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Privacy Policy

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Last Updated: April 16, 2024

This Privacy Policy describes how SavvyMoney, Inc. (“SavvyMoney,” “we” or “us”) collects, uses, and shares information about you (“You” or “Your”) that we obtain through Your use of the websites that reference this Privacy Policy (the “Websites”) and any services, materials, publications and communications provided to You in conjunction with the Websites (collectively, the “Programs”). Portions of the Programs may be available to You through the mobile applications, websites or other internet properties (collectively, “Apps”) provided by a Services Partner (defined below). This Privacy Policy also describes the choices available to You regarding our use of Your personal information and how You can access, update and request deletion of such information. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Service.

Please read this Privacy Policy carefully to understand our policies and practices regarding Your information and how we will treat it. By accessing and using any of the Websites and/or the Programs (directly or through an App), You agree to the terms and conditions of this Privacy Policy. If You do not agree to the terms and conditions of this Privacy Policy, please do not access or use any of the Websites or the Programs (directly or through an App) or provide any information to us. 

We may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, we will post a revised version of this Privacy Policy on the Websites. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” date at the top of this Privacy Policy. Your continued access to or use of any of the Websites and/or the Programs (directly or through an App) after any changes to this Privacy Policy have been posted shall constitute Your agreement and consent to such changes. Please return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

Collection and Use of Personal Information

Personal Information We Collect

We may collect certain information that identifies You or can be used to identify You (“Personal Information”) through Your use of the Websites and/or the Programs. If You enroll with us through the services, such as online banking or other services, of a Services Partner with whom You have a preexisting relationship, we may receive Personal Information about You from both You and Your Services Partner. If You inquire about or respond to offers for personalized loan or personalized offers for products or services (“Offers”) made by a Services Partner with which You may or may not have a preexisting relationship, we may receive certain Personal Information about You from both You and the Services Partner making such Offers. “Services Partner” includes any third party that provides You with access to the services on the Websites and/or the Programs, including by sponsoring such access, or otherwise invites You to access or use the Websites and/or Programs to view Offers and/or information contained on Your credit report. Services Partners include credit unions, banks, mortgage lenders, credit card issuers, other financial institutions, insurance providers, technology service providers, and other parties. Additionally, if You inquire about, apply for, or respond to Offers You receive from a Services Partner, we may receive certain Personal Information about You from both You and the Services Partner making such Offers to You. Lastly, if You authorize us to obtain Your credit report from one or more credit reporting agencies on Your behalf, we may receive certain Personal Information about You from such credit reporting agencies, including Your credit score(s). 

We may provide you with the opportunity to use a chatbot to answer your questions about the Programs and to provide customer support. Use of our chatbot requires that you have an account with us, and therefore we will request that you provide Personal Information via the chatbot to identify you as a SavvyMoney account holder. We ask that you not provide any sensitive Personal Information when using our chatbot.

Personal Information about You may include, but is not limited to, the following categories of information:

  • Name
  • Email address
  • Postal address
  • Telephone number
  • Date of birth
  • Social Security number
  • Unique Services Partner User ID
  • Information provided by You to authenticate Your identity
  • Username and password to access the Websites or the Programs
  • Credit information, such as Your credit score(s), number of open and closed credit accounts, outstanding amounts owed, payment history and other information contained in Your credit report

We collect Personal Information from the following sources: (a) directly from You through Your use of and interactions with the Websites and the Programs; (b) from Services Partners with which You have a preexisting relationship; (c) from Services Partners making Offers to You with which You may or may not have a preexisting relationship; (d) from Services Partners that have invited You to access or use the Websites and/or Programs to view Offers and/or information contained on Your credit report with which You may or may not have a preexisting relationship; and (e) after You enroll with us, from one or more credit reporting agencies.

