This policy will explain the following:
- The categories and specific pieces of personally identifiable information (“PII”) collected from you through the Site and Services, the categories and parties with whom the information may be shared, and how the information is used
- The choices available to you regarding your PII
- The security practices in place to protect against the unauthorized access, use, or disclosure of your information
- How you can make requests regarding your PII, including accessing and correcting, and where required by law, deleting, your information
Please note that you can reference the SmartDollar Terms of Service for the terms and conditions governing general access and use of the Site and Services.
Each time you visit the Site, we may automatically collect certain types of information. Some examples of information we may automatically collect, compile, and track are as follows:
- We may collect your internet service provider’s address, internet protocol or IP address, the web page from which you came, web browser software, the type of handheld or mobile device used to link to the web page, and the language settings on your web browser.
- We may collect a record of your activity or your “clickstream” while visiting the Site.
- We may use “cookies” of different types to recognize your computer. A cookie is a small text file that a website, online application, or email may save to your internet browser and/or your computer’s hard drive for use in subsequent visits to the Site or other sites related to the same. For more information, please see our Cookies Policy below.
- We may use web beacons, match scripts, pixel tags, or similar technologies that allow us to know if a particular web page was visited, an email opened, or links in the email utilized. In some instances, these technologies may allow us to match activities with users.
- We may collect information you enter via the Site or Services, such as your name, email address, mailing address, or phone number.
- We may collect Site and Services usage data.
- If you take advantage of our One-on-One Coaching, we may collect the following information to share with your coach:
- Your topics of discussion
- Your current Baby Step
- Current action items and action items assigned
- Debt Snowball details and SmartDollar Progress
Use of Information
We will not sell your information to third parties. Your information will be used to make available and deliver the Services to you. We may also use collected or compiled access and usage information for our own lawful research, benchmarking, and statistical purposes, which may help us to perform analysis for the purposes of improving the Site and Services and to manage our business. Aggregate or combined data may be collected from online and offline facilities and may be used to enhance our ability to communicate with you and to support business functions such as internal business processes, generalized marketing/non-personalized advertising, authentication, customer service, fraud prevention, public safety, and legal functions.
Your information will not be accessible to or shared with anyone other than our team members or our third-party partners or service providers, which we have vetted from a privacy and security perspective and who have a valid business need to properly fulfill their duties in supporting, managing, and maintaining the Site, Services, and underlying technology of the same.
If your employer or the plan sponsor purchasing your subscription to the Services requests it, we may share your information with them, their wellness vendor(s), third parties promoting the Services to them, or non-wellness third parties your employer or plan sponsor utilize in support of their general business operations. The information types we share and the limitations on sharing activity are addressed below.
Sharing Personally Identifiable Information
Because the Services are designed to promote your personal financial wellness and encourage participation in your retirement plan, your employer or plan sponsor may request that we share certain data elements or usage metrics directly with them, their wellness vendor(s), third parties promoting the Services to them, or non-wellness third parties they utilize to support their general business operations.
We do not share your personally identifiable financial information with your employer or plan sponsor, either directly or indirectly. If any financial information and data elements are shared with your employer, plan sponsor, or applicable third parties, it will be in de-identified format or aggregated with other data to such an extent that it does not uniquely identify you.
As noted above under “Use of Information,” your PII may be accessible by applicable third-party service providers. Some examples of the services that these third parties provide in support of the Site, Services, or your employer or plan sponsor include the following:
- Enabling us to deliver, make available, maintain, and support the Services, including support and ongoing improvement of customer service.
- Developing, hosting, or maintaining the Site on our behalf.
- Aggregating user information, which we may then share with prospective marketing partners in a non-identifiable, aggregated format for the purposes of generalized product marketing/non-personalized advertising. We do not sell or share your PII with third parties for targeted marketing purposes. In the event we decide to do so in the future, we will provide the opportunity for your affirmative consent, opt-out procedures, and any required disclosures.
