Privacy Policy

Updated: February 3, 2020

Sea of Savings, LLC (“the Smart Wallet,” “we,” “our” or “us”) provides the following Privacy Policy (“Policy”) which sets forth our practices related to collecting, using, disclosing and selling information that is personally-identifiable to a user (“PII”), as well as information that is not personally-identifiable (“non-PII”) to a user.  For purposes of this Policy, PII and non-PII will be referred to collectively as “Information.”

By accessing and using one of our websites that we own and operate which offer 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 (collectively, the “Websites” and individually, a “Website”), you understand and agree to our collection, use and disclosure of your Information that you may provide to us.  If you do not understand and agree to how we collect and handle Information, please do not use or visit the Websites, participate in the Content or sign up for our mailing list.  Please note if you are not a U.S. resident, you are not permitted to participate in the sweepstakes we may offer.

NOTICE OF COLLECTION OF PERSONAL INFORMATION

This Policy provides notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the California Consumer Privacy Act of 2018 (“CCPA”), that we collect personal information as that terms is defined in the CCPA (“Personal Information”).  As required by the CCPA, the following sections of the Policy also details the categories and sources of Personal Information collected and the business and commercial purposes for the collected Information. We also include a description of rights afforded to California consumers at “RIGHTS OF CALIFORNIA USERS WITH REGARD TO THEIR PERSONAL INFORMATION.”

TYPES/CATEGORIES OF INFORMATION WE MAY COLLECT REGARDING USERS

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):

  • Information that could reasonably identify a user, such as name, email and gender;
  • Information collected from a user’s responses to survey questions, including employment and other preferences, as further described below;
  • Information collected from our web server log files, including device type(s), user agent data, referring URL(s), and IP address(es);
  • Information collected from third parties or parties under common control (which includes our parent, subsidiaries and other entities under common control with us – collectively “Related Parties”) to validate and augment a user’s profile including a user’s email address or other user Information;
  • Information collected from our customer support department, including customer support inquiries and Content-related emails; and
  • 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.

HOW WE COLLECT INFORMATION – SOURCES

Here are ways we collect Information from and about users (see below for additional descriptions of the methods of Information collection that are provided to California residents):

  • Registration forms and surveys;
  • Emails and other contacts received from users as part of customer service or to claim a prize;
  • From publicly availably sources, such as Internet search engines; and
  • From the use of “cookies” (small text files placed on a user’s computer that track online behavior), single-pixel GIF image files (also called “web beacons”) and other technological means (collectively, “Cookies”).

We also collect Information from our servers that host the Websites and combine that Information with Information on users that we have already collected via other means.  Here are some sources of Information and the methods we use:

  • Our hosting servers collect Information from users through various technological means when users access and interact with our Websites;
  • 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;
  • From third parties including service providers who assist us in hosting the Websites, providing customer support and fulfilling prizes;
  • From third parties who drive users to our Websites and whose goods and services are advertised on our Websites; and
  • From Related Parties and third parties who send emails to users.

HOW WE MAY USE INFORMATION

We may use Information in many ways and for many purposes including the following:

  • For Website operations, content improvements, testing, research, analysis and product development;
  • To provide users with customer service, information, products or services that users request from us;
  • To provide users with email alerts 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;
  • As necessary or appropriate to protect the rights, property or safety of us, Related Parties, our clients, advertisers, service providers and others;
  • As described to users when collecting Information or as otherwise set forth in any applicable consumer protection, state or federal privacy, or data security laws;
  • To maintain suppression or opt-out lists so that users are not contacted when they have asked not to be;
  • If we are sold, merge with a third party, are acquired or are the subject of bankruptcy proceedings, your Information may be shared with the applicable third party(ies); if we are involved in one of these transactions, users will be notified via email or a Policy update on our Website of any change in ownership or uses of your Information, as well as any choices that you may have regarding your Information; 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 or regulations.

HOW WE MAY SHARE INFORMATION

We may share Information that we have about users in many ways and for many purposes,  including the following:

  • With our vendors and marketing partners that assist us with delivery of email messaging;
  • To enable our Information verification and fraud detection vendors to perform contracted for services;
  • With our interest-based advertising partners, as described further below; and
  • With our Related Parties to augment and verify the Information we collect.

