Privacy Policy & Cookies Policy

Effective Date/Last Updated: 3/19/2024

Sea of Savings, LLC (“the Smart Wallet,” “we,” “our,” or “us”) operates this website and other websites (“Website” or “Websites”) which offers content related to personal finance and may include samples, surveys, sweepstakes, coupons, freebies, jobs, and other general interest topics (collectively, “Content”) to users made available on our Websites from our advertiser clients and marketing partners (collectively, “Trading Partners”). We provide the following Privacy Policy (“Privacy Policy” or “Policy”), which describes how we collect, use, disclose, and share or sell information that is personally identifiable to a user (“Information”). This Privacy Policy also discusses consumers’ data privacy rights under U.S. state data privacy laws, including the California Consumer Privacy Act, as amended (“CCPA”) and other states that have adopted or may adopt data privacy laws and how to exercise those rights. California Consumers: Read the California Notice at Collection within this Privacy Policy below. Capitalized terms used but not defined herein shall have the same meaning as in the Website’s Terms and Conditions, which are fully incorporated herein by reference.

ACCEPTANCE OF PRIVACY POLICY

By accessing and using one of our Websites, you signify your acceptance of this Privacy Policy and your agreement to the collection, use, disclosure, and sharing or sale of your Information as described herein. If you do not intend to agree to the terms of this Privacy Policy, DO NOT use the Website.

PRIVACY POLICY UPDATES

This Privacy Policy is subject to change from time to time. Your continued use of a Website following the posting of changes to these terms will confirm your acceptance of all changes made; provided, that if we expand or alter the Information we collect or how we use it, we will notify users by: (a) sending the modified Policy to our users via email; or (b) any other reasonable means acceptable under applicable state and federal law.

FOR U.S. RESIDENTS ONLY

Please note if you are not a U.S. resident, you are not permitted to use the Website or participate in the sweepstakes we may offer.

CATEGORIES OF INFORMATION WE COLLECT

Here are the types and categories of Information that we may collect regarding users (see below for additional descriptions of the categories of Information collected that are provided to California residents):

Identifiers (such as name, email, IP address, and gender and telephone numbers);
Personal information (such as the Identifiers listed above which may include information that is considered protected classification characteristics under state or federal law or sensitive Information under state law);
Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data);
Information collected from our customer support department, including customer support inquiries and Content-related emails;
Internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses);
Information collected from Cookies (as defined below), including whether a user has previously visited one of our Websites or has opened an email sent by us;
Information related to a user’s consent to receive SMS messaging, commercial email, and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s) that seek to obtain a user’s prior express written consent (as defined in the Telephone Consumer Protection Act (“TCPA”)) to receive SMS/text messages; and
Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends, and attitudes).

HOW WE COLLECT INFORMATION

We may collect Information from the following sources:

Directly from users via registration forms, surveys, and communications, including emails, text messages and other contacts received from users as part of customer service or to claim a prize;
From publicly available sources, such as Internet search engines;
Our systems access Information held by Related Parties and third parties and match it with user Information which enables us to verify the Information we collect from users;
Via our hosting servers, which collect Information from users through various technological means when users access and interact with the Website;
From our service providers and contractors who assist us in hosting the Websites, providing customer support, and sending SMS messages;
From parties under our common control (which includes our parent, subsidiaries, and other entities under common control with us – collectively “Related Parties”);
From our Trading Partners;
From cookies (small text files placed on a user’s browser by a website such as the Website that tracks online behavior), web beacons (single-pixel GIF image files), and other technological means (collectively, “Cookies”); and
By combining Information collected from various sources listed above, including our Trading Partners, Related Parties, and service providers to augment and verify Information and to improve the overall quality of our services.

HOW WE MAY USE INFORMATION

We may use Information in the following ways:

For the purpose of providing you with Content and information about other products and services;
For Website operations, content improvements, testing, research, analysis, and product development;
To provide users with customer service and respond to customer inquiries;
To provide users with email alerts, SMS/text messages, and other communications users have requested or consented to receive or where we are required to send concerning user registrations, sweepstakes entry, and prizes, our products or services, or other information;
To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement and any inquiry specific to prior express written consent (“TCPA Consent”) under the Telemarketing Sales Rule (“TSR”) and/or the TCPA;
To detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, or existing laws, rules, and regulations;
As necessary or appropriate to protect the rights, property, and/or safety of us and our Trading Partners, Related Parties, service providers, and any other third party with whom we have a contractual relationship for commercial or business purposes;
To maintain suppression or opt-out lists so that we won’t contact users who have asked not to be contacted;
To augment Information by enhancing it with other data sources provided by our Trading Partners, Related Parties, and service providers to enable us, for example, to gain deeper insights into our users; and
To respond to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations.

