Privacy Policy | The Smart Wallet

Updated: May 21, 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 and disclosing information about our website users (“Information”).

By accessing and using one of our websites that we own and operate which links to this Policy and which offers content related to personal finance and may include samples, 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 as described in this Policy. If you do not understand and agree to how we collect and handle Information, please do not use or visit the Websites or participate in the Content.

TYPES/CATEGORIES OF INFORMATION WE MAY COLLECT REGARDING USERS

Here are the types and categories of Information that we may collect regarding users :

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 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:

Emails and other contacts received from users as part of customer service;
To the extent permitted by law, 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 such as device type(s), user agent data, referring URL(s), and IP address(es)through various technological means when users access and interact with our Websites;
From third parties including service providers who assist us in hosting the Websites, providing customer support; and

HOW WE MAY USE INFORMATION

We may use Information:

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;
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;
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 for the following purposes, for which we may be compensated:

To enable our Information verification and fraud detection vendors to perform contracted for services; and
With our interest-based advertising partners, as described further below.

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.

MINORS AND NON-CANADIAN RESIDENTS

The Websites are intended for use only by users who are of age of majority or older who are residents of Canada.

COOKIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY ANALYTICS

Our Websites use Cookies to determine whether users have previously visited our Websites. 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 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 .

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.

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.

ACCESS AND CORRECTION OF YOUR INFORMATION; WITHDRAWING CONSENT

The file containing your Information will be maintained on our servers or those of our service providers. We and our service providers may process your Information outside of Canada, including in the United States. While outside of Canada, Information will be subject to applicable foreign laws. Canadian and foreign laws may permit government and national security agencies to access personal information in certain circumstances.

You may request access to or correction of your Information in our control, or withdraw your consent to our collection, use and disclosure of your Information, by writing to us as described below. Your rights to access, correct and withdraw consent are subject to contractual and legal restrictions. We may take steps to verify your identity before providing access or making corrections.

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.

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 or disclose 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 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), or if you would like to request access to or correction of your Information, please contact us at [email protected] and input CA in the subject line.