MoneyWellth Privacy Notice
Last Updated February 24, 2022
This is the Privacy Notice for the MoneyWellth App powered by Moneywellth, LLC (“MoneyWellth”, “us”, or “we”). The MoneyWellth App (or the “App”) is designed to help you do things like make a budget, manage spending, and save for retirement and other life events. This Privacy Notice explains how MoneyWellth treats the information we collect when you use our Services, which includes the MoneyWellth App (or “App”), MoneyWellth.com, our other websites and online channels (collectively, the “Site”), and your interactions with MoneyWellth in any manner.
Our Privacy Promise
MoneyWellth knows that maintaining your privacy is key to helping you improve your financial wellbeing. 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:
- · You can always login to control the information 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 Information.
- · We only work with service providers and affiliates that meet or exceed our own privacy standards.
- · MoneyWellth welcomes your requests to exercise your privacy rights.
If you have questions about our privacy practices or would like to make a complaint, please contact us at email@example.com.
- 1. CONSENT
- 2. PERSONAL INFORMATION
As used in this Privacy Notice, “Personal Information” 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, such as:
- ● Identifiers (e.g., name, email address, username, phone number, IP address)
- ● Protected Information (e.g., race, citizenship, marital status, sex)
- ● Biometric information (e.g., health data, gait or physical movements, face/voice prints) and audio, electronic, visual, thermal, olfactory, or similar information;
- ● Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- ● Employment-related information (e.g., current or past employment);
- ● Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
- ● Sensitive Personal Information (e.g., social security or government identification number; precise geolocation; racial or ethnic origin; religious beliefs; biometrics; health information; information related to sex life or sexual orientation; union membership; contents of mail, email or text messages when we are not the recipient);
- ● Internet activity (e.g., interactions with a website, content, or advertisement); or
- ● Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Personal Information does not include (a) publicly available information; (b) aggregated information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (c) deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer.
- 3. COLLECTION AND USE OF PERSONAL INFORMATION
Moneywellth collects your Personal Information (a) with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We only collect, use, retain, and disclose Personal Information as reasonably necessary and proportionate to achieve our purposes, or for other purposes that we disclose to you and are compatible with the context of how we collected the Personal Information.
In the preceding 12 months, Moneywellth has collected Personal Information in the categories of identifiers, protected information, financial information, commercial history, and your internet activity, and inferences drawn from the Personal Information you choose to submit via the App. We collect this information from sources and for purposes described below:
- a. Your App Account, 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, save 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.
- b. 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.
- c. Third Party Financial Aggregator Services, with your consent. You have the option to connect your financial accounts with the MoneyWellth 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.
- d. 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 withaccess 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.
- e. 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 Information 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.
In addition to the specific uses described above, we reserve the right to use your Personal Information 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 Notice 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 Information or use your Personal Information for purposes that are incompatible with the purpose stated at the time of collection without first notifying you by updating this Privacy Notice or through other means.
- 4. RETENTION OF PERSONAL INFORMATION
All Personal Information collected by Moneywellth is retained for a period of three months. Data collected via cookies and similar technologies, including data containing Personal Information, 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 Information 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.
- 5. CHILDREN’S PRIVACY
Moneywellth is designed for adults, not children. We do not knowingly collect Personal Information from children under 18. If we discover that a child has provided us with Personal Information, we will delete their information from our systems. Pease contact us at firstname.lastname@example.org if you believe we might have collected a child’s information online.
- 6. DISCLOSURE OF PERSONAL INFORMATION
In the preceding 12 months, Moneywellth has disclosed Personal Information 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. Our service providers may require access to certain Personal Information to perform their contractual obligations to MoneyWellth. Our service providers are contractually required to protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. The type of information that we provide to a Service Provider will depend on the service that they provide to us.
- b. 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.
- c. Law Enforcement. We reserve the right to disclose your Personal Information to law enforcement or other government agencies as permitted or required by law.
- d. Other Third Parties. Moneywellth may disclose your Personal Information 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.
- e. 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 RIGHTS
- a. Controlling Your Personal information. MoneyWellth gives you the ability to directly control the Personal Information we collect and hold about you through our Services:
- i. Your Account. You have the option to access, correct or update, or delete the Personal Information in your account profile by logging into your account and saving your desired changes.
- ii. Emails. We may send you informational or support emails related to your MoneyWellth account. 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 email@example.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.
- iii. Device Settings. You can control the data collected via cookies and related technologies by adjusting your device settings.
- iv. Texting. If you provide us with your wireless phone number, you consent to MoneyWellth sending you text messages for authentication purposes. The number of text messages you receive will depend on the Services you use and the information you request. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any text message, 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.
- v. 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).
- vi. 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.
- vii. 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.
- viii. Privacy Requests. If you wish to exercise your privacy rights beyond the methods available through the Services, or if you want to express concerns, lodge a complaint, or request information, please contact MoneyWellth at firstname.lastname@example.org.
- a. Controlling Your Personal information. MoneyWellth gives you the ability to directly control the Personal Information we collect and hold about you through our Services:
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 Information, 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.
Depending on where you reside, you may be entitled to additional controls over your Personal Information. Please contact email@example.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.
