Last Updated: February 7, 2023
Collection and Use | Information Sharing | Tracking Technologies | Security | Additional Info | Contact Info
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 Website and/or the Program. If You enroll with us through the services, such as an online banking or other financial services, of an Integration Partner with which You have a preexisting relationship, we may receive Personal Information about You from both You and Your Integration Partner. If You inquire about or respond to credit offers made by an Integration 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 Integration Partner making such credit offers. “Integration Partner” includes any third party who makes available to You the services available on the Website and/or the Program or otherwise invites You access or use the Website and/or Program to view credit offers and/or information contained on Your credit report. Integration Partners include credit unions, banks, mortgage lenders, credit card issuers, other financial institutions, and other parties. Additionally, if You inquire about, apply for, or respond to credit offers You receive from an Integration Partner, we may receive certain Personal Information about You from both You and the Integration Partner making such credit 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).
Personal Information may include, but is not limited to, the following categories of information:
- Email address
- Postal address
- Telephone number
- Date of birth
- Social security number
- Information provided by You to authenticate Your identity
- Username and password to access the Website or the Program
- 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 Website and the Program; (b) from Integration Partners with which You have a preexisting relationship; (c) from Integration Partners making credit offers to You with which You may or may not have a preexisting relationship; (d) from Integration Partners who have invited You access or use the Website and/or Program to view credit 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 Website or the Program, 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 Website and the Program, 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 Website or the Program.
- Information relating to the device You use to access and use the Website and the Program (such as the browser type, location of device, device ID, operating system, mobile network information).
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 Website and the Program, and/or complete transactions You have requested.
- Retrieve Your credit report on an ongoing basis and monitor Your credit.
- Send You 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 credit offers made to You by an Integration Partner.
- Display content based on Your interests.
- Send You important information regarding the Website and/or the Program, 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 Website and the Program, identifying usage trends and determining the effectiveness of features, offers and promotional campaigns.
- 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 our 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 Website and Program, 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
We may share Your Personal Information with an Integration Partner, including when You apply for credit offers made by an Integration Partner through the Website or the Program, or when You request that an Integration Partner or other third party follow up with You about Your income, debt and spending, or to otherwise contact You regarding credit offers and other promotions for which You may be eligible. Also, if You inquire about, apply for, or respond to credit offers You receive from an Integration Partner, we may share Your Personal Information with such Integration Partner and its third party providers that allow You to apply for such credit offers. Additionally, we may share Your Personal Information with Integration Partners who have invited You access or use the Website and/or Program to view credit offers and/or information contained on Your credit report. Lastly, if You seek customer service assistance from an Integration Partner for Your account with us, such Integration Partner may be provided with access to Your account, including all information contained in Your account. The Personal Information that we may share with an Integration Partner include: (a) Your contact information (which includes Your name, email address and postal address); (b) whether You appear to qualify for credit offers made available by such Integration 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 Website and/or the Program, including the content You access.
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 Website and the Program, 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 Website of any change in ownership or uses 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.
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 Website and the Program are used. Among other things, these technologies are used in analyzing trends, administering the Website, tracking users' movements around the Website 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 Website.
To opt out of Google Analytics, please see https://tools.google.com/dlpage/gaoptout.
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 Website and the Program, to analyze and understand usage, and to administer the Website and the Program.
In our agreements with Integration Partners, we commit to maintaining an information security program, and notifying the Integration Partners of any security breaches, consistent with the applicable obligations of the Integration Partners under the Gramm-Leach-Bliley Act.
Your State Privacy Rights
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 Website and Program.
Sources of Collection: Access and use of Website and Program, 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 Program, and to communicate with You
Disclosures for a Business Purpose: To Integration Partners and SavvyMoney service providers to assist in providing SavvyMoney products and services made available on the Website and the Program
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 Program and Integration Partners
Purposes of Collection: To enable SavvyMoney to provide its products and services made available on the Website and the Program to You and to allow SavvyMoney to communicate with You
Disclosures for a Business Purpose: To Integration Partners and SavvyMoney service providers to assist in providing SavvyMoney products and services made available on the Website and Program
Sources of Collection: Purchase of SavvyMoney products and services made available on the Website and the Program and Integration Partners
Purposes of Collection: To provide SavvyMoney products and services to customers and maintain purchase history
Disclosures for a Business Purpose: To Integration Partners and SavvyMoney service providers to facilitate delivery of products and services made available on the Website and the Program
Internet or other electronic network activity
Sources of Collection: Your browsing and search history on the Website and other interaction with the Website and Program
Purposes of Collection: To improve the user experience on the Website and Program, diagnose server problems and administer the Website and Program
Disclosures for a Business Purpose: To third-party analytics services providers for the purpose of enhancing the Website and Program and improving the effectiveness of our advertising
Sensitive personal information
Sources of Collection: Creation of accounts, enrollment into SavvyMoney products and services, and Integration Partners
Purposes of Collection: To provide SavvyMoney products and services made available on the Website and the Program to You
Disclosures for a Business Purpose: To Integration Partners to assist in providing SavvyMoney products and services made available on the Website and the Program 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 whom 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 Website and Program to You.
You may contact us to exercise these rights at email@example.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.
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.
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 who previously received such information.
Links to Other Websites or Internet Properties
We display personal testimonials of customers on the Website 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 firstname.lastname@example.org.
Social Media Features and Widgets
Protecting the privacy of children is especially important to us. The Website and the Program 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 Website or the Program 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 email@example.com
We do not represent or warrant that the Website or the Program, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Website and the Program do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.
By email at: firstname.lastname@example.org
By mail at:
4160 Dublin Blvd, Suite 250
Dublin, CA 94568
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