Privacy Policy

We care about your privacy and want you to feel comfortable and secure in your use of our site.

At Boldin, NewRetirement, Inc. d/b/a Boldin, (“boldin.com”), we care about your privacy and want you to feel comfortable and secure in your use of our site (www.boldin.com).

We urge you to read this notice explaining our online information practices. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. By using this site, you are accepting the practices described in this Privacy Policy.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

TRUSTe

Information Collection and Use

Personal Information – this is “individually identifiable” information you provide to us when requesting information through our site.

We collect and use personal information about you to respond to any requests you make for information, products and/or services offered through this website. We may also collect information in order to inform you about products, services, and other opportunities we think will be of interest to you.

Even though some personal information we gather from you may be considered publicly available through government records or other public sources, we treat all personal information submitted by you as nonpublic personal information.

The information we collect includes, but is not limited to, information from the following places:

  • Information you supply to us when you sign up to receive communication from us (example: your email address).
  • Information provided by you in association with obtaining financial products or services (such as your name, age, telephone number, self-assessed property value).
  • Information you provide us through surveys, feedback, promotions or other forms hosted on our website or the pages of a boldin.com partner.
  • Information about others (such as beneficiaries, spouses, dependents, or other individuals identified in your account or in documents you provide to us), which we process to provide the services you have requested.
  • Documents and the contents of documents you upload to features like Vault, which may include financial statements, estate-planning documents (such as wills, trusts, and beneficiary designations), insurance documents, and tax records. These documents may contain account numbers, log-in credentials, government identifiers, signatures, and information about third parties such as beneficiaries and family members.

Information concerning personal data collected and used in connection with Google API Services is set forth in more detail below in “Google Authentication”. Our use of information received from Google API Services will adhere to the Google User Data Policy, including the applicable Limited Use requirements.

Google Authentication: When you use OAuth to log in to our application, we may collect your name, email address and other contact details associated with your account, as well as collect and store the permissions you grant our application during the consent process (collectively, “Google Data”).

The Google Data is (1) only used to provide the services; (2) not transferred to third parties except as necessary to provide or improve the services, as required by law, or in connection with a merger, acquisition, or sale of assets; (3) not used for serving advertisements or credit/lending purposes; (4) not retained to develop, improve, or train generalized AI and/or ML models; and (5) not read by humans, except (a) as necessary for security purposes or to comply with applicable law, (b) if we obtain your affirmative consent, or (c) limited to internal operations and the Google Data (including derivatives) have been anonymized and aggregated.

For clarity, even if you use AI-powered features, we will continue to treat Google Data in accordance with the commitments in this section.

Sensitive Personal Information

Some of the personal information we collect is considered “sensitive personal information” under the California Consumer Privacy Act and similar state laws. This may include your Social Security number and other government identifiers, account log-in credentials, financial account information, the contents of mail, email, and text messages, and (where you upload documents containing such information) information concerning health, racial or ethnic origin, religious beliefs, or sex life or sexual orientation.

We use sensitive personal information only to provide the services you request, to maintain and secure our services, and to comply with law. We do not use or disclose sensitive personal information for purposes that, under the CCPA, would require offering a right to limit. If you nevertheless wish to exercise a right to limit the use of sensitive personal information, email privacy@boldin.com or submit a request through the form linked from our footer.

AI-Powered Features (AI Assistant)

We may offer AI-powered features (such as an AI Assistant) that help you interact with and understand information in your account. When you use these AI-powered features, we may collect and process:

  • the content you submit (for example, messages, questions, and feedback);
  • the AI-generated responses; and
  • information from your Boldin account that you request the AI feature to use to respond (for example, financial planning inputs and account-related information).

We use this information to: (i) provide the AI feature and generate responses; (ii) maintain, monitor, secure, and troubleshoot the service; (iii) prevent fraud, abuse, and respond to security incidents; (iv) improve our AI-powered features (with your consent, as described below); and (v) comply with applicable law.

When you use Vault and other features that let you upload documents, the “content you submit” described above includes those documents and their contents, and our AI-powered features may parse them to extract structured information (for example, account holdings, beneficiaries, or policy details) for use within your plan. We request your consent prior to using Vault documents, document contents, or data extracted from them to train or improve AI or machine-learning models, We also do not use Vault content for advertising, audience segmentation, cross-context behavioral advertising, or marketing personalization without your consent.

Information Sharing and Disclosure

We do not sell personal information about you. We do not share personal information about you with other people or non-affiliated companies except to provide products or services you have specifically requested or as described below:

Product or Service Requests – If you enter a request for a financial, insurance or other product or service offered through this website with your consent, we will share personal information included in your request form, such as your name, email, physical address, telephone number, and property information, with lenders and partners in our provider network who offer the product you inquired about and like products with similar benefits to process and complete your request. Documents and document contents you upload to Vault are not shared with our lender or provider network in connection with product or service requests unless you explicitly direct us to share a specific document for a specific request.

