Privacy Policy

Our Policy Behind Our Privacy Policy

The Lampo Group, LLC d/b/a SmartDollar ("we", "us", or "our") has every intention of protecting your privacy. Respecting the privacy and the security of your personal information is important to us. This Privacy Policy discloses our privacy practices as applicable to our web-based SmartDollar retirement education program that can, and potentially among other avenues, be accessed via www.smartdollar.com (the "Site"), including any features, functionality, tools and product support that we may provide you access to in connection with the same (collectively, the "Services") and how we may use the information that we gather on the Site, or via your access and use of the Site and Services. By accessing or using the Site or Services, or otherwise voluntarily providing personal information to us in connection with the same, you consent to the terms of this Privacy Policy. This Privacy Policy applies solely to information collected by us in connection with the Site and Services and sets forth the following:

  • What personally identifiable information ("PII") is collected from you through the Site and Services, how it is used, and with whom it may be shared;
  • What choices are available to you regarding your information;
  • The security practices in place to protect against the unauthorized access, use, or disclosure of your information; and
  • How you can correct any inaccuracies in the information.

Please note that you can reference our SmartDollar Terms of Service for the terms and conditions that govern general access and use of the Site and Services.

Collected Information

Each time you visit the Site, we may automatically collect certain types of information. Some examples of information we may automatically collect, compile, and track are:

  • Your internet service provider's address, internet protocol or IP address, the web page from which you came, 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;
  • We may collect a record of your activity or your "clickstream" while visiting the Site;
  • We may use "cookies" of different types to recognize your computer. A cookie is a small text file that a website, online application, or e-mail may save to your internet browser and/or your computer's hard drive for use in subsequent visits to the Site or other sites related to the same (for more information, see our Cookie Policy below);
  • We may use web beacons, match scripts, pixel tags or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, or links in the email utilized. In some instances, these technologies may allow us to match activities with particular users;
  • Information you enter via the Site or Services, such as your name, e-mail address, mailing address, or phone number; and
  • Site and Services usage data.

Use of Information

In no event will we sell your information to third parties. Your information will be used to properly make available and deliver the Services to you. We may also use collected or compiled access and usage information for our own lawful research, benchmarking, statistical purposes which may help us perform analysis for the purposes of improving the Site and Services and to manage our business. Aggregate or combined data may be collected from online and offline facilities and may be used to enhance our ability 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.

Your information will not be accessible to anyone other than our team members, or our third-party partners or service providers that we have vetted from a privacy and security perspective and who have a valid business need to properly fulfil their duties in supporting, managing, and/or maintaining the Site, Services, or underlying technology of the same. If requested by your employer or the plan sponsor purchasing your subscription to the Services, we may share your information with them, their wellness vendor(s), third-parties promoting the Services to them, or non-wellness third-parties your employer or plan sponsor utilize in support of their general business operations. The information types we share and limitations on sharing activity are addressed below.

Sharing of Information

Because the Services are designed to promote your personal financial wellness and encourage participation in your retirement plan, from time to time your employer or plan sponsor may request us to share certain data elements or usage metrics directly with them, their wellness vendor(s), third-parties promoting the Services to them, or non-wellness third-parties they utilize to support of their general business operations.

In no event will we share with your employer or plan sponsor, directly or indirectly via a third-party, any financial information of yours that is personally identifiable to you. All information or data elements shared with your employer, plan sponsor, or applicable third-parties that are financial in nature (if any) will be in de-identified format or aggregated with other data to an extent that it does not uniquely identify you.

As mentioned above under "Use of Information", your personal information may be accessible by applicable third-party service providers. Some examples of the services that these third-parties provide in support of the Site, Services, your employer or plan sponsor are:

  • Third party software, services, providers, or vendors enabling us to deliver, make available, maintain, and support the Services including support and ongoing improvement of customer service;
  • Developing, hosting or maintaining the Site on our behalf;
  • Aggregating user information that we may then share in non-identifiable aggregated format with prospective marketing partners for the purposes of generalized product marketing (i.e., not individually targeted to users of the Services)
     
    • California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. In maintaining compliance with regulations applicable to the nature of the Services, we have not and do not transfer information to third parties for direct marketing purposes. In the event we decided to do so in the future, we would provide affirmative consent and opt-out procedures.
  • Data warehouse, aggregation, and/or 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 the request of your employer or plan sponsor, data shared will be limited to the following elements:
     
    • SmartDollar Point Totals
    • Employee ID Number (if provided by your employer)
    • Enrichment Data - data elements provided to us by your employer to support the effective use of the Services and to provide enhanced aggregated reporting and segmentation. Some examples of this include, but are not limited to, work location, business unit, union group and job title. In no event will such data include any granular financial information that is personally identifiable to you.
    • Aggregate information that may or may not be financial in nature, but in no event where such information is uniquely identifiable to you.

