Smarter Financial Moves Privacy Policy

LAST UPDATED: 5/25/2021

Smarter Financial Moves, LLC (“Smarter Financial Moves” or “we”, “us” or “our”) is committed to respecting your privacy. We will only use your Personal Information in accordance with the terms of this Privacy Policy (“Policy”). This Policy describes how we collect, use, protect and disclose Personal Information received from your use of our websites, including, but not limited to, https://smartmove.co and the features, functionalities, browser extensions and other services available through our websites (collectively, our “Websites”) and our mobile applications, including, but not limited to, the Smarter Financial Moves App available through the Apple App Store and the Google Play Store, along with the features, functionalities, applications, browser extensions and other services available through our mobile applications (collectively, our “Apps”). The Websites and Apps, along with our business operations related to the operation of the Websites and Apps, are referred to in this Policy as our “Platform”.

You can access and interact with our Platform in many ways, including from a computer or mobile device. This Policy applies regardless of how you access or interact with our Platform. Depending on how you interact with our Platform, there may be some cases where we need to provide you with additional information about how we use your Personal Information and/or what options you have regarding our use of your Personal Information. We may provide this additional information via notices on the Platform or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Policy.

Please read this Policy carefully. If you do not want us to collect, use or disclose your Personal Information in the ways described in this Policy, please do not use our Platform, provide us with your Personal Information or authorize a third party to make your Personal Information available to us. By using the Platform, providing us with your Personal Information or otherwise making your Personal Information available to us, you acknowledge that you understand that we may use your Personal Information as described in this Policy. Please note, as described in this Policy, we may receive your Personal Information from third parties that have not expressly advised you that they will disclose your Personal Information to us. If you have any questions about how we collect, use, protect, disclose or otherwise process Personal Information, including whether we have received your Personal Information from a third party, please contact us by email at support@smartmov.co.

  1. PERSONAL INFORMATION WE COLLECT

Our primary goals in collecting Personal Information are to provide and improve our Platform, to conduct our operations, to communicate with you and to enable visitors to our Websites and Apps to enjoy and easily navigate them. This section describes what Personal Information we collect. When we refer to “Personal Information” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “Personal Information” does not include publicly available information from government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.

  • Categories of Personal Information We Collect. Depending on the type of activity you are performing on the Websites Apps or how you use or interact with our Platform, we may collect and disclose the Personal Information listed below in connection with our Platform. Please note, depending on how you interact with us, we may not collect all (or any) of the Personal Information identified below.
    • identifiers and contact information, such as your real name or alias, physical address, email address, IP address and similar information;
    • online identifiers you use, such as your username, social media handles and similar information;
    • Platform account information, such as your username, password, account activity and similar information;
    • identify verification information, such as your social security number and similar information;
    • third-party financial account information, such as your user IDs, passwords and similar information;
    • financial information, such as account balances, income, expenses, purchase and similar types of information;
    • demographic information, such as your age, gender and similar information; and
    • other information you or third parties provide us.
  • Usage Information. We may collect information about the devices that access or interact with our Websites and Apps (“Usage Information”), which may include:
    • device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a computer or mobile device used to access or interact with our Websites or Apps;
    • information about interactions with our Websites or Apps, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with activities on our Websites or Apps;
    • information about Internet and network activity, such as websites visited, search engine results and similar information associated with a computer or mobile device that accesses or interacts with our Websites or Apps;
    • information automatically collected by cookies and other technologies on our Websites or Apps; and
    • any other information that a computer or mobile device automatically sends whenever connected to a website or an online application.

Usage Information, by itself, generally does not identify the specific person using the computer or mobile device that generated it. This means that Usage Information usually will not be considered Personal Information and our use of such Usage Information is not subject to this Policy. However, if we link Usage Information directly with other Personal Information or other information that could identify a specific person, we will treat the linked Usage Information as Personal Information and use the linked Usage Information in accordance with this Policy.

For more information about how we collect Usage Information, please see the “How We Collect Usage Information” section below.

