September 4, 2024

The Lampo Group, LLC d/b/a SmartDollar (“SmartDollar,” “we,” “our,” or “us”), is committed to protecting your privacy, and in doing so, we want to make sure that this Privacy Policy (“Policy”) is clear and concise enough for you to understand it. This Policy discloses our privacy practices and how we may use the information that we gather on our digital properties, including but not limited to our website, online platform, services, products, and the SmartDollar program (collectively, the “Site and Program”).

This Policy applies to information collected by our Site and Program and contains the following:

1. A list of the categories of personally identifiable information we may collect from you through our Site and Program;
2. How the information may be used and with whom it may be shared;
3. What choices are available to you regarding our use of your data;
4. The security measures in place to protect the misuse of your information;
5. How you can correct any inaccuracies in the information collected; and
6. Privacy rights for state specific residents.

Each time you visit and use our Site and Program, certain information may be collected. In some instances, the collected information may allow us to match activities with users. We may also collect your information from other sources, as described below. Examples of the type of information that may be automatically collected are as follows:

• Your internet service provider's address, your internet protocol or IP address, device ID, the web page from which you accessed our Site and Program, your web browser software, the type of handheld or mobile device used to link to the web page, and the language settings on your web browser;
• Records of Site and Program features or services utilized, such as SmartTax, Mama Bear online legal forms, and One-on-One Financial Coaching;
• Data about the webpages you visit, including without limitation web browser specifications, websites visited before accessing our Site and Program, and websites visited after leaving our Site and Program;
• A record of your activity and interactions while visiting or using our Site and Program, including the existence or types of data you may upload or the terms you search;
• Data about your device and nearby networks, including internet connection information, computer equipment information, regional and language settings;
• Data about the performance of our website or mobile apps;
• “Cookies” or other common tracking methods of different types to recognize your computer (please see the Cookies section below for description of what Cookies are and how they are used); and
• Web beacons, match scripts, pixel tags, or similar technologies that allow us to know information such as whether a particular web page was visited, an e-mail opened, links in the email accessed, or other information that may help us improve your experience.

We use this information to:

• Monitor the usage of our Site and Program and gathering analysis and assessing trends and interests;
• Provide, maintain, personalize, and improve our Site and Program; and
• Detect, prevent, and address technical issues.

We may also collect any personal information that you provide/input on our Site and Program. This may include:

• your name, e-mail address, mailing address, phone number,
• your current Baby Step and your Debt Snowball and other SmartDollar program (“Program”) progress details to share with your coach if you choose to utilize the One-on-One Financial Coach feature of the Program, and
• Any other information you provide to us through our Site and Program.

We may use the information you provide to us for any of the following purposes:

• Administer our Site and Program and systems;
• Create, maintain, and personalize your account with us;
• Provide, maintain, personalize, and improve our Site and Program;
• Detect, prevent, and address technical issues and provide customer support;
• Monitor and maintain the safety, security, and integrity of our Site and Program and technological assets;
• Better understand and serve your needs;
• Respond to you regarding the reason you contacted us;
• Enhance your customer experience and improve our customer service;
• Customize offerings to you that relate to the services you have used or requested or which otherwise relate to your behaviors we have observed on the Site and Program or on the websites you visit before accessing our Site and Program or the websites you visit after leaving our Site and Program;
• Notify you about changes to our Site and Program;
• Monitor the usage of our Site and Program, gather analysis, and assess trends and interests;
• Allow you to participate in interactive features and forums, if any, on our Site and Program; or
• Communicate newsletters, marketing or promotional materials, or other information to you about the Program, services, enhancements, features, and SmartDollar-related sweepstakes.

We may also use this information to evaluate and manage our business. Combined data is collected from online and offline facilities and may be used for our own lawful research, benchmarking, analysis, and statistical purposes, or to enhance the ability of SmartDollar to communicate with you and to support business functions, such as internal business processes, marketing, authentication, customer service, fraud prevention, and public safety and legal functions.

We will make every effort to keep you informed of SmartDollar’s special events, news and offers, so periodically, we may send these announcements via email or direct mail. If you do not wish to be contacted by SmartDollar or our business affiliates, simply click on the unsubscribe link found at the bottom of the email or newsletter.

Your information will not be accessible to or shared with anyone other than our employees, our third-party partners or service providers, and our contractors which we have vetted from a privacy and security perspective and who have a valid business need to properly fulfill their duties in supporting, managing, and maintaining the Site and Program, including the underlying technology of the same.