HOW WE MAY SHARE INFORMATION

We do not sell Information or share it for any cross-contextual advertising purposes. We may share Information in the following ways:

With our service providers in connection with the delivery of email messaging, text/SMS messaging, and push notifications, provided that we have obtained TCPA Consent from such users to be contacted by text/SMS messaging and push notifications;
With our service providers and our Trading Partners who assist us in the delivery of email messaging;
To enable our Information verification and fraud detection vendors to perform contracted-for services; and
With our Related Parties to augment and verify the Information we collect and to develop and enhance their products and services.

When we share Information, we enter into agreements that describe the purpose for which the Information is shared, restrict its use to the agreement’s specified purpose, and require that all Information remain confidential and be protected from unauthorized disclosure.

As described below, we do not sell user’s Personal Information within the meaning of the CCPA.

MINORS

The Websites are designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and other laws protecting children’s privacy. In compliance with COPPA, we do not knowingly collect or retain Information from children under the age of 13, and any minor under the age of 13 is not permitted to claim Rewards. If you are a parent or guardian of a child under 13 years of age and you think your child has given us Information, you can email us at [email protected].) In compliance with the CCPA, we do not knowingly sell or share Information of users under the age of 16 for any commercial purpose.

COOKIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY ANALYTICS

Although we don’t use Cookies for other purposes, some of our third-party Trading Partners may place Cookies on our Websites to track users’ online behavior while on our Website and after they leave our Website. These third-party Cookies may enable the delivery of interest-based advertisements (to find out more about Cookies, please visit www.cookiecentral.com) based on a user’s visit to our Website and/or other websites. In addition, our Trading Partners may use Information gathered in this manner to recognize you across different channels and platforms, including computers, mobile devices, and Smart TVs and may use this Information over time for advertising, analytics, attribution, and reporting purposes.

We may use Google Analytics and similar tools provided by our third-party partners to help analyze how users interact with the Website and to display customized ads and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with the Website and do not involve the collection of any additional Information.

Most computers are initially set up to accept Cookies, but users can reset their Internet browsers to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even where you reject a Cookie, you may still use the Website, but your ability to use certain features or offerings may be impaired. For example, if you return to our Website, you may have to re-enter Information you previously supplied to us. We may retain Cookie data indefinitely.

Users may opt-out from interest-based advertising delivered to their web browser by companies who have elected to participate in one of the interest-based advertising opt-out mechanisms, such as the Digital Adverting Alliance’s opt-out program located here or the National Advertising Institute’s opt-out program located here. Users may also choose to opt-out of interest-based advertising on their mobile devices. For more information, please click here.

Please note that opting out of interest-based advertising does not mean you will no longer see advertising online. Rather, it does mean that the company or companies from which you opt-out will no longer show ads that have been tailored to your interests.

As required under some state laws, we are required to inform users that, as is the case with most websites, we generally do not honor or alter our behavior when a user to one of the Websites has activated the “do-not-track” setting on their browser. The exception to this is in the case of California consumers, where, in compliance with the CCPA, we will honor any opt-out preference signals they set on applicable browsers.

OTHER WEBSITES

Our Website contains links to other sites or services. When you link from the Website to a third-party site, you are leaving the Website and are subject to the privacy policies and terms and conditions of those sites – NOT this Privacy Policy. We are not responsible for the privacy practices, content, or security of third-party sites, including those of our Trading Partners. You should review the applicable privacy policies of the third-party websites before registering with or providing Information to those websites.

OPTING-OUT FROM MARKETING

Users may opt-out from receiving future contact from us via the following ways:

Email. To opt-out from email marketing click the “Unsubscribe” link on the bottom of every email page or click here;
TCPA Consent Opt-Out/SMS/Text Messaging Opt-Out. Providing TCPA Consent is not required to access Content on our Website. You may continue to use all other aspects of the Website, regardless of whether you elect to provide TCPA Consent. Users who elected to provide TCPA Consent to receive SMS/text messaging but later wish to revoke TCPA Consent can opt-out from SMS/text messaging by replying STOP to text/SMS messages received or by contacting customer service here; and
Cookies. To-opt out of Cookies, interest-based advertising and/or third-party analytics please see the section above.

ACCESSING, CORRECTING AND DELETING YOUR INFORMATION

Because we do not sell your Information or share it for any cross-contextual advertising purposes, we do not provide a “Do Not Share My Personal Info” link on our Website. Users who provide Information to us may contact us at [email protected] to correct their Information, request their Information be deleted, and/or access what Information we have collected, processed, and shared. We will respond to user requests within forty-five (45) days. If you request deletion of your Information, please note that your Information will be suppressed from further use as described in this Policy.

Note that we may retain and use your Information as necessary to comply with our policies including legal obligations, dispute resolution, and enforcement of our agreements.

