MoneyWellth Privacy POLICY

Last Updated May 3, 2024

This is the Privacy Policy for the MoneyWellth App (or the “App”) powered by MoneyWellth, LLC (“MoneyWellth”, “us”, or “we”). This Privacy Policy explains how MoneyWellth treats the information we collect when you use our Services, which includes mobile and web versions of the App, MoneyWellth.com and our other websites and online channels (collectively, the “Site”), and your interactions with MoneyWellth in any manner.

By using our Services in any manner, you consent to this Privacy Policy and our privacy practices. Your use of our Services is subject to this Privacy Policy and our Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. If you do not agree with this Privacy Policy, do not access or use the Services.

 

Our Privacy Promise

The App is designed to help you do things like make a budget, manage spending, and save for retirement and other life events. MoneyWellth knows that maintaining your privacy is key to helping you improve your financial well-being. We want you to have a very clear understanding of how we collect, protect, and use your information. Here is a summary of our privacy promise to you:

·         The App is private by default. MoneyWellth will never share the Personal Data you input to the App with the Sponsor through which you access our Services.

·         You can always log in to control the data associated with your account.

·         You decide how we communicate. MoneyWellth will only send you marketing messages if you agree to it and only as often as you want to hear from us.

·         MoneyWellth will never sell your Personal Data.

·         Any reporting we do on trends or content consumption is done in the aggregate. Your user data is 100% anonymous in these reports.

·         If your Sponsor also provides you with access to Lenux Health, your Personal Data may be shared between MoneyWellth and Lenux Health.

·         We only work with service providers and affiliates that meet or exceed our own privacy standards.

·         The Services are designed for users located in the United States and Canada.

·         MoneyWellth welcomes your requests to exercise your privacy rights.

Please note: MoneyWellth is not a financial institution, and the Services are not subject to the Gramm-Leach-Bliley Act, which is a federal law that applies to Personal Data processed in connection with providing personal or household financial services. All financial matters are handled by your bank or other financial institution and all payments related to the Services are processed through a third-party PCI-DSS payment processor.

You are encouraged to read this Privacy Policy carefully to fully understand our privacy practices. This Privacy Policy is part of and governed by our Terms of Use. Any terms used in this Privacy Policy without being defined have the meaning given in the Terms of Use. If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@moneywellth.com.   

 

1. YOUR PERSONAL DATA

As used in this Privacy Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:

·         Identifiers (e.g., name, email, telephone number, address, username);

·         Commercial information (e.g., products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies);

·         Educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);

·         Employment information (e.g., current or past employment);

·         Sensitive information (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);

·         Legally protected information (e.g., race, citizenship, marital status, sex);

·         Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;

·         Internet activity (e.g., browsing history; content interactions); and

·         Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behaviors, attitudes, intelligence, and aptitudes.

Not all information about a person qualifies as Personal Data under privacy laws. For example, publicly available information, aggregated data, and anonymized information are often exempt from legal rights and protections.    

2. NO CHILDREN’S PERSONAL DATA

The Services are designed for adults, not children. We do not knowingly collect Personal Data from children under 18. If we discover that a child has provided us with Personal Data, we will delete their information from our systems. Pease contact us at privacy@moneywellth.com if you believe we might have collected a child’s information online.

3. COLLECTION AND USE OF PERSONAL DATA

MoneyWellth will only collect and use your Personal Data with your consent as informed by this Privacy Policy and freely given by you, if we have a legitimate interest in the collection, or as authorized or required by law. We only collect, use, retain, and disclose Personal Data as is adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to provide the Services. We may also process Personal Data for other purposes that we disclose to you or as compatible with the context of how we collected your Personal Data.

In the preceding 12 months, MoneyWellth has collected Personal Data in the categories of identifiers, protected information, financial information, health data, commercial history, and your internet activity, and inferences drawn from the Personal Data you choose to submit via the App. We collect this information from sources and for purposes described below:

a.    Your App account and activities, with your consent. When you create your account on the App, we will collect a username and password as your login credentials along with identifiers like your name, email address, phone number, and postal code to make up your App profile. MoneyWellth also collects the name of the employer or other organization through which you gain access to the App (your “Sponsor”), if applicable. MoneyWellth uses your email to verify your identity at login and to communicate with you about our Services.

Within the App, you have the option to answer survey questions that may collect financial information, health data, or other Personal Data. You can also input details about your life events or financial goals and save content for future reference. This information is collected with your consent and is used to provide you with access to the App and to offer you a tailored user experience.

