Privacy Policy

LAST UPDATED: March 03 2021

Description of Tango: Tango is a digital advice platform. Franklin Templeton is the investment manager, Bambu is the technology provider and Apex Clearing (Apex) is the custodian. Tango leverages “GOE” (Goals Optimization Engine).

At Apex, Franklin Templeton and Bambu we understand that privacy is an important issue for advisors and their customers. It is our policy to respect the privacy of all individuals that visit www.tangorobo.com and to protect the security and confidentiality of non‐public personal information relating to the visitors. Please note that this policy applies to all visitors, past & present, of www.tangorobo.com.

Personal Information Collected

We collect personal information about users of www.tangorobo.com, which may include the following:

Information provided by you such as your name, address, telephone number and email address.
Information relating to your business provided by you.
Information which may be gathered from readily available public sources regarding you and your firm.
Information which may be received from other sources with your consent or with the consent of your firm.
Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g. URL, browser type, pages visited, date/time of access);
Information captured by cookies (refer to the ‘Cookies’ section below).

How We Use Your Personal Information

The information collected about users of www.tangorobo.com will be shared among our business partners – Apex, Franklin Templeton and Bambu who may contact you to discuss your interest in Tango. Additionally, we may use the personal information we collect about users of www.tangorobo.com for some or all of the following purposes:

providing products, services and information that you requested;
personalizing your experience of our website;
administering the website, investigating any complaints and responding to inquiries;
providing website users with information and offers on products or services that may be of interest to them; and
performing statistical and trend analysis to improve the user experience and performance of our website.

Security

We strive to ensure that our systems are secure and that they meet industry standards. We seek to protect all information that is provided to us by you and your firm.

Cookies

We may use “cookies” to provide better service, to facilitate use of the website, to track usage of the website, and to address security hazards. A cookie is a small piece of information that a website stores on a personal computer, and which it can later retrieve.

You can learn more about each type of cookie we use and choose which cookie categories you wish to allow by visiting the Cookie Policy – HERE.

How to Contact Us

To learn more about Apex’s privacy practices, visit https://www.apexclearing.com/privacy-policy/

To learn more about Franklin Templeton’s privacy practices, visit https://www.franklintempleton.com/financial-professionals/help/privacy.

To learn more about Bambu’s privacy practices, visit https://bambu.co/privacy-policy

Apex reserves the right to make changes to this policy. For more information relating to Apex’s Privacy Policy or to limit our sharing of your personal information, please contact:

Apex Clearing Corporation
Attn: Compliance Department
350 N. St. Paul St., Suite 1300
Dallas, Texas 75201
214‐765‐1055

Tango is a collaboration among three entities: Franklin Advisors, Inc., Apex Clearing, and Bambu. Franklin Advisors is registered with the SEC as an investment adviser. Apex Clearing is a member of FINRA, a participant in SIPC and licensed in 53 states and territories. Bambu is a technology company based in Singapore, in which Franklin Templeton is a strategic investor.

Tango is a robo-advisor designed to empower advisors to provide personalized, goals-based wealth management at scale. The solution is a collaboration between Franklin Advisers, Inc. (“Franklin Advisers”), Apex Clearing Corporation (“Apex”) and Mangosteen BCC Pte Ltd (“Bambu”). Franklin Advisers provides the personalized, goals-based portfolio management advice to advisors through its proprietary Goals Optimization Engine (GOE™). Bambu’s white-label platform is the digital solution for clients and advisors, while Apex facilitates trading and custody through its modern back-end platform built for safety, scale and speed.

The Goals Optimization Engine used in Tango, is a digital solution that can be built into the electronic platforms of affiliated and unaffiliated investment advisers and other financial institutions (the “GOE Program Sponsors”) for use in connection with their managed account programs and the advisory services they provide to their clients (the “GOE Sponsor Clients”). The GOE Program uses Franklin Advisers’ proprietary investment algorithm (the “GOE Algorithm”) to select and recommend a portfolio (a “GOE Portfolio”) designed to best achieve a GOE Sponsor Client’s stated investment goal. The GOE Algorithm selects the recommended GOE Portfolio out of several prospective portfolios based on information provided about the GOE Sponsor Client relating to the client’s risk tolerance, initial investment amount, target goal amount, investment time horizon, priority of the goal, acceptable level of investment losses at goal tenure date, and expected future investment contributions and withdrawals. Franklin Advisers (based on the GOE Algorithm) then determines, in its discretion, whether to implement the GOE Portfolio recommendation. A GOE Portfolio will generally consist of U.S. Registered Funds, and in some cases will include or consist entirely of funds affiliated with Franklin Advisers or its affiliates (“Affiliated Funds”). The GOE Algorithm reassesses the progress of the GOE Portfolio at intervals pre-determined with each GOE Sponsor Client (or as the information provided on behalf of the GOE Sponsor Client is updated), and may identify and implement or recommend adjustments to the GOE Portfolio’s holdings at those times.

Franklin Advisers will, from time to time, have interests that conflict with the interests of clients investing through GOE. For example, Franklin Advisers and its affiliates receive asset-based and other fees for providing advisory and other services to the Affiliated Funds. Franklin Advisers, therefore, will have an incentive to include funds that have higher fees or profitability in any GOE Portfolio. Franklin Advisers may construct GOE Portfolios without considering the universe of potential funds sponsored by persons not affiliated with Frank Templeton (“Third Party Funds”), even though there may (or may not) be Third Party Funds that are more appropriate for inclusion in such GOE Portfolios, including available Third Party Funds in the applicable asset classes that have lower fees and expenses, greater performance or other favorable terms relative to an Affiliated Fund.

There are limitations inherent in the use of algorithms to manage accounts. For instance, an algorithm is not designed to actively manage asset allocations based on short-term market fluctuations or back-to-back down market events, or consider certain factors such as individual tax circumstances such as capital gains taxes. Rather, its functions consist of proposing a portfolio based on responses to the online questionnaire with respect to a GOE Sponsor Client, identifying opportunities for reallocation, and initiating recommendations accordingly. Franklin Advisers investment advisory personnel oversee the algorithm and the portfolios used and produced by the algorithm, but they do not personally or directly monitor each individual GOE Sponsor Client account. Franklin Advisers’ algorithms are subject to periodic updates, and modifications may have unintended consequences. There is also a risk that the algorithm and related software may not perform within intended parameters, which may result in a recommendation of a portfolio that is more aggressive or conservative than necessary, and trigger or fail to initiate a recommended reallocation.

Franklin Advisers has prepared a white paper describing GOE’s methodology in greater detail. A copy of the paper entitled “The Methodology Behind Franklin Templeton’s Goals Optimization Engine” is available upon request.

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