When you make a request regarding accessing, correcting, or deleting your Information, we will ask individual users to identify themselves and the Information requested to be accessed, corrected, or deleted before processing such requests. To the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on archive servers).

Please see the “U.S. State Law Rights and Disclosures” section of this Privacy Policy for additional information on privacy rights for consumers in certain states.

SECURITY OF YOUR INFORMATION

We use commercially reasonable efforts to prevent unauthorized access, disclosure, or accidental loss or destruction of your Information. Access to your Information is strictly limited and we take reasonable measures to ensure that your Information is not accessible to the public. We restrict access to users’ Information to only those persons who need access to perform or provide their job or service, both internally and with our third-party service providers. Information is encrypted with advanced TLS (Transport Layer Security) when collected, stored, and/or transmitted.

While we have endeavored to create a secure and reliable Website for users, we are not able to fully eliminate security risks associated with Information. Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of third parties who access or transmit your Information will prevent your Information from being improperly accessed, stolen, or altered. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies if we learn of an information security breach of your Information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

U.S. STATE LAW RIGHTS AND DISCLOSURES

California was the first U.S. state to adopt a comprehensive data privacy law. Since the CCPA was adopted – and as of the date this Policy was last updated – about a dozen states have enacted data privacy laws, and more than fifteen states are currently considering adopting data privacy laws. All of these data privacy laws provide statutory rights to consumers in their respective states.

In general, the CCPA affords the broadest range of rights to California consumers of the data privacy laws adopted to date. We currently offer all of our U.S. users the same rights afforded to California consumers. We also briefly describe any additional rights beyond those afforded under the CCPA in other states that have adopted data privacy laws.

NOTICE AT COLLECTION

This Policy provides timely notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the CCPA, that we collect Information at or before collection.

In the chart below, we set forth the categories of Information we collect from users and which categories of Information we share. We collect these categories of Information for the following purposes: to provide you with Content and information about other products and services; for Website operations, content improvements, testing, research, analysis and product development; to provide users with customer service and respond to customer inquiries; to provide users with email alerts, SMS/text messages and other communications users have requested or consented to receive or where we are required to send concerning user’s registrations, sweepstakes entry and prizes, our products or services or other information; to detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, or existing laws, rules, and regulations; as necessary or appropriate to protect the rights, property, and/or safety of us and our Trading Partners, Related Parties, service providers, and any other third-party with whom we have a contractual relationship for commercial or business purposes; to maintain suppression or opt-out lists so that we won’t contact users who have asked not to be contacted; to augment Information by enhancing it with other data sources provided by our Trading Partners, Related Parties, and service providers to enable us, for example, to gain deeper insights into our users; and to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations. We will retain your Information unless you exercise your data privacy rights for so long as we need to protect us from claims related to your interactions with us. We do not knowingly sell or share Information of users under the age of sixteen (16) years for any commercial purpose.

Category	Sold/Shared?
Identifiers (such as name, email, IP address, telephone number, and gender)	Shared only for business purposes
Personal information (such as the Identifiers listed above and which may include information that is considered protected classification characteristics under state or federal law or sensitive Information under state law)	Shared only for business purposes
Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data);	Shared only for business purposes, including to determine amounts owed to us by Trading Partners
Information collected from our customer support department, including customer support inquiries and Content-related emails;	Shared only for business purposes
Internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses);
Information collected from Cookies (as defined below), including whether a user has previously visited one of our Websites or has opened an email sent by us; and
Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends, and attitudes).

Please see the Rights of California Consumers section of this Privacy Policy immediately below to learn about California consumer privacy rights and how to exercise those rights. This includes the right to know the Information we have collected and sold, the right to opt out from the sale or sharing of Information, and the right to correct or delete your Information.

RIGHTS OF CALIFORNIA CONSUMERS

California consumers have rights under the CCPA regarding their Information. These rights are:

Right to Know. The right to know what Information we have collected, including the categories of Information, the source of collection, our purpose for collecting the Information, the categories of third parties with whom we disclose, share or sell that Information, and for what reason, and the specific pieces of Information we have collected about you.
Right to Delete. The right to request that we delete the Information about you that we have collected. Note that there are certain exceptions to this right, including when the Information is necessary to provide you with goods or services you requested, to prevent fraud, and to comply with our legal obligations.
Right to Correct. The right to request that we correct inaccurate Information that we maintain about you.
Right to Opt-Out of Sale/Sharing. The right to limit or opt-out from the sale or sharing of Information.
Right to Opt-Out of Sale/Sharing of Sensitive Information. The right to limit or opt out from the sale or sharing of sensitive Information, as defined under the CCPA. Note that there are certain exceptions to this right, including when the Information is necessary to provide you with goods or services you requested, to prevent fraud, and ensure safety and security. We do not collect Sensitive Information.
Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.