Certain App features may be powered by artificial intelligence technology (“AI Features”). If you interact with MoneyWellth’s AI features, we will collect any Personal Data that you choose to include in a prompt or other input (“Inputs”) to the AI Feature. MoneyWellth will only use your Inputs to generate the requested content outputs and to provide and improve the AI Feature and our other Services. By interacting with an AI Feature, you consent to this collection of your information for these purposes.

b.    Your chats with MoneyWellth, with your consent. If you participate in a chat on the App or the Site, we collect and record any information, including Personal Data, that you choose to include in your chats with us. Please note that our chat feature is made possible through our relationship with a third-party service provider, and your chats may be accessible simultaneously and in real time by that third-party service provider. By initiating or continuing a chat on the Services, you consent to our third-party service provider accessing your chats. If you do not consent to such access to your chats, you should not initiate or participate in a chat on the App or the Site.

c.    Your Sponsor, with a legitimate interest. If you use the App as part of a benefits package provided by your Sponsor, MoneyWellth may receive your email address and other identifiers from your Sponsor. We collect this information to achieve our legitimate interest of meeting our contractual obligations to your Sponsor and we use it to initiate your account and provide you with access to the App and our other Services.  

d.    Third Party Financial Aggregator Services, with your consent. You have the option to connect your financial accounts with the App via Plaid, a third-party financial aggregator service. Once connected, MoneyWellth will have access to your transaction history, account balance, and other data within your financial account. We receive this data under Plaid’s privacy practices, and we use it to help you track your spending, savings, and investments against your financial wellness goals within the App. MoneyWellth will never disclose your financial account information with third parties unless you tell us to.

e.    Your interactions with MoneyWellth content, with a legitimate interest. MoneyWellth’s mission is to expand access to financial education and resources so that every individual can live a life free of financial worry. A key part of achieving this mission is providing users with access to rich financial wellness content through the App and our other Services. MoneyWellth may collect usage information from your interactions with our content, such as the pages you viewed, Services features you use, and details about any links with which you interact. We collect this information to achieve our legitimate interest of providing and improving our Services.

f.     Your communications with MoneyWellth, with your consent. If you interact with MoneyWellth via social media or contact us in any way, we will collect identifiers like your name and email address, along with any other Personal Data that you choose to include in your communication to us. We use this information to respond to your inquiries and to send you marketing messages according to your stated communication preferences.

g.    Your use of the App or the Site, with a legitimate interest. MoneyWellth may automatically collect technical data about your device or use of the Services, such as your IP address, log information, generalized geolocation when using the App, error messages, and unique device identifiers. Like most commercial digital services, MoneyWellth uses cookies and related technologies as described in our Cookie Policy. We collect this information to achieve our legitimate interest of providing and improving our Services.

In addition to the specific uses described above, we reserve the right to use your Personal Data to (i) protect your privacy and the privacy of others; (ii) comply with a law, regulation, legal process, or order; (iii) monitor your compliance with this Privacy Policy and your agreements with us; (iv) if we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to MoneyWellth, or to others; or (v) for any other purpose with your consent. MoneyWellth will not collect additional categories of Personal Data or use your Personal Data for purposes that are incompatible with the purpose stated at the time of collection without first notifying you by updating this Privacy Policy or through other means.

4. SPONSOR PRIVACY PRACTICES

MoneyWellth will never disclose your Personal Data to a Sponsor that provides you with our Services as an employee or member benefit.  However, your Sponsor may collect and process Personal Data about you through other means. MoneyWellth has no control over the type or scope of Personal Data collected, used or stored by Sponsors. Personal Data processed by Sponsors belongs to the Sponsor and is collected, processed, stored, shared, and disclosed by each Sponsor according to its own terms of use and privacy policies. Personal Data processed by Sponsors is not subject to this Privacy Policy, and MoneyWell this is in no way responsible for such information.

5. RETENTION OF PERSONAL DATA

All Personal Data collected by MoneyWellth is retained for a period of three months. Data collected via cookies and similar technologies, including data containing Personal Data, is also retained for up to three months. All data is only retained as long as it is necessary and relevant to our operations, after which the data is de-identified or securely deleted. MoneyWellth reserves the right to retain Personal Data for longer periods if necessary to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms and conditions, or take other actions permitted by law.

6. DISCLOSURE OF PERSONAL DATA

MoneyWellth never shares your financial or health information with your Sponsor. In order to provide the App and other Services, we sometimes need to disclose certain Personal Data to trusted third parties as described in this section. In the preceding 12 months, MoneyWellth has disclosed Personal Data in the categories of identifiers, protected information, financial information, commercial history, and your internet activity with third parties for a business purpose, including:

a.    Our Service Providers. MoneyWellth uses service providers like data analytics companies, payment processors, and email and data hosting providers. For example, we rely on Braze to support our user communications and engagement efforts. We may disclose your Personal Data with Braze subject to the Braze Privacy Policy. Our service providers may require access to certain Personal Data to perform their contractual obligations to MoneyWellth. Our service providers are contractually required to protect your Personal Data, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Data. The type of information that we provide to a Service Provider will depend on the service that they provide to us.

