our assets. If you don't accept this responsibility for yourself, then you should not use MyWallSt.
If you ignore our advice to do independent research of industries, companies, and stocks, choosing instead to trade solely on information, "tips," or opinions found in our forum, you have made a conscious, willing, free, and personal decision to do so. You have also probably made a mistake.
Data & Analysis
In the material and data that we make available on our site and apps, we rely on a wide variety of sources. We believe these sources of data to be accurate and reliable, but sometimes they may not be. MyWallSt makes no claims or representations as to the accuracy, completeness, or truth of any material contained in our areas. Nor is MyWallSt liable for any errors or delays in the content or transmission of the data on platforms. We promise not to lie to you, but we reserve the right to be wrong or even stupid.
Looking Out For Your Money
The MyWallSt website and apps are designed to help customers obtain financial information to support their investment and personal financial decisions. This information is sometimes provided by our staff and sometimes by others.
Effective date: May 21, 2018
Who are MyWallSt?
MyWallSt is a publisher and a technology platform, not a registered broker-dealer or registered investment adviser, and does not provide investment advice. Brokerage services are provided to clients of MyWallSt by DriveWealth LLC, an SEC registered broker-dealer and member FINRA/SIPC. Investing involves risk and investments may lose value. Past performance does not guarantee future results.
MyWallSt was founded in 2013 by two close friends with the mission to get the world investing successfully. MyWallSt stands for getting started, moving new investors from Zero to One.
Data Controller & Owner
Rubicoin LTD t/a MyWallSt, 5 Merrion Row, Dublin 2, Ireland
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service means the MyWallSt.com website, the Learn by MyWallSt & MyWallSt mobile applications operated by Rubicoin Ltd t/a MyWallSt.
Personal Data means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
How We Use Your Personal Data
We are committed to protecting the privacy of your information. Below, we describe the ways in which we use the information we collect and receive to provide, maintain, and improve the Service; to provide troubleshooting and customer support; to protect the Service for all our users and to contact you.
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide trouble-shooting and customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Rubicoin Ltd t/a MyWallSt. may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it's not overridden by your rights (see further details under ‘Legitimate interests’
- For payment processing purposes
- To comply with the law
We process your personal data when necessary to pursue our legitimate interests in the following cases:
- Tailoring our websites, apps and communications for you. We collect information about your engagement with us online (such as pages/screens that you have visited on our websites or apps) and combine that with aggregated insights we have about our user base, to build a fuller understanding of your individual preferences
- Send communication to our subscriber base in relation to new content, app & feature updates, critical changes or bug updates.
- Monitoring, improving and protecting our products, content and services
- Sending you some types of direct marketing by email, including a welcome email to users and subscribers
- Responding to your comments or complaints
- Undertaking, or inviting you to take part in, market research
Rubicoin Ltd t/a MyWallSt. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Disclosure Of Data
Disclosure for Law Enforcement
Under certain circumstances, Rubicoin Ltd t/a MyWallSt. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Rubicoin Ltd t/a MyWallSt. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Rubicoin Ltd t/a MyWallSt.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Content commenting services allow Users to make and publish their comments on the contents of this Application. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when users do not use the content commenting service.
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Rubicoin Ltd t/a MyWallSt. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at invest@MyWallSt.com.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data by contacting us on invest@MyWallSt.com
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Rubicoin Ltd t/a MyWallSt. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
How does MyWallSt disclose or share my information?
MyWallSt is not in the business of selling or renting your information.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
What type of External Third Parties do MyWallSt use?
Cloud storage providers - we use cloud computing platforms that securely store all of our data, including customer details.
Email service providers - in order to send you marketing content and transactional emails, we share your details with our email service providers.
Social Media Platforms - We may make your name and email address available to companies in order to advertise and market our services to you through other platforms on the internet (e.g. Facebook).
Analytics tools - we use analytics tools to track the way that users interact with our website. See more information under ‘Analytics Tools’.
Profiling tools - we use profiling tools to understand how you engage with our Services and show you content we think will be most relevant to you, based on our understanding of your interests and preferences.
Marketing and insights providers - marketing and insights tools allow us to understand our customers better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our customers to facilitate this process.
Customer service platforms - when you interact with our customer service team, your details are shared with our customer service platform providers.
Last updated: May 22, 2018
These Terms and Conditions ("Terms", "Terms and Conditions") govern your relationship with the mywallst.com site, the MyWallSt and Learn by MyWallSt mobile applications (the "Service", “Services”) operated by Rubicoin Ltd t/a MyWallSt ("us", "we", or "our").
Please read these Terms and Conditions carefully before using our Services
Your access to and use of the Services is conditioned on your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who access or use the Services.
By accessing or using the Services we offer you agree to be bound by these Terms. If you disagree with any part of the terms then you may not access the Service.
Information found on mywallst.com and in the apps that we produce is general information which may be helpful but should not be construed as legal, tax or other professional advice. Laws differ by state and country and we cannot guarantee the accuracy of this information for your particular scenario. You should consult an experienced attorney, tax professional or financial advisor concerning your specific situation.
Who can use the MyWallSt Services?
You must be at least 13 to use the Services. No individual under these age limits may use the Services, provide any Personal Data to MyWallSt, or otherwise submit Personal Data through the Services (e.g., a name, address, telephone number, or email address).
Rubicoin Ltd t/a MyWallSt offer a Subscription with a free trial for a limited period of time ("Free Trial").
At any time and without notice, Rubicoin Ltd t/a MyWallSt reserves the right to (i) modify the terms and conditions of the Free Trial offer, or (ii) cancel such Free Trial offer.