How to Exercise Your Rights. Because we do not sell your Information or share it for any cross-contextual advertising purposes, we do not provide a “Do Not Share My Personal Info” link on our Website. To exercise your other CCPA rights, you may contact us here or send an email to [email protected].

Verification Process. We require a verification process for requests to access, correct, or delete Information in order to prevent an unauthorized third party from accessing or making decisions regarding a user’s Information. Generally, we will verify a request by matching the identifying information supplied by the user with the Information we already have for the user. If we cannot verify the user using the foregoing method, we may request additional information, such as a government-issued identification card, which we will not retain or use for any other purpose.

Use of an Authorized Agent. California consumers may also designate an authorized agent to make these requests on their behalf. You must provide written authorization to the authorized agent that they are authorized to act on your behalf. When contacting us, the agent must submit proof of that authorization. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government-issued identification card, to verify your identity before processing your request to protect your Information.

Timing. We will confirm receipt of your request within ten (10) business days. For all verifiable consumer requests, we strive to respond within forty-five (45) days of receipt. If we require additional time, which can be up to ninety (90) days in the aggregate, we will provide written notice. Any disclosures we provide will be delivered electronically in a secure fashion. If, for some reason, we cannot fulfill or comply with your request, our response will explain that decision.

How We Handle Deletion Requests After Verification. Once we receive and confirm your request to delete, we will delete or de-identify (and direct our service providers, vendors, and other applicable third parties to delete) your Information from our system other than from our archive servers (which we maintain for compliance purposes), unless there is an applicable exception. If we do not comply with a deletion request, we will provide you with grounds for the denial in writing. Note that after a deletion request, we may retain and use your Information for the limited purpose of complying with our policies, including this Policy, and to comply with applicable laws.

Disclosure of Information Collected. Once we receive and confirm your verifiable consumer request to access your Information, we will disclose to you the following:

The categories and sources of Information collected;
Our business and commercial purposes for collecting and sharing that Information;
The categories of third parties with whom we shared that Information;
The specific pieces of Information collected; and
The categories of Information disclosed for a business purpose and the categories of third parties to whom the Information was disclosed.

Notice of Right to Opt-Out of the Sale or Sharing of Your Information, including Sensitive Personal Information. Because we do not sell your Information or share it for any cross-contextual advertising purposes, we do not provide a “Do Not Share My Personal Info” link on our Website pages. To exercise your other CCPA rights, you may contact us here or send an email to [email protected].

Note that we may collect Information that is considered “Sensitive Personal Information” under the CCPA in some of the survey questions that we ask. “Sensitive Personal Information” under the CCPA includes non-public information that reveals a consumer’s social security, driver’s license, state identification card, or passport number, a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation, and biometric data. You do not have to provide us with any Sensitive Personal Information in order to use our Website.

Global Privacy Controls. Certain browsers allow users to enable an opt-out preference signal in their browser settings (a “Global Privacy Control”). When a Global Privacy Control is enabled, it signals websites that the user visits that the user is automatically exercising their right to opt-out of the sale or sharing of their Information without the need, for example, of clicking on a “Do Not Sell My Information” link. Although we do not sell or share Information, we have enabled acceptance of California users’ Global Privacy Control.

Commitment to Nondiscrimination. We are committed to not discriminating against California consumers who exercise their CCPA rights. As such, unless otherwise permitted by the CCPA, we will not deny, charge you different prices or rates, or provide a different quality level of goods or services, including through granting discounts or other benefits, or imposing penalties, and/or suggest that you may receive a different price, rate, or quality level of goods or services. While we do not provide financial incentives for users who do not exercise their CCPA rights, please note that some of the functionality of the Website may be unavailable if consumers exercise their right to have their Information deleted.

De-identified Data Disclosure. We may use de-identified data in some instances (data that cannot be linked to any identifiable natural person or any device linked to any such person). We maintain de-identified data without attempting to re-identify it, and any de-identified data that is sold or shared is not able to be re-identified.

RIGHTS OF USERS OF OTHER STATES THAT HAVE ADOPTED DATA PRIVACY LAWS

Each of the states that have adopted data privacy laws affords their residents data privacy rights with respect to the collection, use, sale and/or sharing of Information. As noted above, the CCPA affords California consumers a broad range of rights with respect to their Information and we have elected to afford all of our U.S. users with these rights. Some state data privacy laws afford consumers with other rights including the right to opt out of targeted advertising and the right to opt-out of automated processing performed on Information that evaluates, analyzes, or predicts personal aspects of the user. If a user resident in a state that offers these rights requests that we afford users these state-specific rights, we will honor such requests.

Other states beyond California have enacted data privacy laws, and more are expected to do so. We will update our privacy practices to comply with those laws when they’re effective.

QUESTIONS, SUGGESTIONS, OR TO CONTACT US

If you have any questions, comments, complaints, or suggestions regarding this Policy or our Websites, please contact us here.