Because the Program is designed to promote your personal financial wellness and encourage participation in your retirement plan, your employer or plan sponsor may require that we share certain data elements from the list of said elements set forth below (“Data Elements”) or usage metrics directly with them, their wellness vendor(s), third parties promoting the Program to them, or non-wellness third parties they utilize to support their general business operations. However, we will not share your personally identifiable financial information with your employer or plan sponsor, either directly or indirectly. Any information and Data Elements shared with your employer, plan sponsor, or above-referenced third parties will be in de-identified format or aggregated with other data to such an extent that it does not uniquely identify you.There may be times when we need to share, or otherwise disclose, your personal information with third-party service providers. These third-party service providers are only granted access to your personal information for the purpose set forth below, and they are contractually restricted in the ways they may use your information. The providers may also use Cookies (as defined within this Policy) or other automatic collection technology on our behalf.

The reasons we may need to share this information with those providers relate to the services they provide to us or that we may provide to them, which may include:

• Enabling us to deliver, make available, maintain, and support the Site and Program, including support and ongoing improvement of customer service.
• Managing and processing your personal information;
• Developing, hosting, or maintaining our Site and Program;
• Analyzing customer information and/or improving customer service. 
• Other services that you expressly request which require us to share your personal information.
• Aggregating user information, which we may then share with prospective marketing partners in a non-identifiable, aggregated format for the purposes of generalized product marketing/non-personalized advertising. We do not sell or share your personally identifiable information with third parties for targeted marketing purposes. In the event we decide to do so in the future, we will obtain your affirmative consent, establish opt-out procedures, and provide you with any required disclosures.
• Data warehousing, aggregation, and analysis in support of your employer or plan sponsor’s general business operations and wellness programs. In the event we share data with non-wellness third parties at your employer’s or plan sponsor’s request, the data we share will be limited to the following Data Elements:
  • SmartDollar Points Totals.
  • SmartDollar Points awarded for specific categories of activities within the Program, including use of Program enhancement features, e.g., SmartTax and Mama Bear online legal forms.
  • Employee ID Number, if provided by your employer.
  • Enrichment Data—data elements your employer provides to us to support the effective use of the Program and to provide enhanced aggregated reporting and segmentation. Some examples of this include, work location, business unit, union group, and job title. Such data will not include any granular financial information personally identifiable to you.

Also, if a division, or part or all of SmartDollar, is purchased, sold, or otherwise transferred to/by another company, or is in the process of a potential transaction with another company, customer information will likely be shared for evaluation purposes and included among the transferred business assets. Such acquiring company’s right to use your personal information shall be limited to the terms of this Policy unless additional notice is provided to you.

We may also be required to disclose specific information to comply with the law, a subpoena, or other litigation process. We may also disclose your information to protect the interests or safety of our visitors and customers, employees, or others, which includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

SmartDollar does not sell your personal information to third parties.

We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.

When deciding how long to keep your information, we consider the following:

• How long we have had a relationship with you or provided a service to you
• Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
• Whether we have taken any legal positions (e.g., in connection with any statutes of limitation)

Rather than deleting your data, we might de-identify it by removing identifying details.

Our Site and Program are intended for access and use within the United States only and comply with applicable United States privacy laws. Our Site and Program are not intended for, or directed to, citizens, domiciles, or residents outside of the United States, including those of the European Union. By accessing our Site and Program, you affirm that you are not a citizen, domicile, or resident of a country outside of the United States, including those of the European Union.

Do Not Track (“DNT”) is a privacy preference that you can set in some web browsers to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser. However, these features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a DNT feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Policy.

“Cookies" are defined as small pieces of information (data files) which are unique to your device or account and that are downloaded to and stored by your browser or other application on your computer's browser or other device’s browser or hard drive when you use our Site and Program. Cookies make it easier for you to use our Site and Program by saving your preferences so that we can use them to improve your next and subsequent visits to our Site and Program. Cookies help us learn which areas of our Site and Program are useful and which areas need improvement. Cookies may be either persistent or temporary (or session) Cookies. A persistent Cookie retains user preferences for a particular website, app, or service, allowing those preferences to be used in future use sessions, and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary Cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies are used to connect your computer or other device with information stored about your online activity, searches, preferences, and product purchases, both within the same website visit and from one visit to the next, on our Site and Program and/or other websites. Some examples of the information Cookies may store include your account preferences, user specific information on pages accessed, searched terms or addresses entered, and previous visits to the Site. You can choose whether to accept Cookies by changing the settings on your browser or device. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new Cookies, how to have the browser notify you when you receive new Cookies, or how to disable Cookies altogether. If you reject Cookies, you may not be able to participate in certain activities or receive a promotion customized for you. Our Site and Program do not control and do not guarantee the effectiveness of browser-based tools for managing Cookies. When we use Cookies or similar technologies, we may set the Cookies ourselves or ask third parties to do so.