In addition, as You navigate through and interact with the Websites or the Programs, we may use automatic data collection technologies to collect certain information about Your equipment, browsing actions and patterns, including:

  • Information about Your usage of the Websites and the Programs, including the dates on which You retrieved information contained on Your credit report, as well as traffic logs indicating pages and content You have accessed, traffic data, logs, and other communication data and the resources that You access and use on the Websites or the Programs.
  • Information relating to the browser and device You use to access and use the Websites and the Programs (such as the browser type, IP address, location of device, device ID, operating system, mobile network information) and other information that “fingerprints” (i.e., permits the identification of) Your device.
  • Keystroke tracking, which involves analyzing the rhythm and pattern of Your typing on Your keyboard.

For further information, see Cookies and Other Tracking Technologies below. 

Use of Personal Information

We may use Your Personal Information to:

  • Authenticate Your identity and prevent fraud.
  • Create an account with us and administer Your account.
  • Fulfill Your requests, respond to Your inquiries, provide the features You enroll for on the Websites and the Programs, and/or complete transactions You have requested.
  • Communicate with you via our chatbot. In addition, we use data collected via our chatbot to monitor the performance and effectiveness of our chatbot in order to continually enhance its accuracy and the user experience.
  • Retrieve Your credit report on an ongoing basis and monitor Your credit.
  • Send You the requested product or service information or inform You of products or services that we believe You may be interested in.
  • Provide and transmit information on applications You initiate in response to Offers made to You by a Services Partner.
  • Display content based on Your interests.
  • Send You important information regarding the Websites and/or the Programs, changes to our terms, conditions, and policies and/or other administrative information. If this information relates to Your account with us, You may not opt out of receiving such communications except by closing Your account.
  • For our internal business purposes, such as data analysis, audits, developing new products or services, enhancing and improving the Websites and the Programs, identifying usage trends and determining the effectiveness of features, offers and promotional campaigns.
  • For the benefit of Services Partners, including sharing performance metrics data to assist Services Partners in assessing the effectiveness of their campaigns, products and services.
  • As we believe to be required, necessary or appropriate: (a) to comply with legal process; (b) to respond to lawful requests by public authorities (which includes public authorities outside Your country of residence), including to meet national security or law enforcement requirements; (c) to enforce the Terms of Service; (d) to protect our operations, business and systems; (e) to protect our rights, privacy, safety or property, and/or that of other users of the Websites and Programs, including You; (f) in the case of a dispute, to allow us to pursue available remedies or limit the damages that we may sustain; and (g) in any manner permitted under applicable law, including the laws outside Your country of residence.

Choice/Opt-Out of Marketing Communications

You may choose to stop receiving marketing emails and communications from SavvyMoney by following the unsubscribe instructions included in such emails or communications, in the “Email Notifications” section under “Resources” on the Websites (if You are enrolled with us), or You can contact us at our contact information at the end of this Privacy Policy.

Information Sharing

We share Your Personal Information with third parties only in the ways that are described in this Privacy Policy. We do not sell Your Personal Information to any third parties.

We may share Your Personal Information with third parties that are our agents or that provide services to us to help us with our business activities and in providing the Websites and the Programs to You, such as authentication of the identity of users, preventing fraud, website hosting, data analysis, email delivery services, text delivery services, retrieving credit reports, credit application processing, chatbot functionality, and customer service. These third parties are authorized to use Your Personal Information only to enable them to provide services to us or act as our agents in performing the activities we are permitted to conduct under the Terms of Service and this Privacy Policy. We require that these third parties are bound by contractual obligations to keep Your Personal Information confidential and use it only for the purposes for which we disclose it to them.

We may share Your Personal Information with a Services Partner, including when You apply for Offers made by a Services Partner through the Websites or the Programs, or when You request that a Services Partner or other third party follow up with You about Your income, debt and spending, or to otherwise contact You regarding Offers and other promotions for which You may be eligible. Also, if You inquire about, apply for, or respond to Offers You receive from a Services Partner, we may share Your Personal Information with such Services Partner and its third-party providers that allow You to apply for such Offers. Additionally, we may share Your Personal Information with Services Partners that have invited You to access or use the Websites and/or Programs to view Offers and/or information contained on Your credit report. Lastly, if You seek customer service assistance from a Services Partner for Your account with us, such Services Partner may be provided with access to Your account, including all information contained in Your account. The Personal Information that we may share with a Services Partner include: (a) Your contact information (which includes Your name, email address, postal address, phone number and Unique Services Partner User ID); (b) whether You appear to qualify for Offers made available by such Services Partner; (c) based on Your credit report, whether You appear to meet certain credit thresholds or criteria; (d) Your credit score(s) and any credit application information You submit; and (e) information about Your usage of the Websites and/or the Programs, including the content You access. 