- Data warehousing, aggregation, and analysis in support of your employer or plan sponsor’s general business operations and wellness programs. In the event we share data with non-wellness third parties at your employer’s or plan sponsor’s request, the data we share will be limited to the following elements:
- SmartDollar Points Totals.
- Employee ID Number, if provided by your employer.
- Enrichment Data—data elements your employer provides to us to support the effective use of the Services and to provide enhanced aggregated reporting and segmentation. Some examples of this include, but are not limited to, work location, business unit, union group, and job title. Such data will not include any granular financial information personally identifiable to you.
- Aggregate information, which may or may not be financial in nature, but which will in no event be information uniquely identifiable to you.
Your PII may be shared with your employer or plan sponsor’s designated 401(k) provider (“Record Keeper”) in support of your or your employer’s or plan sponsor’s retirement plan. Although PII may be shared with a Record Keeper, such data will not include any granular financial information that is personally identifiable to you. Sharing data in this manner ensures that the Record Keeper can assess the aggregate impact of the Services and enables the Record Keeper to thoughtfully tailor communications it may send to you regarding retirement plan participation.
Moreover, if a division or part or all of our company is bought, sold, or otherwise transferred, or is in the process of such a transaction, your information may be shared for evaluation purposes and included among the transferred business assets.
We also may disclose PII when such disclosure appears necessary to comply with the law, a subpoena, or other litigation process or to protect the lawful interests or safety of our customers, employees, or others. This includes potentially exchanging information with other companies, government agencies, and law enforcement organizations for fraud protection, information security purposes, and credit risk reduction.
PRIVACY RIGHTS UNDER CALIFORNIA AND VIRGINIA LAW
A California resident has the right to request that a business that collects, sells, or shares the California resident’s PII, or that discloses it for a business purpose, disclose to the resident (1) the categories of PII that the business collected about the resident; (2) the categories of sources from which the PII was collected; (3) the business or commercial purpose for collecting, selling, or sharing the PII; (4) the categories of third parties to whom the business discloses PII; (5) the specific pieces of PII the business has collected about the resident; (6) the categories of PII that the business sold or shared about the resident and the categories of third parties to whom the PII was sold or shared, by category or categories of PII for each category of third parties to whom the PII was sold or shared; (7) the categories of PII that the business disclosed about the resident for a business purpose; and (8) the categories of persons to whom it was disclosed for a business purpose. A California resident also has the right to request that a business that maintains inaccurate PII about the resident correct such inaccurate PII, taking into account the nature of the PII and the purposes of the processing of the PII.
A Virginia resident has the right to request that we (1) confirm whether or not a we are processing the resident’s PII and to access such PII; (2) correct inaccuracies in the resident’s PII, taking into account the nature of the PII and the purposes of the processing of the PII; (3) delete PII provided by or obtained about the consumer; (4) obtain a copy of the resident’s PII that the resident previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the resident to transmit the PII to another controller without hindrance, where the processing is carried out by automated means; and (5) to opt out of the processing of the PII for purposes of (i) targeted advertising, (ii) the sale of PII, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the resident.
California and Virginia residents may make the foregoing requests by calling us at 1.800.754.4220 or by sending an email to email@example.com and including “Privacy Rights Request” in the SUBJECT line. The email should also include the requestor’s street address and mailing address, if the mailing address is different from the street address. We will respond to your request within 45 days of receipt, except that we may extend the time to respond by an additional 45 days when reasonably necessary. In the case of the need for an extension, we will advise you of the extension and the reason therefor within the first 45 days after receipt of your request.
If we decline to act on your request, we will inform you of our justification for declining to act and instructions for how you may appeal our decision. Appeals may be commenced by sending a letter to us via U.S. Mail, first class postage prepaid and with delivery confirmation, addressed as follows:
The Lampo Group, LLC
Attention: SmartDollar In-House Counsel
1011 Reams Fleming Blvd.
Franklin, TN 37064
Your letter must include your name, physical and mailing address, a copy of the dated correspondence from us declining to act on your request, and an explanation of why you believe our justification for declining to act is in error.
