Effective date: December 31, 2019
2. A NOTE ABOUT CHILDREN. We do not intentionally gather personal data about visitors who are under the age of 13.
4. TYPES OF DATA WE COLLECT.
Personal Data You Provide to Us. We collect personal data from you when you provide it voluntarily on the Site. You may provide your name, phone number, email address, zip code, marital status, financial goals, household income, home ownership status, details about your family, Twitter handle, Facebook profile and other details you may submit to us. You may also provide information in response to our surveys,
We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable Cookies, some areas of our website may not work properly. We have also enabled Google Analytics features, including Demographics and Interest Reporting to gather demographic information provided by these features. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing your Google Ads Settings.
SmartAsset is a member of the Digital Advertising Alliance (DAA) self-regulatory program and adheres to the DAA self-regulatory Principles for Online Behavioral Advertising. We work with a variety of advertisers, ad networks and analytics companies (“Ad Partners”) that collect information about your use of our services. You can opt out of the use of interest-based advertising at any time by visiting the Digital Advertising Alliance consumer choice page.
Our Relationship with Social Networking Sites. We have created, and may offer you, interfaces that allow you to connect with social networking websites such as Facebook and Twitter ("SN Sites") through our Site. We will work with the SN Site's application protocol interface (better known as their developer API) in a way that allows you to authorize us to access your account on that SN Site on your behalf. In order to provide this authorization, you will not provide us with your user name or password to the SN Site, but you will need to log-in to that SN Site directly through our Site. Once authorized by you, the SN Site will provide us a token that allows the SN Site to recognize us when we ask, on your behalf, for access to your account information or to post information. You will be able to revoke our access to any SN Site at any time by amending the appropriate settings from within your account settings on the applicable SN Site, though such revocation may limit the Services we are able to provide you.
5. USE OF YOUR DATA.
General Use. In general, personal data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Company uses your personal data in the following ways:
- Provide you with the Services and customer support;
- Respond to your requests, resolve disputes and/or troubleshoot problems;
- Improve the quality of the Site and the Services;
- Communicate with you about the Site and the Services;
- Market our Services (and those of third parties) to you that we believe may be of interest to you. If you prefer that we do not send you these messages, please see the section below on YOUR CHOICES REGARDING YOUR PERSONAL DATA to learn how to opt-out.
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- Audit our internal processes for compliance with legal and contractual requirements and internal policies;
- Enforce the terms and conditions that govern the Site and the Services; and
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Creation of Anonymous Data. We may create Anonymous Data records from personal data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Products and services and improve site navigation. Company reserves the right to use and disclose Anonymous Data to Third Party Companies in its discretion.
6. DISCLOSURE OF YOUR PERSONAL DATA.
Disclosure to Third Party Service Providers. We may share your personal data with third party service providers to facilitate creation of accounts or to provide services to us that enable us to make the Site or the Services available to you.
Disclosure to SmartAdvisor Marketplace and Marketing Participants. We may share your advisor matching form intake data with relevant financial advisor matches that meet participation criteria and actively participate in the SmartAdvisor platform. The terms and conditions permit those advisors to contact you with the information you have provided.
Other Disclosures. Regardless of any choices you make regarding your personal data (as described below), Company may disclose personal data if it believes in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on Company; or (b) protect or defend the rights or property of Company or users of the Products or related services.
7. THIRD PARTIES.
Personal and/or Anonymous Data Collected by Third Parties. We may receive Personal and/or Anonymous Data about you from other sources like telephone or fax, or from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website ("Third Party Companies"). Our Third Party Companies may supply us with personal data, such as your email address, in order to help us establish the account. We may add this information to the information we have already collected from you via our website in order to improve the Services we provide.
Our provision of a link to any other website or location, such as the payment processing websites, is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect personal data or Anonymous Data from you.
NOTICE TO CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83).
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A "CALIFORNIA CUSTOMER"), MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES' DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING INFO@SMARTASSET.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR, AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
8. YOUR CHOICES REGARDING YOUR PERSONAL DATA.
Changes to Personal Data. You may request deletion of your personal data by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
9. JOB APPLICANTS. When visit the careers portion of our Sites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to operate and improve the Services, and as otherwise necessary for compliance, fraud prevention, and safety purposes.
10. SECURITY OF YOUR PERSONAL DATA. Company is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. Despite these measures, you should know that Company cannot fully eliminate security risks associated with personal data and mistakes may happen.
Attn: Michael Carvin
535 5th Ave, 30th Floor, New York, NY 10017, USA
12. DISPUTE RESOLUTION. If you believe that Company has not adhered to this Statement, please contact Company by email at email@example.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
14. NOTICE TO CALIFORNIA RESIDENTS
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information. CCPA Scope and Exclusions. The description of our Privacy Practices and Privacy Rights in this Notice apply only to California residents whose interactions with SmartAsset are limited to:
- Visiting our website,
- Signing up for email alerts,
- Commenting on or contributing to our forums, or
- Applying for our job openings on our websites (however, the CCPA does not extend Privacy Rights to job applicants).
The description of our Privacy Practices and CCPA Privacy Rights do not apply to the personal information we collect, use or disclose about:
- Consumers who initiate or complete the process of applying for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”), and implementing regulations, or the California Financial Information Privacy Act (“FIPA”), and
- Representatives of businesses that seek to obtain our Services, or to provide their products or services to us.
- Through our services – for example, by inquiring about retaining a financial advisor – you direct us to disclose your information to companies that provide the services in which you are interested.
Here is a description of our relevant privacy practices:
|How you interact with us||Personal information collection||CCPA-defined categories||Sources of personal information||Purposes for which we may collect and use the personal information||Data Sharing|
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The CCPA grants individuals the following rights:
- Information. You can request information about how we have collected, used and shared your Personal Information during the past 12 months.
- Access. You can request a copy of the personal information that we maintain about you.
- Deletion. You can ask us to delete the personal information that we collected or maintain about you.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request. To request access to or deletion of personal information:
- call 1-888-375-4407
- email firstname.lastname@example.org
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
Online Tracking Opt-Out Guide
Like many companies online, we use services provided by Google, Facebook and others companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
- Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
- Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: