- What personally identifiable information ("PII") is collected from you through the Site and Services, how it is used, and with whom it may be shared;
- What choices are available to you regarding your information;
- The security practices in place to protect against the unauthorized access, use, or disclosure of your information; and
- How you can correct any inaccuracies in the information.
Please note that you can reference our SmartDollar Terms of Service for the terms and conditions that govern 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:
- 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 web beacons, match scripts, pixel tags or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, or links in the email utilized. In some instances, these technologies may allow us to match activities with particular users;
- Information you enter via the Site or Services, such as your name, e-mail address, mailing address, or phone number; and
- Site and Services usage data.
- If you take advantage of our one-on-one coaching feature, either a Test Program or any permanent one-on-one coaching feature we may make available, we may collect the following information to share with the Financial Coach:
- Your topics of discussion for the coaching session;
- Your current Baby Step;
- Current action items, and in addition, action items assigned to you by your Financial Coach; and
- Debt Snowball details and SmartDollar progress.
Use of Information
In no event will we sell your information to third parties. Your information will be used to properly 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 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, marketing, authentication, customer service, fraud prevention, and public safety and legal functions.
Your information will not be accessible to anyone other than our team members or our third-party partners, including service providers that 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/or maintaining the Site, Services, or underlying technology of the same. If requested by your employer or the plan sponsor purchasing your subscription to the Services, 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 limitations on sharing activity are addressed below.
Sharing of Information
Because the Services are designed to promote your personal financial wellness and encourage participation in your retirement plan, your employer or plan sponsor from time to time 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 of their general business operations.
In no event will we share with your employer or plan sponsor, either directly or indirectly via a third party, your financial information which is personally identifiable to you. All information or data elements which are financial in nature and shared with your employer, plan sponsor, or applicable third parties will be in de-identified format or aggregated with other data to an extent that it does not uniquely identify you.
Within the parameters referenced above under "Use of Information", your personal information may be accessible by applicable third-party service providers. Some examples of the services these third parties provide in support of the Site, Services, your employer, or plan sponsor are as follows:
- Software and services which enable us to deliver, make available, maintain, and support the Services, including the support and ongoing improvement of customer service;
- Developing, hosting, or maintaining the Site on our behalf;
- Aggregating user information in non-identifiable aggregated format which we may then share with prospective marketing partners for the purposes of generalized product marketing, and thus not used to individually target users of the Services.
- California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. In maintaining compliance with regulations applicable to the nature of the Services, we have not and do not transfer information to third parties for direct marketing purposes. In the event we decided to do so in the future, we would provide affirmative consent and opt-out procedures, and any other required disclosures.
- Data warehouse, aggregation, and/or analysis in support of your employer’s or plan sponsor's general business operations and wellness programs. In the event we share data with non-wellness third parties at the request of your employer or plan sponsor, data shared will be limited to the following elements:
- SmartDollar Point Totals
- Employee ID Number (if provided by your employer)
- Enrichment Data - data elements provided to us by your employer 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. In no event will such data include any granular financial information that is personally identifiable to you.
- Aggregate information that may or may not be financial in nature, but in no event where such information is uniquely identifiable to you.
Service providers we utilize and with which we share your information are contractually limited in the ways they may use your personal information and are subject to confidentiality and industry standard security requirements. Third parties your employer or plan sponsor utilize, request, or require that we share your information with, or those that your employer or plan sponsor requests or requires to share information with us, are subject to any permitted-use, privacy, confidentiality, and security restrictions your employer or plan sponsor may have contractually in place with them. In your access or use of the Site and Services, you agree that The Lampo Group LLC, its corporate affiliates, subsidiaries, and their employees and agents are not responsible or liable for any use of your information we share with your employer, plan sponsor, or any third parties with which your employer or plan sponsor requests or requires us to share information or for any third party sharing your information with us at the request of your employer or plan sponsor. Although we cannot reasonably compel third parties utilized by your employer or plan sponsor to enter into contractual agreements with us, we make commercially reasonable efforts to enter into agreements with the same as an added protection for any information sharing activities and to ensure the confidentiality of such information.
Your PII may be shared with your employer or plan sponsor’s designated 401(k) provider ("Record Keeper") in support of your and/or your employer’s or plan sponsor’s retirement plan. Although PII may be shared with a Record Keeper, in no event will such data include any granular financial information that is personally identifiable to you. Sharing of data in this manner ensures that the Record Keeper can assess the aggregate impact of the Services and enables them to thoughtfully tailor communications they may send you regarding retirement plan participation.
Moreover, if a division or part or all our company is bought, sold, or otherwise transferred, or is in the process of a potential transaction, your information may be shared for evaluation purposes and included among the transferred business assets.
We may also 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.
YOUR CALIFORNIA PRIVACY RIGHTS (CALIFORNIA RESIDENTS)
California residents have the right to request a list of the companies with which we may share personal information for the third parties’ direct marketing purposes, a list of the categories of such personal information collected and shared, and the categories of sources from which the personal information is collected. California residents may make this request by e-mailing firstname.lastname@example.org. Please include "California Privacy Rights Request" in the first line of the description and your California mailing or street address.
If you are a California resident, you also have the right to access or request that we delete any Personal Information we have collected about you in the previous twelve (12) months and to inquire about our collection, sale, and disclosure of your Personal Information by calling us at 1-800-754-4220 or by e-mailing email@example.com.
Your exercise of these rights will have no adverse effect on the price and quality of our services.
California residents may request further information about compliance with California law and to make a request under California law by e-mailing firstname.lastname@example.org. Please include "California Privacy Rights Request" in the first line of the description and your California mailing or street address.
Your Access to and Control Over Information
You may opt out of any future contacts from us at any time. Contact us at email@example.com or by calling 1-800-754-4220 for any of the following:
- Learn what data we have about you;
- Change or correct any data we have about you; or
- Request deletion of any data in our in-scope application systems that are personally identifiable to you as a user of the Services. Please note that, while we make reasonable efforts to comply with such requests, deletion of personal information does not ensure complete and comprehensive removal of that data from all our systems due to certain technical limitations.
Do Not Track
Do Not Track (DNT) is a privacy preference that users can set in some web browsers, thereby allowing 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 to receive a promotion tailored to you. Neither we nor the Site control or guarantee the effectiveness of browser-based tools for managing cookies.
We are determined to keep your information private. We use industry-standard security techniques on the Site and within the Services to help protect against unauthorized access, use, or disclosure of information collected via your access and use of the Site and Services. However, while we strive to protect your personal information, 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 personal data 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. You may reference our General Statement on Information Security for more insight into our information security practices as they relate to the Site and Services.
How to Correct, Access, and Update Your Information
If you wish to access information that you have submitted through the Site or Services or to request the correction of any inaccurate information you have submitted through the same, you can do so by emailing us at firstname.lastname@example.org or by calling 1-800-754-4220.
The Site and Services are intended for access and use within the United States. The Site and Services are not intended for nor directed to citizens, domiciles, or residents of the European Union or to U.S. citizens based or located outside of the United States. Accordingly, the Site and Services comply with applicable United States federal law and state laws. By accessing and/or using the Site or Services, you affirm that you are not a citizen, domicile, or resident of the European Union nor a U.S. citizen based 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. Please note that while we make reasonable efforts to comply with such requests, deletion of personal information does not ensure complete and comprehensive removal of that data from all systems due to certain technical limitations. If you become aware of any PII we have collected from children under 13, please email us at email@example.com or call us at 1-800-754-4220.
Under Age 18
Minors under 18 years of age may request deletion of the personal information that they provide to us through the Site by sending an email to firstname.lastname@example.org or by calling 1-800-754-4220. Please note that, while we make reasonable efforts to comply with such requests, deletion of personal information does not ensure complete and comprehensive removal of that data from all systems due to certain technical limitations.
The Lampo Group, LLC
1011 Reams Fleming Blvd.,
Franklin, TN 37064
Last Updated: May 5, 2022