Service providers we utilize and that we share your information with are contractually limited in the ways they may use your personal information and are subject to confidentiality and industry standard security requirements. Third-parties your employer or plan sponsor utilize, request or require that we share your information with, or those that your employer or plan sponsor requests or requires to share information with us, are subject to any permitted-use, privacy, confidentiality and security restrictions your employer or plan sponsor may have contractually in place with them. In your access or use of the Site and Services, you agree that The Lampo Group LLC, its corporate affiliates, subsidiaries and their employees and agents are not responsible or liable for any use of your information shared by us to your employer, plan sponsor, or any third-parties that your employer or plan sponsor requests or requires us to share information with or for any third party sharing your information to us at the request of your employer or plan sponsor. Although we cannot reasonably compel third parties utilized by your employer or plan sponsor to enter into contractual agreements with us, we make commercially reasonable efforts to enter into agreements with the same as an added protection for any information sharing activities and to ensure the confidentiality of such information.

Your PII may be shared with your employer or plan sponsor’s designated 401(k) provider ("Record Keeper") in support of your, and/or your employer’s or plan sponsor’s, retirement plan. Although PII may be shared with a Record Keeper, in no event will such data include any granular financial information that is personally identifiable to you. Sharing of data in this manner ensures that the Record Keeper is able to assess the aggregate impact of the Services and enables them to thoughtfully tailor communications they may send you regarding retirement plan participation.

Moreover, in the event that a division or part or all of our company is bought, sold or otherwise transferred, or is in the process of a potential transaction, your information may be shared for evaluation purposes and included among the transferred business assets.

We may also disclose PII when such disclosure appears necessary to comply with the law, a subpoena or other litigation process or to protect the lawful interests or safety of our customers, employees, or others. This includes potentially exchanging information with other companies, government agencies, and law enforcement organizations for fraud protection, information security purposes, and credit risk reduction.

Your Access to and Control Over Information

You may opt out of any future contacts from us at any time. You can do any of the below listed things at any time by contacting us at privacy@smartdollar.com or by calling 1-800-754-4220:

  • See what data we have about you;
  • Change/correct any data we have about you; or
  • Have us delete any data in our in-scope application systems that are personally identifiable to you as a user of the Services. 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 any and all of our systems due to certain technical limitations.

Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, we and the Site do not recognize DNT.

Cookies Policy

The Site uses "cookies", which are small pieces of information stored by your browser, other applications on your computer's browser, or your hard drive. The cookies are used to connect your computer 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 the Site and/or other websites. Some examples of this data include your account preferences, user specific information on pages accessed, searched terms or addresses entered, and previous visits to the site. 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 benefit from certain features of the Site and Services or receive a promotion tailored to you. We nor the Site control or guarantee the effectiveness of browser-based tools for managing cookies.

Security

We are determined to keep your information private. We use industry-standard security techniques on the Site and within the Services to help protect against unauthorized access, use, or disclosure of information collected via your access and use of the Site and Services. However, while we strive to protect your personal information, we cannot guarantee the security of the information you transmit to us via the Internet. 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 and that you properly maintain and update the device you use to access the Site and Services. You may reference our General Statement on Information Security for more insight into our information security practices as they relate to the Site and Services.

How to Correct, Access, and Update Your Information

If you wish to access information that you have submitted through the Site or Services, or to request the correction of any inaccurate information you have submitted through the same, you can do so by emailing us at privacy@smartdollar.com or by calling 1-800-754-4220.

Geographic Restrictions

The Site and Services are intended for access and use within the United States. The Site and Services are not intended for, or directed to, citizens, domiciles or residents of the European Union or U.S. citizens that are based out of or located outside of the United States. Accordingly, the Site and Services comply with applicable United States federal and state laws. By accessing and/or using the Site or Services you affirm that you are not a citizen, domicile or resident of the European Union or a U.S. citizen based out of or located outside of the United States.

Updates or Changes to the Privacy Policy

This Privacy Policy may be revised from time to time as we add new features and functionality at the Site and to the Services, as laws change, and as industry privacy and security best practices evolve. When we do so, we will post the updated policy on this page including date of update. It is your responsibility to return to this page to check for any updates or changes. Your continued access and use of the Site and Services subsequent to any changes or updates to this Privacy Policy constitutes your acknowledgement of, agreement with, and acceptance of such policy changes and updates.

Other Sites

Our Site may contain links to other sites, including those of our business partners. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.

Children's Privacy

Under Age 13

We do not knowingly solicit or collect PII online from children under the age of 13 without prior verifiable parental consent. If we learn that a child under the age of 13 has submitted PII online without parental consent, we will take all reasonable measures to delete such information from our systems and to 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). Please note that, while we make reasonable efforts to comply with such requests, deletion of personal information does not ensure complete and comprehensive removal of that data from all systems due to certain technical limitations. If you become aware of any PII we have collected from children under 13, please email us at privacy@smartdollar.com or call us at 1-800-754-4220.

Under Age 18

Minors under 18 years of age may have the personal information that they provide to us through the Site deleted by sending an email to privacy@smartdollar.com or by calling 1-800-754-4220 requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of personal information does not ensure complete and comprehensive removal of that data from all systems due to certain technical limitations.

Contact

Please contact us if you have any questions or concerns about our privacy policy. You are welcome to call our Customer Care Center at 1-800-754-4220 between 8:30 a.m. and 5:30 p.m. CST to speak with a customer service representative. You may also contact us by e-mail at privacy@smartdollar.com.

The Lampo Group, LLC 
d/b/a SmartDollar 
1011 Reams Fleming Blvd., 
Franklin, TN 37064



 

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