Effective May 14, 2014
This Privacy Notice (“Notice”) describes the online information collection, use and disclosure practices of HelloWallet (“HelloWallet,” “we” or “us”), located on the World Wide Web at http://www.hellowallet.com. This Notice describes the information we collect from visitors to our Web site (“Visitors”) and users of our service (“Users”), and how we use and share that information.
What Information Do We Collect Online And For What Purposes Do We Collect It?
In order to serve our Users, we collect certain categories of personally identifiable and non-personally identifiable information through our online service. The categories of information we collect include the following:
Information Collected To Register Users
When Visitors to the HelloWallet Web site register to become Users of the service, we request certain information that will help us to provide a useful and informative financial management tool. The information we request may include the Visitor’s name, e-mail address, and first and last name. We also may ask Visitors who register to become Users of our service to provide log-on credentials that will permit HelloWallet to obtain access to Users’ financial accounts, and ask a series of questions about prospective Users’ household and financial condition, such as retirement savings, other savings, credit card debt and other debt. When prospective Users register for a subscription-based HelloWallet service, we may ask for additional information such as payment card number, payment card expiration date and telephone number.
Information collected in connection with User registration, and other information collected as described in this Notice, may be used to process payments, confirm renewal charges or payments to your account, administer your account and for similar purposes.
We also may use information we collect to notify you about important functionality changes to the Web site, new HelloWallet services, and special offers (including promotion of our service or third-party services) we think you will find valuable. Except for non-advertising communications sent to you regarding material changes to the service or to the terms of this Notice, you may decline to receive commercial e-mails from HelloWallet by noting that preference in your account settings. Each commercial e-mail you receive from HelloWallet also will include a one-click opt out mechanism concerning future HelloWallet commercial e-mails.
Information Collected For Other Purposes
HelloWallet also may collect information from Users for other purposes, including but not limited to: (1) responses to technical support requests; (2) contact information for participation in promotions or contests; (3) optional questionnaires; and (4) responses to inquiries about HelloWallet products or services.
Information Posted To Public Forums
Information you voluntarily place on bulletin boards, blogs and chatrooms sponsored by HelloWallet is visible to other Users. HelloWallet is not responsible for the collection, use and sharing of information Users choose to place on our bulletin boards, blogs and chatrooms.
Clickstream data is nonpersonal information transmitted automatically to us from your computer or mobile device when you interact with our online service using your computer browser or a HelloWallet mobile app. Clickstream data may include your computer’s IP address, the type of Internet browser and operating system you are using, mobile device platform, type of Java Virtual Machine, Internet connection speed and identification of any hardware or software that has previously caused technical problems with the HelloWallet service. Clickstream data also includes the pages and information you access on our service, the time you spend on our service, and the path you take in navigating our service. Collection and analysis of clickstream data permits your computer or mobile device to connect with and navigate our service more effectively. Clickstream data will not be used to identify you personally.
Information Stored On Cookies
If you do not wish to have cookies stored on your computer, you may instruct your browser to block them, erase them or warn you before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. However, blocking or erasing cookies may prevent you from using some of the functionalities of our Web site.
Anonymized And Aggregate Information
Besides the personal information, clickstream data and information stored on cookies that we collect directly from you and your computer or mobile device, HelloWallet uses personal information to generate two categories of non-personal information: (1) anonymized data, which relates to individuals but replaces names and other personally-identifiable information with coded entries that do not disclose individual identities; and (2) aggregate data, which relates to collective characteristics of our Users, such as the percentage of Users that live in specific zip codes, that cannot be used to identify individual Users.
HelloWallet may share anonymized data with our Academic Advisory Board for purposes of research.
HelloWallet uses aggregated information for such purposes as to operate and enhance our services, target promotions to Users, and statistically analyze the usage of our Web site to improve the content, layout and services of the Web site and enhance our marketing and promotional efforts. We may share aggregate information with third parties, such as our partners or the general public, for education, research, marketing and promotional purposes.
HelloWallet also may share aggregate data with sponsoring organizations, such as employers that offer HelloWallet accounts as an employee benefit.
When and For What Purposes Does HelloWallet Share Your Personal Information With Others?
Disclosures To Agents
HelloWallet retains third-party companies and individuals (“Agents”) to perform functions that facilitate our service. Services performed by our Agents include, but are not limited to: (1) gathering financial information from your accounts at the financial institutions you link to your HelloWallet account; (2) sending postal mail and e-mail; (3) removing repetitive information from customer lists; (4) analyzing data; (5) providing marketing assistance; (6) providing customer assistance; and (7) collecting and processing payments for the service. All Agents are required by their contracts with HelloWallet to limit their use of personal information provided by HelloWallet to the purposes for which the agents were retained.