Parts of the Service are billed on a subscription basis ("Subscription(s)"). You will be billed in advance on a recurring and periodic basis ("Billing Cycle"). Billing cycles are set either on a monthly or annual basis, depending on the type of subscription plan you select when purchasing a Subscription
Important Information about our Subscriptions:
- Payment will be charged to your iTunes Account (iOS users) or Google Account (Android users) when you confirm your purchase.
- Your subscription automatically renews unless auto-renew is turned off at least 24-hours before the end of the period.
- Your account will be charged for renewal within 24-hours prior to the end of the current period.
- You can manage your subscription in the ‘You’ section of the MyWallSt application.
- There are no refunds for termination or cancellation of your Subscription. If you no longer wish to subscribe to MyWallSt, it is your responsibility to cancel your Subscription in due time, regardless of whether or not you actively use the Subscription.
- Any unused portion of the Free Trial period, will be forfeited when you purchase a subscription, where applicable.
Rubicoin Ltd t/a MyWallSt, in its sole discretion and at any time, may modify the Subscription fees for the Subscriptions. Any Subscription fee change will become effective at the end of the then-current Billing Cycle.
Rubicoin Ltd t/a MyWallSt will provide you with reasonable prior notice (at least 15 days) of any change in Subscription fees to give you an opportunity to terminate your Subscription before such change becomes effective.
Your continued use of the Service after the Subscription fee change comes into effect constitutes your agreement to pay the modified Subscription fee amount.
Refunds for Subscriptions are available.
If you purchased your Subscription through the mobile app via iTunes, you will need to contact them in order to get a refund.
Please contact Apple iTunes Customer Support directly at https://support.apple.com/contact.
• If you purchased your Subscription through the mobile app via Google Play, you will need to contact us them order to get a refund.
For more information please see here: https://support.google.com/googleplay/answer/2479637?hl=en
When you create an account for any of our Services, you must provide us with accurate and complete information as prompted by the account creation and registration process. Otherwise, some of our Services may not operate correctly, and we may not be able to contact you with important notices.
You are responsible for safeguarding the password that you use to access the Service and for any activities or actions under your password, whether your password is with our Service or a third-party service.
You agree not to disclose your password to any third party. You must notify us immediately upon becoming aware of any breach of security or unauthorized use of your account.
If you are a resident of the European Union: You have the right to delete your account with us by contacting us. If you choose to permanently delete your account, the non-public Personal Data that we have associated with your account will also be deleted.
The Service and its original content, features and functionality are, and will remain, the exclusive property of Rubicoin LTD t/a MyWallSt, it's subsidiaries and its licensors. The Service is protected by copyright, trademark, and other laws of both the United States and foreign countries. Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of Rubicoin LTD t/a MyWallSt.
Links To Other Web Sites
Our Service may contain links to third party web sites or services that are not owned or controlled by MyWallSt.
Rubicoin LTD t/a MyWallSt has no control over, and assumes no responsibility for the content, privacy policies, or practices of any third party web sites or services. We do not warrant the offerings of any of these entities/individuals or their websites.
You acknowledge and agree that Rubicoin LTD t/a MyWallSt shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by, or in connection with use of or reliance on any such content, goods or services available on or through any such third party web sites or services.
We strongly advise you to read the terms and conditions and privacy policies of any third party web sites or services that you visit.
We may terminate or suspend your account immediately, without prior notice or liability, for any reason whatsoever, including without limitation if you breach the Terms.
Upon termination, your right to use the Service will immediately cease. If you wish to terminate your account, you may simply discontinue using the Service.
You agree to defend, indemnify and hold harmless Rubicoin LTD t/a MyWallSt, it's subsidiaries and its licensee and licensors, and their employees, contractors, agents, officers and directors, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney''s fees), resulting from or arising out of a) your use and access of the Service, by you or any person using your account and password, or b) a breach of these Terms.
Limitation Of Liability
In no event shall Rubicoin LTD t/a MyWallSt, nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use the Service; (ii) any conduct or content of any third party on the Service; (iii) any content obtained from the Service; and (iv) unauthorized access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.
Your use of the Service is at your sole risk. The Service is provided on an "AS IS" and "AS AVAILABLE" basis.
The Service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance.
Rubicoin LTD t/a MyWallSt, its subsidiaries, affiliates, and its licensors do not warrant that a) the Service will function uninterrupted, secure or available at any particular time or location; b) any errors or defects will be corrected; c) the Service is free of viruses or other harmful components; or d) the results of using the Service will meet your requirements.
Some jurisdictions do not allow the exclusion of certain warranties or the exclusion or limitation of liability for consequential or incidental damages, so the limitations above may not apply to you.
These Terms shall be governed and construed in accordance with the laws of United States and the state of New York.
Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Service, and supersede and replace any prior agreements we might have had between us regarding the Service.
We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will try to provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.
By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Service.
If you have any questions about these Terms, please contact us: firstname.lastname@example.org
• Payment will be charged to your iTunes Account when you confirm your purchase.
• Your subscription automatically renews unless auto-renew is turned off at least 24-hours before the end of the period.
• Your account will be charged for renewal within 24-hours prior to the end of the current period.
• You can manage your subscription and auto-renewal in the Accounts Settings of your mobile device.
• Any unused portion of a free trial period, if offered, will be forfeited when you purchase a subscription, where applicable.
We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will provide at least 15 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.
By continuing to access or use our Service after any revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use the Service.
If you have any questions about these Terms, please contact us: email@example.com