  1. HOW WE COLLECT PERSONAL INFORMATION
    • Directly From You. When you engage with us in connection with our Platform, such as requesting information, creating an account, signing up to receive communications, communicating with us or otherwise interacting with us, we may ask you to provide certain Personal Information. Some of the Personal Information we request may not be required, however, we will specifically indicate what Personal Information is required to engage in such activity.
    • From Third Party Services.
      • We may obtain information (which may include Personal Information) about you from sources that are not us, including, but not limited to, the third parties that provide services that are integrated with our Platform, Internet, offline sources, social media platforms, advertising or marketing platforms, various service providers and other public or commercial sources (collectively, “Third Party Services”) and any information collected by or in connection with any of those Third Party Services.
      • When you access our Websites or Apps through certain Third Party Services, associate our Websites or Apps with certain Third Party Services or share our content via certain Third Party Services, you acknowledge and agree that you are authorizing us to collect, store, share and use any content and information we receive from those Third Party Services about you in accordance with this Policy.
      • We may combine the content and information we receive from Third Party Services with any information that we obtain about you in connection with our Platform. In some cases, you may be able to revoke our access to content and other information we receive from certain Third Party Services, including any social networking sites you connect to through our Websites or Apps, by changing the appropriate settings for your account with the applicable Third Party Service.
    • From Other Third Parties.
      • We may obtain Personal Information about you from other third parties through or in connection with our Platform. These third parties may include our business partners, our service providers, social media sites, ad networks, analytics providers and other third parties that are authorized to share information about you with us.
      • We may also obtain Personal Information about you from others that refer you to us.
  1. HOW WE COLLECT USAGE INFORMATION

We collect Usage Information in a variety of ways. Some Usage Information, such as the IP address of the computer or mobile device attempting to access our Websites or Apps, is necessary for us to make the Websites or Apps available. Other Usage Information, such as information about what features on our Websites and Apps are popular, help us to improve our Websites and Apps. This section describes the primary ways we collect Usage Information in connection with our Websites and Apps.

  • When you access our Websites or Apps, our systems automatically record Usage Information that your computer or mobile device sends whenever you visit a website or use an online application, as well as Usage Information about how long your computer or mobile device is connected to our Websites or Apps and the activities that your computer or mobile device engages in while connected to our Websites or Apps.
  • We may automatically collect information using “cookies”. Cookies are small data files stored on your hard drive or mobile device storage by a website and other online applications. Among other things, cookies help us improve our Websites and Apps and your experience. We use cookies to see which areas and features of our Websites and Apps are popular and to understand usage of our Websites and Apps. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Websites or Apps; and (2) third party cookies, which are served through Third Party Services on our Websites and Apps, and can be used by such Third party Services to recognize your computer or mobile device when it visits other sites or uses other online applications. For more information about third party cookies used on our Websites and Apps, please see the “Third Party Personal Information Collection” section below. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, please visit https://www.allaboutcookies.org/.
  • Other Tracking Technologies. We may collect information using web beacons, clear gifs, pixel tags or other similar technologies. These technologies are electronic images that may be used on our Websites, Apps or in emails we send. We use these technologies to deliver cookies, count visits, understand usage and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
  • Do Not Track Signals. Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments and legal changes.
  1. HOW WE USE AND DISCLOSE PERSONAL INFORMATION

We use and disclose Personal Information we collect for various purposes in connection with our Platform. This section describes the primary purposes for which we use the Personal Information we collect.