b.    Lenux Health. If your Sponsor contracts to provide you with access to Lenux Health as part of your Sponsored Services, you may access and use the Lenux Health Site, and your Personal Data may be shared between MoneyWellth and Lenux Health to facilitate your use of both services.

c.    Advertisers. MoneyWellth may disclose your email address and other identifiers to service providers we use to support our marketing efforts (“Advertisers”). Our Advertisers will only use your email address to send you marketing emails on the schedule you select in your App profile.

d.    Law Enforcement. We reserve the right to disclose your Personal Data to law enforcement or other government agencies as permitted or required by law.

e.    Other Third Parties. MoneyWellth may disclose your Personal Data to other third parties in certain circumstances as permitted by applicable law, for example: (i) if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); (ii) to comply with a legal requirement or a court order; (iii) when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; (iv) to exercise or defend our legal claims; or (v) for any other reason with your consent.

f.     Aggregated and Deidentified Information. MoneyWellth reserves the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.

7. YOUR PRIVACY CONTROLS

MoneyWellth gives you the ability to directly control the Personal Data we collect and hold about you through the methods described below. If you need assistance, please visit the Help Center or contact support@moneywellth.com.

a.    Your Account. You have the option to access, correct or update, or delete the Personal Data in your account profile by logging into your account and saving your desired changes.

b.    Text/SMS Messages. If you opt-in to text/SMS notifications, MoneyWellth may use your Personal Data to send you text/SMS messages containing information about the App or other matters related to the Services through Brevo. You may cancel text/SMS messages at any time by replying STOP or UNSUBSCRIBE to any of these text messages, but doing so may limit or eliminate your access to your App account. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.

c.    In-App Notifications. If you opt-in to receive in-App notifications, MoneyWellth may use the Personal Data collected through the App to send you notification related to your use of the App or other matters related to the Services through Brevo. You can opt-out of in-App notifications by changing your account settings.

d.    Emails. We may send you informational or support emails related to your use of the Services. Some emails may be generated through our use of Brevo services. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails or send a request to support@moneywellth.com. Note that if you opt out of marketing communications, we may still send you non-promotional communications related to your use of the Services.

e.    Device Settings. You can control the data collected via cookies and related technologies by adjusting your device settings.

f.     Opt-Out of Interest-Based Ads. You may limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt-Out of Interest-Based Ads” (for Android devices).

g.    Block Location Tracking. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

h.    Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.

i.      Privacy Requests. If you wish to exercise your privacy rights beyond the methods available through the Services, or if you want to express concerns, complain, or request information, please contact MoneyWellth at privacy@moneywellth.com. MoneyWellth may only legally fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

8. YOUR PRIVACY RIGHTS

Depending on where you reside, you may be entitled to additional controls over your Personal Data. Please contact privacy@moneywellth.com if you have questions about exercising your privacy rights. Residents of jurisdictions requiring specific notices of privacy rights may review the applicable supplemental notices below.

a.    United States Privacy Rights. In the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing general consumer privacy rights. For example, California, Colorado, Connecticut, Iowa, Nevada, Utah, Virginia, and other states require companies to inform consumers about their privacy rights and provide a method to exercise those rights. MoneyWellth will respond to and fulfill your request to the extent required by applicable law. MONEYWELLTH IS CURRENTLY EXEMPT FROM CERTAIN STATE PRIVACY LAWS. Depending on where you live, you may be entitled to some or all of the following privacy rights.

                                      i.        Right to Know. You have the right to know how we treat your Personal Data. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

                                     ii.        Right to Access. You have the right to request confirmation that we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and readily usable format. Please note that MoneyWellth may be prohibited by law from disclosing certain pieces of Personal Data, and we may be limited in the number or frequency of requests we must fulfill. 

                                    iii.        Right to Correct. You have the right to request that we correct inaccurate Personal Data about you on our systems. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.

                                   iv.        Right to Deletion. Upon your request and where we are required to do so by law, we will delete your Personal Data that we collected and retained, with certain exceptions. We may permanently delete, deidentify, or aggregate the Personal Data in response to a request for deletion.

                                     v.        Right to Disclosure. You may have the right to request that we disclose information to you about our collection and use of your Personal Data, such as: (i) the categories of Personal Data we have collected about you; (ii) the categories of sources for the Personal Data we have collected about you; (iii) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (iv) the categories of third parties with whom we share that Personal Data; and (v) if we sold or shared your Personal Data under the CCPA, two separate lists stating: (A) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (B) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.  

                                   vi.        Limited Use and Disclosure of Sensitive Personal Data. You may have the right to opt out or limit our use of your sensitive Personal Data. MoneyWellth does not seek to collect sensitive Personal Data about any individual, and in no case do we disclose any sensitive Personal Data for inferring characteristics about you or otherwise use your sensitive Personal Data without your consent. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to opt-out or limit our use and disclosure of sensitive Personal Data.

