Privacy Policy

Updated: November 7, 2019

Sea of Savings, LLC (“us” or “we” or “the Smart Wallet”) sets forth the following Privacy Policy (“Policy”) with our practices associated with our collecting, using, and sharing information that is personally identifiable to a user (“PII”) and information that is not personally identifiable to a user (“non-PII”) in connection with our operation and promotion of this website that displays content relating to personal finance and other general interest topics (“Content”).  For purposes of this Policy, PII and non-PII will be referred to as “Information.”

By accessing and using one of our websites that we own and operate, which offers content related to personal finance and may include samples, surveys, sweepstakes, coupons, freebies, jobs, and other general interest topics (collectively, the “Websites” and individually a “Website”), you understand and accept how we collect, use and share Information.  If you do not understand and accept how we collect, use and share Information, please do not use or visit a Website, access the Content or participate in any offers or promotions displayed on a Website.

HOW WE MAY COLLECT INFORMATION

Here are some of the ways we may collect Information from users:

  • Registration forms and surveys;
  • Emails, USPS mail and other contacts received from users as part of customer service relating to the Content or other Website offers; 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 from third parties, including parties under common control (which includes our parent, subsidiaries and other entities under common control with us – collectively “Related Parties”) that we associate with a user’s Information, in the following ways:

  • Our hosting servers collect Information from users through various technological means when users access and interact with our Websites;
  • By accessing Information held by Related Parties and third parties and matching it with user Information which enables us to verify the Information we collect from users; and
  • From Related Parties and third parties who send emails to users.

TYPES/CATEGORIES OF INFORMATION WE MAY HAVE REGARDING USERS

Here are types and categories of Information we may have regarding users:

  • Information that could reasonably identify a user, such as name, age, email address(es), income, and gender;
  • Information collected from a user’s responses to survey questions, including employment and other preferences;
  • Information collected from our web server log files, including device type(s), user agent data, referring URL(s), and IP address(es), as well as how a user interacts with our Website including Content they access;
  • Information collected from third parties or Related Parties to validate a user’s email address;
  • Information collected from our customer support department, including customer support inquiries;
  • Information relating to a user’s interaction with commercial email and other forms of communication; and
  • Information collected from Cookies, including whether a user has previously visited one of our Websites or has opened an email sent by one of our marketing partners.

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, 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 you 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, for which we may be compensated, including the following:

  • With our vendors and marketing partners that assist us with delivery of email messaging;
  • 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 and/or are compensated for 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.

CHILDREN AND NON-US RESIDENTS

The Websites are designed to comply with the Children’s Online Privacy Protection Act (“COPPA”).  COPPA requires that website operators do not knowingly collect PII from anyone under the age of 13 without prior verifiable parental consent.  We do not knowingly collect or retain information from the Websites from children under the age of 18.

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

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.

COOKIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY ANALYTICS

Our Websites use Cookies to determine whether users have previously visited our Websites and to streamline the registration process.  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.

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.

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

All users who provide their Information to us may request that we modify, delete and/or correct their Information by contacting us here.  We will respond to your request within thirty (30) 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 verify the identity of the user and may decline to process requests that we reasonably believe are fraudulent, 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).

NEVADA PRIVACY RIGHTS

Nevada consumers have the right to submit an opt-out request to a website operator to not sell any “covered information” that the website operator has collected.  Covered information includes a consumer’s name, postal and email addresses, telephone number, social security number and includes the PII we have about our users as described above in “TYPES/CATEGORIES OF INFORMATION WE HAVE REGARDING USERS.”  If you are a Nevada consumer and you wish to exercise your right to request us to stop the sale of your PII, please submit your request by emailing [email protected] with the subject line “My Sea of Savings Nevada Privacy Rights” and include a request that we not sell any of your covered information.  Please allow thirty (30) days for a response.

CALIFORNIA PRIVACY RIGHTS

The California “Shine the Light” law permits users who are California residents to request information regarding our disclosure of their Information to third parties, including the categories of Information shared and a list of the names and addresses of third parties with whom the Information was shared.  If you are a California customer and would like to request that we provide this information, please submit a request by emailing us at [email protected] that you are exercising your “Sea of Savings California Privacy Rights under Ca. Civil Code Sec. 1798.33.”  Please allow thirty (30) days for a response.

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 the Shine the Light law, 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 his/her browser.

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 PII to only those persons who need access to perform their job or service, both internally and with our third-party service providers.

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.

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 PII, 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 PII in this different manner and we will only use your PII in this way where you opt-in to such use.  Users should periodically visit this Policy to review our current policies on our 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, please contact us here.