Everyone on our network of providers, including banks, brokers and other firms has entered into a marketing agreement with boldin.com and are required to comply with state and federal privacy laws and regulations.

boldin.com and Partners on our provider network may contact you by telephone (including calls to a mobile phone or calls made using automated dialing), email, direct mail or any other method they may deem appropriate based on the information you supplied to us in order to process and complete your request, even if you have opted into the National Do Not Call List administered by the Federal Trade Commission or any state equivalent Do Not Call List.

If any of these firms calls you by telephone and you wish not to be contacted again by that firm, then you should notify that firm that you do not wish to be contacted again. If a firm ignores your request and contacts you again, please contact us immediately by sending an email to boldin.com Customer Service. Please note that the lenders and other firms may maintain the information you provided whether you choose to use their services or not.

Vendors / Service Providers – We may share certain information we collect with companies that provide services on our behalf (including marketing services, data verification, live chat, hosting, analytics, and third-party AI service providers that power our AI-powered features). When you use AI-powered features, your inputs and related account information may be processed by our third-party AI service provider(s) solely to generate responses and provide the feature. These companies only have access to personal information necessary to deliver their service, and are subject to confidentiality and other legal agreements with us. For Vault, we additionally engage secure document-storage providers and, where applicable, document-parsing and AI retrieval providers. These providers are bound by written agreements requiring confidentiality, encryption in transit and at rest, restricted access, and usage restrictions.

As Permitted by Law – In certain situations, NewRetirement, Inc., d/b/a Boldin, may be required to disclose personal data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be required to share your personal information with law enforcement or government agencies in response to subpoenas, court orders, similar legal process or like circumstances. We may use the personal information that you supply to us and we may work with other third parties to bring selected retail opportunities to you via direct mail, email and telemarketing. If you do not want us to share your personal information with these companies, contact us at Customer Service.

When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others. It may be necessary to share information in order to investigate, avert, or take action regarding illegal behavior, suspected fraud, and/or violations of boldin.com’s Terms of Use, or as otherwise required by law.

Business Transfer – At some point it is possible that Boldin could merge with or be acquired by another company, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

If such an acquisition occurs, the successor company would have access to the information maintained by boldin.com, including customer account information, but would continue to be bound by this Privacy Policy unless you agree otherwise.

Advertisements

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Anti-Spam Policy

With the exception of transactional email messages confirming or following up an action you’ve taken on our website, such as requesting information or registering a “Retirement Planner” account, boldin.com will only send email communications to you if you opt to submit your email address to us or register to receive them.

With the exception of transactional email messages confirming or following up an action you’ve taken on our website, such as requesting information or registering a “Retirement Planner” account, Boldin will include an opt-out opportunity to unsubscribe in all email communications; you may also opt out on our unsubscribe page. Sometimes, you may also receive emails that advertise boldin.com’s services from third party publishers.

We do not tolerate Spam and have established firm rules for dealing with any third party email services to ensure that advertisements for boldin.com are not sent out through a “Spam” mailing. Any third party email publishers that refuse to abide by boldin.com’s anti-Spam policy will be dropped as service providers. If you want to stop receiving emails from a third party, you should follow the opt-out instructions included in the third party email so that you will not be included in any future mailings.

If the third party email publisher is unresponsive to your requests, please let us know at boldin.com Customer Service.

IP Addresses and Cookies

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve marketing, analytics, and site functionality.

We at NewRetirement, Inc., d/b/a Boldin, and our partners use technologies such as cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. We also use TrustArc’s Cookie Consent Manager to enable us to configure and help us achieve cookie compliance requirements across the globe including GDPR and CCPA.

Framing – Some of our pages utilize framing and/or masking techniques to serve content from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to www.boldin.com.

Google OAuth, Facebook Connect or other OpenID provider – You can log in to our site using sign-in services such as Google OAuth, Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

Social Media (Features) and Widgets – Our Web site includes Social Media Features, such as the Facebook Like button [and Widgets, such as the Share this button or interactive mini-programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Public Forums – Our blog is managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or login into the third party application if you want the personal information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy.