You may opt out of receiving marketing solicitations and other Offers from a Services Partner based on Your Personal Information provided by us to such Services Partner by contacting the Services Partner with which you have an account(s). For purposes of clarity, if You also wish to opt out of receiving emails and other communications from a Services Partner (which are not based on Your Personal Information provided by us to such Services Partner), You must do so in compliance with the applicable terms, conditions and privacy policy of such Services Partner. You may not opt out of viewing certain Offers that appear on Your screen when You are logged into an App offered by a Services Partner, whether or not based on Your Personal Information provided to us from such Services Partner. If any of the Websites or the Programs are no longer being offered or made available through a Services Partner, such Services Partner may notify You of such fact, even if You have opted out of receiving marketing emails and communications. 

Please understand that this Privacy Policy governs only SavvyMoney’s collection, use and disclosure of Your Personal Information. The collection, use and disclosure of Your Personal Information by a Services Partner or any other third party that You authorize to receive Your Personal Information is governed by that Services Partner’s or other third party’s privacy policy.

We may also disclose Your Personal Information:

  • As required by law, such as to comply with a subpoena or similar legal process.
  • To respond to lawful requests by public authorities (which may include public authorities outside Your country of residence).
  • To protect our rights, privacy, safety or property, and those of users of the Websites and the Programs, including You.
  • To an affiliate or other third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings) (each, a “Transaction”). If we are involved in a Transaction and a third- party receives Your Personal Information as a result, You will be notified via email and/or a prominent notice on the Websites of any change in ownership or use of Your Personal Information, as well as any choices You may have regarding Your Personal Information.
  • To any other third party with Your prior consent to do so.

Non-Personal Information

We may use and share freely any information that we collect from or about You that is not Personal Information, subject to applicable law. Any information about You that has been aggregated or anonymized, such that it cannot be used to identify any individual, is not considered Personal Information. When we combine information about You that is not Personal Information with Your Personal Information, we treat it as Personal Information for as long as it is combined with Your Personal Information. 

Do Not Track Signals

Your browser settings may allow You to automatically transmit a “Do Not Track” signal to online services You visit. Note, however, there is no industry consensus as to how website and app operators should respond to these signals. Accordingly, at this time, we do not respond to “Do Not Track” signals sent from Web browsers or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about a user’s online activities over time and across third-party internet services.

 

Cookies and Other Tracking Technologies

We use technologies such as Google Analytics, cookies and similar technologies for remembering Your user settings, customizing Your experience, and better understanding how the Websites and the Programs are used. Among other things, these technologies are used in analyzing trends, administering the Websites, tracking users’ movements around the Websites and gathering demographic information about our user base as a whole, and we may receive a variety of reports about how users interact with the Websites.

Users can control the use of cookies at the individual browser level. If You reject cookies, You may still use the Websites, but Your ability to use some features or areas of the Websites may be limited.

To opt out of Google Analytics, please see https://tools.google.com/dlpage/gaoptout.

Log files

As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may automatically combine this type of collected log information with other information we collect about You. We do this to improve the Websites and the Programs, to analyze and understand usage, and to administer the Websites and the Programs.