  • Operational Uses and Disclosures. We may use and share your Personal Information for the following purposes:
    • for any purpose with your consent and/or to fulfill any other purpose for which you provide your Personal Information or otherwise specify;
    • to present our Websites and Apps and/or changes and updates to our Websites and Apps;
    • to understand and analyze usage trends and user preferences
    • to notify you about changes to our Platform;
    • to present content to you and other users to fulfill our business purposes;
    • to provide you with information that you request or that may be of interest to you;
    • to provide customer service, including to respond to your comments or questions;
    • to facilitate your use of the features you elect to use on the Platform, including, without limitation, linking your financial accounts to the Platform and transferring funds between your financial accounts through the Platform;
    • to notify you about issues with, or changes to, our policies;
    • to promote our Platform or to provide other promotions and services to you, including, but not limited to, jointly with our third party marketing partners (as a Third Party Service, our “Marketing Partners”). In addition, we may share your Personal Information with our Marketing Partners for such Marketing Partners’ own use. If you do not wish to receive these communications (which may occur via email), you may opt out by using one or more of the options described in the “Managing Your Personal Information” section below;
    • to carry out our obligations and to enforce our rights arising from any contracts we have entered into, including, but not limited to, any such contracts between you and us;
    • to display and target advertisements, marketing, promotions and content via our Websites and Apps and in connection with any Third Party Services. For more information, please see the “Targeted Advertising” section below; and
    • to certain trusted representatives, advisors, business partners and corporate affiliates for certain purposes, including, but not limited to, providing services and support through our Websites and Apps, enhancing your experience on our Websites and Apps, operation of our Websites and Apps.
  • Sale of our Business; Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us, including Personal Information. We reserve the right, in connection with these types of transactions, to transfer or assign your Personal Information and other information we have collected to third parties and to authorize such third parties to use any such information. Except as ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Policy. However, any Personal Information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
  • Protective Disclosures. We reserve the right to preserve and disclose any information, including Personal Information, that we believe is necessary to: (a) comply with any court order, law or legal process, including to respond to any government or regulatory request; (b) enforce or apply our Terms of Service (available at https://www.smartmov.co/terms-of-service and in the Privacy section on our Apps) and other agreements; and/or (c) protect the rights, property or safety of Smarter Financial Moves, our employees, our users and others.
  • Targeted Advertising. We may use Personal Information collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions and offers to you, on behalf of ourselves and Marketing Partners, on and off the Websites and Apps.
  • Use of Anonymized and Other Non-Identifying Information. We may use and disclose aggregated information about the uses and performance of our Platform, and information that does not identify any individual, without restriction.
  1. THIRD PARTY PERSONAL INFORMATION COLLECTION

Based on the nature of our Websites and Apps, third parties may collect information from or about you through your use of our Websites and Apps. This section describes the different categories of third parties that may collect information about you in connection with our Websites and Apps.

  • Linked Third Party Content. Any links to other websites, applications or other third party content on our Websites and Apps are not an endorsement, authorization or representation that we are affiliated with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications or content you access.
  • Other Users. Depending on how you interact with our Websites and Apps, other users may collect information about you that is published or otherwise generally made available on our Websites and Apps. All users of our Websites and Apps are subject to our Terms and Conditions. While we place restrictions on what our users are allowed to do with information made available to them on our Websites and Apps, we are not responsible for any misuse of any information, including your Personal Information, by any user. If you believe that another user has misused your Personal Information or any other information available on our Websites and Apps, please contact us at [email protected].
  • Third Party Cookies and Other Tracking Technologies. We may use tracking solutions provided through certain Third Party Services on our Websites and Apps, such as those outlined below.
    • Google Analytics. We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to assist us in understanding how our Websites and Apps are used. Google Analytics will place cookies on your computer or mobile device that will generate information that we select about your use of the Websites and Apps, including your computer’s or mobile device’s IP address. That information will be transmitted directly to and stored by Google. The information will be used for the purposes of evaluating use of the Websites and Apps, compiling reports on activity on our Websites and Apps for our use and providing other services relating to activity on, and usage of, our Websites and Apps. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of our Websites and Apps. The use of cookies by Google Analytics is covered by Google’s privacy policy, available at https://policies.google.com/privacy. Google allows you to opt out of Google Analytics. You may opt-out by visiting https://tools.google.com/dlpage/gaoptout.
    • Google Tag Manager. We may use Google Tag Manager (“GTM”), a tag management system that allows JavaScript and HTML tags to be quickly deployed and updated on portions of our Websites and Apps for tracking and analytics. GTM enables the use of Google Analytics. If you have opted out of Google Analytics, GTM takes this opt out into account. For more information about the privacy practices applicable to GTM, please refer to https://policies.google.com/privacy/ and the terms of use at https://www.google.com/analytics/tag-manager/use-policy.
    • Facebook Pixel. We may use Facebook Pixel, a cookie placed by Facebook, that enables us to measure the effectiveness of advertising campaigns served on Facebook. The information collected by that cookie will be transmitted directly to and stored by Facebook. For more information about Facebook’s privacy practices, please refer to https://www.facebook.com/about/privacy. To opt-out, please visit https://www.facebook.com/ads/preferences.
    • LinkedIn Insight Tag. We may use LinkedIn Insight Tag, a cookie placed by LinkedIn, that enables us to measure the effectiveness of advertising campaigns served on LinkedIn. The information collected by that cookie will be transmitted directly to and stored by LinkedIn. For more information about LinkedIn’s privacy practices, please refer to https://www.linkedin.com/legal/privacy-policy. To opt-out, you can update your advertising preferences through your LinkedIn account. If you do not have a LinkedIn account, LinkedIn allows you to opt-out of applicable targeted advertising by visiting https://www.linkedin.com/psettings/guest-controls.
    • We may use HubSpot Analytics, a web analytics service provided by HubSpot, Inc (“HubSpot”) that uses cookies and beacons to track how long users are on our Websites and Apps, what marketing pages they visit, what marketing offers they respond to and a user’s identity, to improve our customer education material, set up accounts and operate our Platform. For a description of all HubSpot cookies and information about HubSpot’s privacy practices, please refer to their privacy policy at https://legal.hubspot.com/privacy-policy and their cookie policy at https://legal.hubspot.com/cookie-policy.
  1. MANAGING YOUR PERSONAL INFORMATION