- b. California and Certain Other U.S. States. This section provides the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”) and offers informational notices to residents of Virginia, Colorado, Nevada, and other U.S. states with laws providing similar protections. MONEYWELLTH IS CURRENTLY EXEMPT FROM THE CCPA AND CERTAIN OTHER US PRIVACY LAWS. This section is offered as a courtesy to describe the rights afforded to residents of the State of California and other states to the extent the same legal protections apply (each a “Consumer”). Consumers may exercise the rights below to the extent provided by the laws that apply to the Consumer and to MoneyWellth, subject to our receipt of a verifiable Consumer Privacy Request and any exceptions and limitations that may apply:
- i. Right to Disclosure. You have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months, such as (a) the categories of Personal Information we have collected about you; (b) the categories of sources for the Personal Information we have collected about you; (c) our business purpose for collecting or selling that Personal Information; (d) the categories of third parties with whom we share that Personal Information; and (e) if we sold or disclosed your Personal Information for a business purpose, two separate lists stating (1) sales, identifying the Personal Information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Depending on the laws that apply to you, MoneyWellth may only be required to respond to a certain number of disclosure requests within a 12-month period.
- ii. Right to Correct. You have the right to request that we correct inaccurate Personal Information about you in our systems. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., you change address), please inform us and we will update our records.
- iii. Right to Access. You have the right to request a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf (also called a data portability request). We provide copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that some laws prohibit MoneyWellth from disclosing copies of certain pieces of Personal Information (e.g., government ID numbers, financial account information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. If you are a resident of the State of California, your request is limited to specific pieces of Personal Information we have collected about you over the past 12 months, and we are only required to respond to two such requests within a 12-month period.
- iv. Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. MoneyWellth may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
- v. Limited Use and Disclosure of Sensitive Personal Information. MoneyWellth does not seek to collect sensitive Personal Information about any individual, but we may collect some data that qualifies as sensitive Personal Information related to your financial accounts. MoneyWellth only uses this sensitive Personal Information to provide the Services you request, and in no case do we disclose any sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of your sensitive Personal Information.
- vi. No Sale or Sharing of Personal Information. MoneyWellth does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out.
- vii. Right to Opt-Out of Automated Processing. MoneyWellth does not use automated processing of Personal Information or “profiling” to provide the Services. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out.
- viii. Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not (a) deny you goods or services, (b) charge you different prices or rates for goods or services, (c) provide you a different level or quality of goods or services, (d) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (e) 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 the CCPA.
- ix. 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 Information sharing with affiliates and/or third parties for marketing purposes.
Consumers may exercise these rights over their Personal Information, subject to our receipt of a verifiable privacy request, as well as any exceptions and limitations that may apply.
- c. Canada. This section provides supplemental information in compliance with Canada’s Personal Information 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 Information 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 Information we process. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, 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 Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Notice and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Information 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 firstname.lastname@example.org.
- iii. Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information 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 Information in your account, and we will provide you with reasonable assistance to ensure that your Personal Information is accurate in our systems and with our service providers.
- iv. Right to access your Personal Information. Upon written request and identity authentication, we will provide you with your Personal Information 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 Information 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 Information, subject to our receipt of a verifiable privacy request, as well as any exceptions and limitations that may apply.
- d. European Economic Area and United Kingdom. MoneyWellth offers this section to comply with the General Data Protection Regulation (“GDPR”) and its counterpart regulation applicable to residents of the United Kingdom. This section applies solely to residents of the European Economic Area and the United Kingdom (“Data Subjects”). MoneyWellth collects and processes Personal Information of Data Subjects who are App users as a controller. If you are a Data Subject, you have the following rights related to the Personal Information we hold about you:
- i. Right to know how we process your Personal Information. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.
- ii. Right to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example, to protect the rights of other individuals.
- iii. Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if: (a) the data is inaccurate; (b) the processing is unlawful; (c) we no longer need the Personal Information; or (d) you exercise your right to object.
- iv. Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
- v. Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request in a structured and commonly used machine-readable format, so that the other organization can read and use it.
- vi. Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete or anonymize your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
- vii. Right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.
- viii. Right to not be subject to Automated Decision-Making (“ADM”). MoneyWellth does not use ADM to provide the Services. If this changes in the future, we will update this posting to describe our use of ADM and your options to exercise your privacy rights related to your Personal Information processed using ADM.
Data Subjects may exercise these rights over their Personal Information, subject to our receipt of a verifiable privacy request, as well as any exceptions and limitations that may apply. If you are a resident of the EEA and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. If you are a resident in Switzerland, you have the right to complain to the Swiss data protection authorities.
- 8. CONSENT TO CROSS-BORDER DATA TRANSFER
The United States, European Economic Area (“EEA”) Member States, and other countries all have different privacy laws. When your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. If your information is in the United States, it may be accessed by government authorities in accordance with US law. MoneyWellth does not warrant that our Services are appropriate or authorized for use in any other jurisdictions. You are solely responsible for determining whether your use of our Services complies with applicable laws.
MoneyWellth employs legally valid transfer mechanisms for all cross-border transfers of Personal Information. To the extent that MoneyWellth is deemed to transfer Personal Information from the EEA to outside of the EEA, we do so on the legal basis that such transfer is necessary to provide you with the Services you have chosen to use.
By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this section.
- 9. DATA SECURITY
MoneyWellth implements reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. 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.
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 Information for improper purposes. The security of your Personal Information also depends on how you use the Services. We encourage you to take steps to safeguard your Personal Information 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.
- 10. THIRD-PARTY WEBSITES
This Privacy Notice 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.
- 11. CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time. If we make material changes to how we treat your Personal Information, we will post the revised Privacy Notice on this page. The date that this Privacy Notice 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 Notice to check for any changes.