Data Security

We have implemented industry-standard physical, administrative, and technical safeguards to preserve the integrity and security of Your Personal Information. Such safeguards include using secure socket layers (SSL) and encryption both during transmission of Your Personal Information (such as Your address, date of birth, and social security number) and after we receive Your Personal Information. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the absolute security of any information You transmit to us or which is transmitted by us, You authorize us to obtain on Your behalf, or You receive from us, and we cannot guarantee that Your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, administrative and/or technical safeguards. Additionally, we will not be responsible or liable to You for third party circumvention of our security measures. If You have reason to believe that Your interaction with us is no longer secure (for example, if You believe that the security of any account You might have with us has been compromised), You must immediately notify us of the problem by contacting us at our contact information at the end of this Privacy Policy.

In our agreements with Services Partners, we commit to maintaining an information security program, and notifying the Services Partners of any security breaches, consistent with the applicable obligations of the Services Partners under the Gramm-Leach-Bliley Act.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. In particular, California law grants additional privacy rights to California residents. In particular, the California Privacy Rights Act of 2020 (“CPRA”), amending the California Consumer Privacy Act of 2018, requires businesses to disclose, for the past 12 months: (a) the categories of personal information collected, (b) the sources of the collected personal information, (c) the purposes for which the collected personal information is used, (d) the categories of personal information disclosed for a business purpose, and (e) the categories of any personal information sold or shared. We provide these disclosures in the following table, subject to further disclosures elsewhere in this Privacy Policy. In addition, the CPRA provides specific rights to limit the use of personal information defined as “sensitive.” 

Please note that SavvyMoney does not “sell” or “share” any of Your Personal Information as those terms are defined in the CPRA. With respect to any of Your Personal Information defined under the CPRA as “sensitive” (e.g., social security number and financial account information), SavvyMoney only uses such information as necessary to provide the Websites and Programs.

Identifiers

  • Sources of Collection: Access and use of Website and Programs, creation of accounts, enrollment for SavvyMoney products and services
  • Purposes of Collection: To enroll You into SavvyMoney products and services made available on the Website and Programs, and to communicate with You
  • Disclosures for a Business Purpose: To Services Partners and SavvyMoney service providers to assist in providing SavvyMoney products and services made available on the Website and the Programs

Personal information categories listed in the California Customer Records statute

  • Sources of Collection: Enrollment into SavvyMoney products and services made available on the Website and the Programs and Services Partners
  • Purposes of Collection: To enable SavvyMoney to provide its products and services made available on the Website and the Programs to You and to allow SavvyMoney to communicate with You
  • Disclosures for a Business Purpose: To Services Partners and SavvyMoney service providers to assist in providing SavvyMoney products and services made available on the Website and Programs

Commercial information

  • Sources of Collection: Purchase of SavvyMoney products and services made available on the Website and the Programs and Services Partners
  • Purposes of Collection: To provide SavvyMoney products and services to customers and maintain purchase history
  • Disclosures for a Business Purpose: To Services Partners and SavvyMoney service providers to facilitate delivery of products and services made available on the Website and the Programs

Internet or other electronic network activity

  • Sources of Collection: Your browsing and search history on the Website and other interaction with the Website and Programs
  • Purposes of Collection: To improve the user experience on the Website and Programs, diagnose server problems and administer the Website and Programs
  • Disclosures for a Business Purpose: To third-party analytics services providers for the purpose of enhancing the Website and Programs and improving the effectiveness of our advertising

Sensitive personal information

  • Sources of Collection: Creation of accounts, enrollment into SavvyMoney products and services, and Services Partners
  • Purposes of Collection: To provide SavvyMoney products and services made available on the Website and the Programs to You
  • Disclosures for a Business Purpose: To Services Partners to assist in providing SavvyMoney products and services made available on the Website and the Programs to You

California residents also have the rights described below.

Right to access/know Your Personal Information. You may request from us a list of (a) the Personal Information that we have collected about You, and (b) the categories of third parties to which we have disclosed Your Personal Information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete Your Personal Information. You may request, at any time, that we delete Your Personal Information and direct our service providers to delete Your Personal Information from their records. We are not required to delete any information that is necessary to provide the products or services You have requested, to detect security incidents, or to comply with a legal obligation, among other limited exceptions.

Right to limit use of Your Personal Information that is sensitive. You may request, at any time, that we limit our use of sensitive Personal Information to that use that is necessary to provide the Websites and Programs to You.