Testimonials – With your consent we may post your testimonial along with your name. If you want your testimonial removed please contact us at Customer Service. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Confidentiality and Security

The security of your personal information is very important at boldin.com, and we take a number of steps to safeguard it. For example:

  • We use industry standard data encryption technologies when sending and receiving consumer information on the boldin.com website.
  • We maintain physical, electronic, and procedural safeguards designed to protect personal information about you.
  • No measures are 100% secure , however. Therefore, we cannot guarantee its security.
  • For documents you upload to Vault, we maintain additional safeguards, including encryption at rest, role-based access controls, access logging, and required multi-factor authentication for accessing the Vault.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Opting-Out

If you register or otherwise opt to receive communications from us, such as completing an online form, we will periodically send you newsletters and other e-mails featuring educational information, special offers, and other members-only benefits. If you would like to stop receiving these communications, please let us know by clicking here to unsubscribe or send an email to boldin.com Customer Service (you may also opt-out by clicking on the unsubscribe link in our emails). Our email database is updated regularly. However, you may continue to receive email communications from us up to ten business days from the time we receive your unsubscribe request.

This Privacy Policy applies to all information that you provide to boldin.com. Please keep in mind, when you visit websites to which boldin.com provides a link, you will be dealing with a third party that operates under its own privacy and security policy. If you choose to obtain certain services through a third party site, the data collected by the third party is covered by that third party’s privacy policy. We recommend you review the privacy policies of any other service provider from whom you request services.

Children’s Privacy

boldin.com does not knowingly collect information from children under the age of 16. If we learn that we have collected Personal Information of a child under the age of 16, we will delete that data from our systems.  This does not prevent account holders from uploading documents to Vault that reference minor beneficiaries or family members in the ordinary course of estate or financial planning. We do not direct our services to minors, do not knowingly create accounts for children, and do not build profiles or inferences about minors from Vault content.

Updating Your Information

Upon request NewRetirement, Inc., d/b/a Boldin, will provide you with information about whether we hold any of your personal information. You also have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it.

Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such requests of us, please contact boldin.com Customer Service.

You can also write us at the address below and request that your personal information be updated. We will respond to your request within a reasonable timeframe (no more than 45 days).

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at Customer Service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Vault Document Retention

Documents you upload to Vault are retained while your Vault is active. If you delete a document, or if your account is closed, we will remove the document from our active systems in accordance with our retention schedule. We may retain Vault documents longer where required by law (for example, to comply with a legal hold or with applicable regulatory record-keeping requirements). You may request a copy of your Vault documents at any time by submitting a verified access request as described in “Updating Your Information.”

AI Assistant Data Retention

If you use AI-powered features, we may store AI Assistant conversation transcripts to provide the feature, deliver customer support, troubleshooting, and ensure security. We retain AI Assistant conversation transcripts for up to ninety (90) days and then delete them, unless you opt-in to improve our models, or  a longer retention period is required or permitted by law (for example, to comply with legal obligations or to address fraud, abuse, or security incidents, or if the information has been deidentified).

Enterprise and White-Label Customers

If you access AI-powered features through an employer, financial institution, or other organization, different data retention terms may apply under that organization’s agreement with us. Please consult your administrator for details.

Deletion Requests

You may request deletion of your personal information as described in the “Updating Your Information” section above. If you request deletion, we will delete AI Assistant conversation transcripts associated with your account in accordance with applicable law, subject to the exceptions described in this Privacy Policy (such as retention required for legal compliance, fraud prevention, or security purposes). If you request deletion of your personal information, this includes documents you have uploaded to Vault, subject to the exceptions described in this Privacy Policy.

Jurisdiction-Specific Privacy Rights

For more information about privacy rights in your state, please see the section of this Privacy Policy called State Consumer Privacy Statement.

If you are a European Union citizen governed by GDPR. For more information about your privacy rights, please see the section of this Privacy Policy called General Data Privacy Regulation.

Questions and Suggestions

If you have any questions, concerns or suggestions about our Privacy Policy, you may contact us:

By sending an email to: privacy@boldin.com

By sending a letter to:
NewRetirement, Inc., d/b/a Boldin
Attn: Customer Service
1 Belvedere Drive, Suite 200
Mill Valley, CA 94941

Data Protection Officer: Frank Nevers

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the revised Policy on this page and update the “Last Updated” date above. If we make material changes, meaning changes that materially expand how we collect, use, share, or retain your personal information, we will provide additional notice before the change takes effect, such as by email to the address associated with your account or a prominent notice in our Service. Where applicable law requires your consent for a specific change (for example, the sale or sharing of personal information, the processing of sensitive personal information for new purposes, or the use of previously collected information for materially different purposes), we will obtain that consent in the manner required by law before applying the change to that information.

By using our site, you signify your assent to this Privacy Policy. If you do not agree, please do not use the site. Your continued use of the site after the effective date of an updated Privacy Policy will constitute acceptance of the updated Policy, except where additional consent is required by law.

Last updated: June 29, 2026

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