Disclosures To Business Partners
HelloWallet may disclose User’s personal information to its business partners in certain circumstances, subject to Users’ consent. [Business partners are required by their contracts with HelloWallet to limit their use of Users’ personal information to the purposes for which the information was provided.]
Disclosures To Sponsoring Organizations
HelloWallet will provide your personal information to sponsorship organizations, including employers that offer HelloWallet service as an employee benefit, only with your prior consent, which will be obtained after we have provided you with a detailed description of the information requested.
Disclosures Needed To Participate In Promotions, Sweepstakes And Contests
Some HelloWallet sweepstakes, promotions and contests may require that you provide personal information such as your mailing address or credit card number. Such information may be shared with a third party if the third party is sponsoring the event and the information is necessary in order to administer the service or process your transaction.
Some HelloWallet sweepstakes, promotions and contests may include opportunities to request additional information from sponsors and/or may require that you share some basic information in order to participate. By requesting more information or by participating, you give HelloWallet permission to transfer your personal information to the sponsor or partner for the purpose of fulfilling your request.
You are never obligated, as condition of using our service, to participate in HelloWallet promotions, sweepstakes or contests.
Disclosures To Comply With Law And Protect Legitimate Interests
HelloWallet will disclose personal information of Visitors and Users when required by law or in response to legal process, as determined in HelloWallet’s reasonable judgment, and as necessary to protect the interests of HelloWallet, its Users or the public.
Disclosures To Purchasers Or Successor Entities
HelloWallet may transfer personal information to a purchaser or successor entity in connection with the sale of HelloWallet, a subsidiary or line of business associated with HelloWallet, or substantially all of the assets of HelloWallet or one of its subsidiaries, affiliates or lines of business.
How Do We Protect Your Information?
HelloWallet has implemented physical, administrative and technical safeguards to protect Users’ personal information from unauthorized access, disclosure and use. Our physical measures include restrictions of access to areas and facilities in which personal information is stored or where that information may be accessible, and secure disposal of records and storage media. Our administrative measures include restrictive granting and denial of system access privileges, secure administration of passwords and other access credentials, periodic security risk and compliance assessments, and data security training of all employees with access to personal information. Our technical measures include encryption of all personal information sent over public networks or stored on portable media, implementation and updating of firewalls, and use of intrusion detection and anti-virus technologies. HelloWallet cannot be responsible for the information security practices of third-party organizations.
Control Of Your Information
You may request the removal of personal information you have submitted to HelloWallet at any time. We will retain billing records and communication opt-out preference as appropriate. When you request that we delete your HelloWallet service account, we will permanently expunge your data from our productions servers and further access to your account will be disabled. However, aggregate, non-personally identifiable information derived from your personal information may remain on our production servers indefinitely. Your data also may remain on a backup server or media, as required to ensure our continued ability to provide the service in the event of malfunction to our primary production servers. We also reserve the continuing right to use aggregate, non-personally identifiable aggregate information after you have discontinued the service.
Our third-party service providers are required by their contracts with us to take reasonable measures to protect the security of personal information they obtain in connection with providing services to us. Personal information maintained by your financial institutions is subject to the policies of those institutions and your agreements with those institutions.
HelloWallet offers a mobile application (“app”) that permits you to access your financial information from a mobile device. The HelloWallet app does not acquire other information from your mobile device and does not store financial information you have accessed through the app after you have closed the app. At your election, the app may store your HelloWallet logon credentials on your device.
HelloWallet Is Not Directed To Children
Our service and Web site are not directed to children and we do not knowingly collect personal information from children under the age of 18. When we acquire actual knowledge that a Visitor to our service is under the age of 18, we will take appropriate measures to avoid collection of personal information from that Visitor and to delete any information inadvertently collected from that Visitor.
Changes To This Notice
The effective date of this Notice is noted at the top of the Notice’s opening page. If we make changes to this Notice, the revised version will bear a new effective date. When we make changes to the Notice that materially affect Users’ rights, we will use the contact information you provided to notify you of those changes.
Questions About Your Rights
Please direct any questions about your rights under this Notice, or any other questions related to HelloWallet’s privacy and data security policies, to email@example.com.