SmartDollar is committed to keep your information private and secure. We use industry-standard security techniques on our Site and Program to help protect against the loss, misuse, or alteration of information collected from you at our Site and Program. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us. In this regard, we urge you to take every precaution to protect your personal data while you are on the Internet. At a minimum, we encourage you to make sure that you are using a secure browser as you surf the Internet.

Our Site and Program may contain links to third-party websites, including those of our business partners. If you click one of those links, you will be taken to websites we do not control. This Policy does not apply to the information practices of those third-party websites. You should read the privacy policies of third-party websites carefully. While we seek to link only to websites that share our high standards and respect for privacy and security, we are not responsible or liable for the content, privacy policies/practices, actions, or security of third-party websites or services.

Consumers Under Age 16
SmartDollar does not knowingly solicit or collect personally identifiable information online from children under the age of 16 without prior verifiable parental consent. If we learn that a child under the age of 16 has submitted personally identifiable information online without parental consent, we will take all reasonable measures to delete such information from our databases and not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law).

Consumers Under Age 18
Personal information that has been provided to SmartDollar through our Site by minors under the age of 18, can be deleted by sending an email requesting the deletion to privacy@smartdollar.com.

Please note that while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

If you become aware of any personally identifiable information we have collected from children or minors, please contact us at privacy@smartdollar.com or call 1 (888) 227-3223.

While our Site and Program are not intended for use by children, parents who upload personal information regarding their children do so at their own risk and subject to the terms of this Policy.

Several U.S. states provide their residents privacy rights, including the right to:

• Request the following information regarding our use of your personal information:
  • Categories of your personal information that we have collected;
  • Purposes for which we have collected or used such personal information;
  • Categories of sources for the personal information we have collected about you;
  • Categories of third parties to whom we have disclosed your personal information;
  • Categories of personal information disclosed about you for a business purpose; and
  • Categories of information that the business sells or discloses to third parties.
• Receive a copy of your personal information;
• Request for us to delete your personal information (subject to certain exceptions that may apply); and
• Opt-out of the sale of your personal information (subject to certain exceptions that may apply).

To make a request under the CCPA or other applicable U.S. data privacy laws, you or your authorized agent may send an email to the following email address: privacy@smartdollar.com. Please include " Privacy Rights Request" in the subject line of the email.  You also are welcome to call our Ramsey Concierge team at 1 (888) 227-3223 on Monday and Wednesday from 9:30 am to 5:00 pm CST and Tuesday, Thursday, and Friday from 8:00  am to 5:00 pm CST or through the mail or by personal delivery to the physical address listed at the end of this Privacy Policy.

You may designate an authorized agent to make a request to exercise your rights on your behalf. To do that, provide your authorized agent with written permission, signed by you, authorizing the authorized agent to submit the request on your behalf. Your authorized agent must submit that written permission along with the request. We may contact you to verify your identity — and the authorized agent’s authority — before a response to the request is sent.

If we decline to act on your request, we will inform you of our justification for declining to act and instructions for how you may appeal our decision. Appeals may be commenced by sending a letter to us via U.S. Mail, first class postage prepaid and with delivery confirmation, addressed as follows:

The Lampo Group, LLC 
d/b/a SmartDollar 
Attention: General Counsel
1011 Reams Fleming Blvd.
Franklin, Tennessee 37064

Your letter must include your email address, a copy of the dated correspondence from us declining to act on your request, and an explanation of why you believe our justification for declining to act is in error. 

Your exercise of these rights will have no adverse effect on the availability, price, or quality of our services.

This Policy may be revised in our sole discretion from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. When we revise the Policy, we will post the new Policy on this page and change the date located at the bottom of the Policy. We encourage you to return to this page periodically to check for any updates or changes. If we make any change to this Policy regarding use or disclosure of personal information, we will provide advance notice on our Site and Program. Small changes, or changes that do not significantly affect individual privacy interest, may be made at any time and without prior notice.