When we share Information, we enter into agreements that describe the purpose that 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 AND NON-US RESIDENTS

The Websites are designed to comply with the Children’s Online Privacy Protection Act (“COPPA”).  COPPA requires that website operators not knowingly collect PII from anyone under the age of 13 without prior verifiable parental consent.  In compliance with COPPA, we do not knowingly collect or retain Information from the Websites from children under the age of 13 and may only collect a limited amount of Information from users who are between the ages of 13 and 18.

The Websites are intended for use only by residents of the contiguous United States, Alaska and Hawaii.

COOKIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY ANALYTICS

Although we don’t use Cookies for other purposes, some of our third-party marketing 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 marketing partners 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 PII.

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.

OTHER WEBSITES  

We and our Related Parties and marketing partners may advertise and promote the Websites and we may permit our marketing partners to place ads and other content, including links to other websites, on the Website. While we try to post links only to third-party websites that share our respect for privacy, this Policy and our privacy practices do not extend to and may differ from those of third-party websites that can be accessed through links on this Website. You should review the applicable privacy policies of the third-party websites before registering with, providing Information to or navigating those websites.

OPTING-OUT

Users may opt-out from receiving future contact from us using the following methods:

  • To opt-out from email marketing click the “Unsubscribe” link on the bottom of every email page or click here; and
  • To-opt out of Cookies, interest-based advertising and/or third-party analytics please see the section above.

ACCESSING, CORRECTING AND DELETING YOUR INFORMATION

We may use Information provided by users for the purposes disclosed in this Policy until a user requests that their Information be modified, deleted or corrected. All users who provide their Information to us may request that we modify, delete and/or correct their Information by contacting us [email protected] (see below for a description of the augmented rights with respect to accessing and deleting Information that are provided to California residents).  We will respond to your request 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.  However, we will retain and may use your Information as necessary to comply with our policies including legal obligations, dispute resolution and enforcement of our agreements.

We ask individual users to identify themselves and the Information requested to be accessed, corrected or deleted (suppressed) before processing such requests and, 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).

SECURITY OF YOUR INFORMATION

We use commercially reasonable efforts to prevent unauthorized access or 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 our 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.

We don’t generally collect sensitive Information such as medical information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information.  If and when we do collect, store and transmit sensitive information, that Information will be encrypted with advanced TLS (Transport Layer Security).

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 e-mail 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.

CALIFORNIA NOTICE REGARDING CATEGORIES, SOURCES AND BUSINESS AND COMMERCIAL USES OF PERSONAL INFORMATION

The following chart contains the categories of Personal Information, as enumerated in CCPA Sec. 1798.140(o), of Personal Information we may collect, use, and disclose, the sources of the Personal Information and our business and commercial uses of such Personal Information:

Category Category Name/Description 1. Sources 2. Business Use 3. Commercial Use
A Identifiers – name, email postal, and IP address User provided on registration, customer service inquiries and claim forms; related and 3rd party sources to verify user supplied information Operational purposes including customer service; fraud & security incidence detection; website improvement; award prize winners None
B Personal information categories listed in the California Customer Records statute –name and employment information Same as above, plus user responses to survey questions Operational purposes including customer engagement and website improvement None
C Protected classification characteristics under California or federal law – Age and sex Same as 1. B Same as 2.B None
D Commercial information – products or services purchased, obtained, or considered, or other purchasing data User provided customer service inquires and claim forms, from 3rd party advertisers and system collected website activity logs Same as 2. A and to determine amounts owed by advertisers and data purchasers Determine amounts owed by advertisers of performance campaigns
F Internet or similar network activity -browsing and search history, information on a consumer’s interaction with a website, application, or advertisement System collected activity logs and cookies To determine performance of and amounts owed to paid media suppliers Same as

RIGHTS OF CALIFORNIA USERS WITH REGARD TO THEIR PERSONAL INFORMATION

California users have several rights regarding the collection, use, disclosure, and sale of their Personal Information under the CCPA.  One of these rights, notice of collection of Personal Information, is described above; the balance of these rights is described below and include the following rights:

  • Disclosure of Personal Information collected and sold
  • Opt-out from the sale of Personal Information
  • Deletion of Personal Information
  • Access and portability of Personal Information collected
  • Non-discrimination

Disclosure of Personal Information Collected and Sold.  Because we do not sell any of your Personal Information, our disclosure obligations are limited to Personal Information collected about a user. Once we receive and confirm your verifiable consumer request, we will disclose to you for the 12 months prior to your request:

  • The categories and sources of Personal Information collected;
  • The specific pieces of Personal Information collected; and
  • If we disclosed your Personal Information for a business purpose, we will disclose the Personal Information categories for each category disclosed and the categories of third parties to whom the Information was disclosed.

Right to Opt-Out.  Users have the right to opt-out from the sale of their Personal Information.  In general, websites that sell Personal Information are required to provide a “Do Not Sell My Personal Info” link on each Website page where Personal Information is collected. Because we do not sell your Personal Information, we don’t provide the opt-out link described above.

Deletion of Information.   You have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request using the process set forth above, we will delete or deidentify (and direct our service providers, vendors, and other applicable third parties to delete) your Personal Information from our system other than from our archive servers (which we maintain for compliance purposes), unless there is an applicable exception.

We may decline to process your deletion request if the Personal Information is necessary for us or our service providers, vendors or other applicable third parties for a number of reasons.  The following are some of the reasons we may decline your deletion request:

  1. Complete the transaction for which we collected the Personal Information or provide the goods or services you requested;
  2. Detect security incidents, protect, investigate and respond to malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  3. Identify and correct errors that negatively impact intended functionality; and
  4. Comply with a legal obligation, including Federal and/or State tax liability and reporting.

If we do not comply with a deletion request, we will provide the grounds for our denial.

Access and Portability.  California users have the right to access the Personal Information we have collected about them in the previous twelve (12) months.  Upon receipt of verified consumer requests, we will provide the information in a readily usable format.  You cannot request access more than twice in any 12-month period.

Nondiscrimination.  We are committed not to discriminate against California users 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 our Website may be unavailable if consumers exercise their rights to have their personal information deleted.

Exercising Your Rights, Verification, and Timing.  To exercise your CCPA rights, click here; or email us at [email protected].  To prevent an unauthorized third party from accessing or making decisions regarding a user’s information, we verify all requests to exercise these rights (a verifiable consumer request). We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, unfounded or abusive.

In general, 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 which we will not retain or use for any other purpose.

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 cover only the 12-month period preceding the verifiable consumer request’s receipt and 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.

Authorized Agent.  The CCPA enables California users to appoint an authorized agent to act on their behalf to submit disclosure requests and or deletion requests under the CCPA.  The authorized agent must register with the California Secretary of State.  We will honor a request from an authorized agent provided you provide written authorization to the authorized agent to act on your behalf and we can verify your identity and the agent submits proof of authorization.

CCPA Metrics.  We are required to compile certain annual metrics regarding the CPPA including the number of disclosure and deletion requests we receive, the median number of days it takes us to respond and how many of each were denied.  We will provide this information starting in 2021 by posting a link in this Policy.      

CALIFORNIA ONLINE PRIVACY PROTECTION ACT

Browser “Do Not Track” Signals.  Most browsers contain a “do-not-track” setting.  In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for interest-based advertising.  As required by CalOPPA, we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a user to one of our Websites has activated the “do-not-track” setting on her/his browser.

CHANGES TO THIS POLICY

We reserve the right to revise and update this Policy at any time.  If we make material changes to this Policy, we will post the updated Policy on our Website.  Any such revisions will be effective thirty (30) days after posting to the Website and will apply to all Information collected by us both before and following the effective date.  If we expand the way we use Information, we will notify users by: (a) sending the modified Policy to our users via email or (b) by any other reasonable means acceptable under applicable state and federal law.  You will have a choice as to whether we use your Information in this different manner and we will only use your Information in this way where you opt-in to such use.  Users should periodically access this Policy to review our current policies regarding the collection and use of Information.

QUESTIONS, SUGGESTIONS, OR TO CONTACT US

If you have any questions, comments, complaints, or suggestions regarding this Policy or our Website(s), please contact us here.