You may contact us to exercise these rights at privacy@savvymoney.com. To ensure the privacy and protection of individuals, we are required to verify Your identity (or that of Your authorized agent) or otherwise authenticate Your request(s), which we will do in accordance with the CPRA regulations. Please note that, under the CPRA, we are not required to grant a request to access/know or a request to delete with respect to Personal Information obtained from You in Your role as an employee, owner, director, officer or contractor of a company and within the context of SavvyMoney providing its services to such company.

Under the CPRA, You have a right to be free from discrimination as a result of exercising any of the CPRA rights afforded to California residents. If You choose to exercise such rights, we will not deny You the ability to use the Websites or the Programs (or suggest that we might do so), charge You or the Services Partner a different rate for the Programs (or suggest that we might do so) or change the quality of the Websites or the Programs pertaining to You. The only exceptions are when You have an account with us and: (a) You wish to delete any or all of Your Personal Information or (b) You wish for SavvyMoney not to share Your Personal Information with third parties, in either which case You may do so only by closing Your account with us, at which point You will no longer have the ability to access the member-only features of the Websites and the Programs. If You do not have an account with us and (i) You wish to delete any or all of Your Personal Information or (ii) You wish for SavvyMoney not to share Your Personal Information with third parties, please contact us at our contact information at the end of this Privacy Policy with Your request.

Accessing, Correcting, Updating and Deleting Your Personal Information

Upon request, SavvyMoney will provide You with information about whether we hold any of Your Personal Information.

To access, correct or update Your Personal Information or to ensure it is accurate, contact us at our contact information at the end of this Privacy Policy. In order to comply with any of Your requests pertaining to Your Personal Information, we will first need to authenticate Your identity and thereafter we will try to comply with Your request as soon as and to the extent reasonably practicable. If You wish for us to delete any or all of Your Personal Information: (a) if You have an account with us, You must close Your account with us by contacting us at our contact information at the end of this Privacy Policy; and (b) if You do not have an account with us, contact us at our contact information at the end of this Privacy Policy with Your request.

We will respond to Your request within a reasonable timeframe. Please note that we cannot remove Your Personal Information from the database of third parties that previously received such information.

Retention Period

We will retain Your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy as well as may be necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, all in accordance with applicable law.

Links to Other Websites or Internet Properties

The Websites may include links to other websites or other internet properties whose privacy practices may differ from this Privacy Policy. If You submit Personal Information to any of those websites, Your Personal Information is governed by their privacy policies. We encourage You to carefully read the privacy policy of any website You visit.

Testimonials

We display personal testimonials of customers on the Websites in addition to other endorsements. With Your consent, we may post Your testimonial along with Your name. If You wish to update or delete Your testimonial, You can contact us at info@savvymoney.com.

Social Media Features and Widgets

The Websites may include social media features, such as the Facebook Share button and widgets, such as the “share this” button or interactive mini-programs that run on the Websites. These features may collect Your IP address and which page You are visiting on the Websites 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 the Websites. Your interactions with these features are governed by the privacy policy of the party providing such features.

Children’s Privacy

Protecting the privacy of children is especially important to us. The Websites and the Programs are not directed to individuals under the age of 13, and we do not knowingly collect Personal Information from anyone under the age of 13. If You are under the age of 13, do not use the Websites or the Programs or provide any Personal Information to us. If we become aware that we have collected Personal Information from anyone under the age of 13, we will delete that information. If You believe we might have any information from or about a child under the age of 13, please contact us at privacy@savvymoney.com.

Jurisdictional Issues

We do not represent or warrant that any of the Websites or the Programs, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access any of the Websites and the Programs do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.

Contact Information

If You have any questions or comments about this Privacy Policy or our privacy practices, You can contact us as follows:

By email at: privacy@savvymoney.com

By mail at:

SavvyMoney, Inc.
Attn: Privacy
4160 Dublin Blvd, Suite 250
Dublin, CA 94568
Tel: 1-844-513-5777

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

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