Exercise of these rights will have no adverse effect on the price and quality of our services.
California and Virginia Residents' Right to Access and Control Their PII
To do any of the following, please contact us either by sending an email to firstname.lastname@example.org or calling 1.800.754.4220:
- Discover what data we have collected about you as a resident of California or Virginia
- Change/correct any data we have about you as a resident of California or Virginia
- Request that we delete any data in our in-scope application systems that are personally identifiable to you, a resident of California or Virginia, as a user of the Services
Do Not Track
Do Not Track (DNT) is a privacy preference that users can set in some web browsers. It allows users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, we and the Site do not recognize DNT.
The Site uses “cookies,” which are small pieces of information stored by your browser, other applications on your computer’s browser, or your hard drive. The cookies are used to connect your computer with information stored about your online activity, searches, preferences, and product purchases both within the same website visit and from one visit to the next on the Site and/or other websites. Some examples of this data include your account preferences, user specific information on pages accessed, searched terms or addresses entered, and previous visits to the site. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, or how to disable cookies altogether. If you reject cookies, you may not be able to benefit from certain features of the Site and Services or receive a generalized marketing promotion. Neither we nor the Site control or guarantee the effectiveness of browser-based tools for managing cookies.
We are determined to keep your information secure. We use industry-standard security techniques on the Site and within the Services to help protect against unauthorized access, use, and disclosure of information collected via your access and use of the Site and Services. However, while we strive to protect your PII, we cannot guarantee the security of the information you transmit to us via the Internet. In this regard, we urge you to take every precaution to protect your PII while you are on the Internet. At a minimum, we encourage you to make sure that you are using a secure browser as you surf the Internet and that you properly maintain and update the device you use to access the Site and Services.
Opt Out of Our Sharing or Selling Your PII (For California and Virginia Residents)
The Site and Services are intended for access and use within the United States. The Site and Services are neither intended for nor directed to citizens, domiciles, or residents of the European Union or U.S. citizens that are based out of or located outside of the United States. Accordingly, the Site and Services comply with applicable United States federal and state laws. By accessing or using the Site or Services, you are representing and affirming that you are neither a citizen, domicile, or resident of the European Union or other country nor a U.S. citizen based out of or located outside of the United States.
Our Site may contain links to other sites, including those of our business partners. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.
Under Age 13
We do not knowingly solicit or collect PII online from children under the age of 13 without prior verifiable parental consent. If we learn that a child under the age of 13 has submitted PII online without parental consent, we will take all reasonable measures to delete such information from our systems and not to use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any PII we have collected from children under 13, please send email notification to us at email@example.com or call us at 1.800.754.4220. We will act upon your request within 30 calendar days or as required by law.
Under Age 18
Minors under 18 years of age may request deletion of their PII by sending an email request to firstname.lastname@example.org or by calling 1.800.754.4220. We will act upon your request within 30 calendar days or as required by law.
The Lampo Group, LLC
Attention: SmartDollar In-House Counsel
1011 Reams Fleming Blvd.
Franklin, TN 37064
Last Updated: January 18, 2023
We use your personal data only for the purpose of supporting, managing, and maintaining the Site, Services, and underlying technology of the same.
If you object to our use of your personal data for this limited purpose, please close your SmartDollar account and submit a data deletion request to us via email at email@example.com or call us at 1-800-754-4220.
We do not sell or share your personal data with third parties for any purpose other than as stated below.
Your information will not be accessible to, sold, or shared with anyone other than our team members or our third-party partners or service providers, which we have vetted from a privacy and security perspective and who have a valid business need to properly fulfill their duties in supporting, managing, and maintaining the Site, Services, and underlying technology of the same.
In the event we decide to handle your personal data differently than as stated above, we would provide you with all required disclosures as well as affirmative consent and opt-out procedures.