We offer you several choices with respect to how we use your Personal Information. This section describes the mechanisms available to you to control the Personal Information we use about you in connection with our Platform.

  • Tools to Contact Us. If you want to update any Personal Information you have provided to us, update your preferences, control communications we send you or otherwise contact us about your Personal Information, please email us at [email protected].
  • Additional Tool for Communications. For email communications you receive from us, you may opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional emails from us. Please note, opting out of email communications will only apply to marketing and other promotional emails and will not apply to any email or other communications sent for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Platform.
  • Closing Your Account. We do not delete information about you (including your Personal Information) when you close your account. We will designate that your account has been closed, but we may retain your information (including your Personal Information) for a variety of purposes, including complying with legal obligations, backups and archives, analytics and fraud and abuse prevention. If you have a fund transfer transaction pending when you close your account, your access to the Platform will terminate but the pending transfer will continue to completion and the payments provider will remain open as described in their Terms of Use and Privacy policy. Their link can be found on our terms of service, located at https://www.smartmov.co/terms-of-service/. 
  • Targeted Advertising. If you do not want us to use Personal Information that we collect, or that you provide, to deliver advertisements according to our or our Marketing Partners’ target audience preferences, you can opt-out by sending us an email with your request to [email protected]. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org.
  1. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to protecting the security of your Personal Information. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the Internet. Your Personal Information and other information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us. We cannot guarantee the security of any information, including your Personal Information, that you disclose online, and you do so at your own risk.

  1. CHILDREN’S PRIVACY

Our Platform is not intended for anyone under 18 years of age. We do not knowingly collect or allow the collection of Personal Information in connection with our Platform from anyone under the age of 13. If we learn that we have collected the Personal Information of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, you may contact us at [email protected] and ask us to remove your child’s Personal Information from our systems.

  1. INTERNATIONAL TRANSFERS

The Platform is hosted in the United States and is only intended for United States residents. Personal Information collected through our Platform is stored and processed in the United States. If you access or use our Platform from outside the United States, you expressly consent to any transfer of Personal Information outside of your country to the United States which has not been assessed as having adequate privacy laws in some countries and economic regions.

  1. CALIFORNIA PRIVACY RIGHTS

Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to other rights described in this Policy. Under California’s Shine the Light Law, you have the right to send us a request at the email address designated below to receive the following information:

  1. the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
  2. the names and addresses of the third parties that received the information; and
  3. if the nature of the third party’s business cannot be determined from their name, examples of the products or services they market.

This information may be provided in a standardized form that is not specific to you. The designated email address for these requests is [email protected].

  1. UPDATES TO THIS POLICY

From time to time we may revise this Policy to reflect changes in our Platform or to ensure that this Policy complies with applicable laws. Consequently, we reserve the right to update and revise this Policy at any time in our sole discretion. Your continued use of our Websites and Apps and/or engagement with our Platform means that you accept and agree to this Policy as amended or revised from time to time, and you should therefore review this Policy regularly to ensure that you are aware of its terms. You will know if this Policy has been revised since your prior visit by referring to the Last Updated Date at the top of this page.

  1. CONTACT US

We welcome your questions, comments and concerns about privacy. Please email us at [email protected] with any questions or feedback you have pertaining to our privacy practices.