                                  vii.        No Selling or Sharing. Some states entitle consumers to opt-out of the sale or sharing of Personal Data or targeted advertising practices. MoneyWellth does not sell your Personal Data or share your Personal Data with third parties for cross-contextual advertising purposes. If this ever changes in the future, we will update this Policy and provide you with methods to opt-out of such sale and sharing.

                                 viii.        No Profiling. You may have the right to opt-out of automated profiling. MoneyWellth does not process your Personal Data to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.

                                   ix.        Health Data Rights. Some state laws entitle consumers to certain details about health data collected about them, including confirmation of whether the entity collects, shares, or sells the consumer’s health data and access that data (including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties), a method to withdraw consent related to use of health data, and the right to have their health data be deleted. Please contact privacy@moneywellth.com if you wish to request details about your health data on our Services.

                                     x.        Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.

                                   xi.        Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.

To exercise your rights under applicable privacy laws, please submit a privacy request to privacy@moneywellth.com. Only you or someone legally authorized to act on your behalf may make a verifiable Privacy Request related to your Personal Data. You may also make a verifiable privacy request on behalf of your minor child. You may designate a third party to exercise your rights – an authorized agent – however we will require written proof of the authorization and potentially proof of your identity.

b.    Canada. This section provides supplemental information in compliance with Canada’s Personal Data Protection and Electronic Documents Act (“PIPEDA”). This section applies solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Data offering details on an identifiable person without the inclusion of name, title, telephone number, and business address of an employee of a business or organization. The following paragraphs describe PIPEDA rights and explain how to exercise those rights.

                                      i.        Right to know why we collect, use, and distribute the Personal Data we process. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

                                     ii.        Right to expect us to collect, use, or disclose Personal Data responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Policy and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Data based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting us at privacy@moneywellth.com.

                                    iii.        Right to accuracy of your Personal Data. We take steps to reasonably ensure that your Personal Data we are using is accurate. In most cases, we rely on you to ensure that your information is current, complete, and accurate. We provide methods for you to correct, update, and delete inaccurate Personal Data in your account, and we will provide you with reasonable assistance to ensure that your Personal Data is accurate in our systems and with our service providers.

                                   iv.        Right to access your Personal Data. Upon written request and identity authentication, we will provide you with your Personal Data under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Data you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps that are available to you.

Canadian Consumers may exercise these rights over their Personal Data, subject to our receipt of a verifiable privacy request, as well as any exceptions and limitations that may apply.

9. DATA TRANSFER

MoneyWellth is owned and operated in the United States and is intended for use by users living in the United States or Canada. We do not warrant that the Services are appropriate or authorized for use in any other jurisdictions. If you use the Services from outside of the United States or Canada, Personal Data we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Data out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement, or regulatory agencies having access to or obtaining disclosure of your Personal Data pursuant to the laws of the applicable foreign jurisdiction. You are responsible for determining whether this Privacy Policy and the Services comply with the laws that apply to you. By allowing us to collect Personal Data about you, you consent to the transfer and processing of your Personal Data as described in this paragraph.

10. DATA SECURITY

MoneyWellth works to protect your Personal Data by using reasonable and appropriate technical, administrative, and physical security practices and procedures to help protect Personal Data from unauthorized or illegal access, destruction, use, modification, or disclosure. We have implemented and maintain internal policies to govern the collection, processing, access, and handling of data. Our security measures are appropriate to the volume, scope, and nature of the Personal Data processed and designed to meet our duty of care with respect to your Personal Data.

MoneyWellth encrypts user data using industry-standard Transport Layer Security (TLS) technology and stores all data on secure cloud servers. We also perform regular scans of all systems to detect and remedy vulnerabilities on MoneyWellth information systems. MoneyWellth personnel responsible for handling user inquiries are informed of applicable privacy law requirements.

Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Data for improper purposes. The security of your Personal Data also depends on how you use the Services. MoneyWellth encourages you to take steps to safeguard your Personal Data by signing off your device after use and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.

11. THIRD-PARTY WEBSITES

This Privacy Policy applies only to information collected by MoneyWellth when you use the App or our other Services. The Services may include links to third-party websites or platforms for your convenience, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third parties. MoneyWellth is not responsible for the privacy practices of any third party, and your access to and use of third-party websites is governed by the privacy notices of those websites.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes to how we treat your Personal Data, we will post the revised Privacy Policy on this page. The date that this Privacy Policy was last revised is identified at the top of the page. Your continued use of the Services after we make changes is deemed to be your acceptance of those changes. You are responsible for periodically visiting this Privacy Policy to check for any changes.