Privacy Policy

Last update on 4/5/2021

This Privacy Policy discloses the privacy practices of www.smartandfinance.com (“Website”).  It explains how we collect, store, use and share personal information provided by you on our Website.  By accessing and using our Website, you agree that our collection, storage and use your personal information is governed by this Privacy Policy and the posted Terms of Use.  If you disagree with the way we collect and process personal information, please do not use our Website. 

1. INFORMATION WE COLLECT.

1.1. We collect the following categories of information about you when you visit and use our Website or participate in our Surveys or other promotions:

(a)  Personal Information.  Is information that can be used to identify you.  This may include your name, address, telephone number(s), mobile numbers and email address, employment status or other unique information you provide to us during the registration process, through our online surveys or through the course of communicating with us about the products and services provided on our Website.  

(b) Demographic Information.  Is information that may or may not be unique to you in the sense that it refers to selected population characteristics.  Such information includes, but is not limited to, zip code, mobile phone carrier, age, gender, salary range, education, marital status, occupation, military service, industry of employment, personal and online interests.  When we can identify you personally, through the use of this information, it becomes Personal Information.

(c) Behavioral Information.  Is information which is automatically collected when you use our Website through technology on our website.  This includes the areas of our Website that you visit, what services or products you access or order, information about your computer hardware and software, including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet, and other websites you have visited.  When we can identify you personally, through the use of this information, it becomes Personal Information.  

(d) Third-Party Information.  Is information about you that we acquire from a third-party which may include personal, demographic, and behavioral information.  This includes, but not limited to, first party cookies, third-party cookies, anonymous cookies, persistent identifiers, email opt-in records and search engine keywords.  We may or may not have access or control over these cookies and other tracking devices as some are used by third-parties including advertisers and networks, internet service providers, data analytics providers or social networks and platforms.  We have no responsibility or liability for the policies and practices of third-parties.  When we can identify you personally, through the use of this information, it becomes Personal Information. 

(e) Web Technology Information.  Is information we automatically collect from you when you visit our Website.  This includes internet protocol (“IP”) addresses, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  This information is collected from the use of cookies, Web beacons or JavaScript.  

(f) No Information Collected from Children.  We will never knowingly collect any Personal Information from children under the age of 16.  If we obtain actual knowledge that we have collected Personal Information about a child under the age of 16, that information will be immediately deleted from its database.  Because it does not collect such information, we have no such information to use or to disclose to third-parties. 

2. COLLECTION OF INFORMATION THROUGH TECHNOLOGY.

2.1. Generally, we as well as third-party vendors, networks, ISP(s) and supporting advertisers, use technologies such as cookies, web beacons, and java scripts.  These technologies collect internet protocol (“IP”) addresses, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  This information is used to analyze trends, administer our Website, track users’ movements through our Website and gather demographic information about our user base, as a whole.  We may receive reports or logs based on these technologies on an individual or aggregated basis.  California residents have the right to know if we respond to do not track signals or cookies.  We do not respond to such signals or cookies. 

(a) Cookies.  “Cookies” are a feature in your browser software.  If enabled, cookies store small amounts of data on your computer about actions you take on the pages of our Website.  Cookies assist us in tracking which of our features you visit most often, and what content you viewed on past visits.  We may use cookies to keep track of the number of return visits, accumulate and aggregate statistical information generally pertaining to our Website, and deliver specific content to you based on your past viewing history.  You can disable cookies, although our Website may not function properly for you.  Your browser preferences can be modified to accept or reject all cookies or request a notification when a cookie is set.  You may read more about cookies at http://cookiecentral.com/faq/.

(b) Third-Party Cookies.  We allow third-party vendors and advertisers to set their own cookies on and through our Website.  We have no control over their practices and are not responsible for their technology or tracking.  We encourage you to review the policies of such persons or entities on their websites.  We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history.  To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en.  We also participate in all of Google’s Analytics Advertising.  This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting.  Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie.  To opt-out please see https://tools.google.com/dlpage/gaoptout/.  We also use Google Analytics which is an analysis service.  Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services.  You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/. 

(c) Social Media Cookies.  Third-party social media features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly.  Social media features are either hosted by a third-party or hosted directly on our Website.  Your interactions with these features are governed by the Privacy Policy of the company providing it.

(d) Web Beacons.  We use electronic images known as Web Beacons (sometimes called single-pixel gifs, clear gifs, or action tags) which allow us to collect information about your visit to our Website, measure and improve the effectiveness of advertisements and track delivery of advertising.  Web Beacons collect only a limited set of information including a cookie number, time, and date of page view, as well as a description of the page on which the Web Beacon resides.  We may also use Web beacons in email messages sent to you.  This allows us to determine if you opened or acted upon the email message.  Because Web beacons are the same as any other content request, you cannot opt-out or refuse them.  However, they can be rendered ineffective by either opting-out of cookies or changing the cookie setup in your browser.

(e) JavaScript.  We may also use JavaScript.  JavaScript is a computer language that enhances the functionality of websites, particularly with respect to pictures.  We use it to analyze and improve our Website’s functions.  You may deactivate JavaScript through your browser settings or activate it the same way.  If you disable JavaScript, you will not be able to use some of the functions of our Website.

3. HOW WE USE INFORMATION COLLECTED. 

3.1. Providing Services and Products.  We use the information we gather on our Website to provide you with the services and or products you have requested.  This may include passing your information on to a third-party to provide such services or products.  We do not control the privacy practices of third-parties.  If you have any questions or wish to remove your information from the third-party databases, you will need to contact that party directly.  

3.2. Improving Our Website.  We use the information we gather to respond to any inquiries you make, to operate and improve the functionality of our Website, and deliver the products and services advertised on our Website.  We use the same for testing, research, analysis and product or marketing development.  Our services include the display of personalized products, content, and advertising, relating to your experience and interests.  This includes maintaining and improving the safety, security and integrity of our Website, databases, and technology assets.

3.3. Promotions and Communications with You.  We use the information we gather to promote our and third-party services and products to you that might be of interest to you.  Other parties will use the information we gather to provide you with their services and products.  We also use the information we have gathered to respond to your inquiries, concerns, or requests.  If your request is made through a third-party, we may use the information to respond to their requests.

4. DISCLOSURE AND SHARING OF INFORMATION TO OTHERS.

4.1. Product and Service Delivery.  All information, including the personal information, may be used for any purpose we deem appropriate and may be given or disclosed to our affiliates, partners, vendors, advertisers, licensees, and third-parties.  You agree that when you disclose personal information (name, email address, zip code) on or in connection with your use of our Website, Surveys or promotions, such information can be monitored, collected used and shared by us or others and may result in unsolicited messages from other users or third-parties.

4.2. Website Functionality.  We share all categories of information set out in this policy with third-party Service Providers we employ to perform technical or analytical functions on our behalf.  Examples include third-parties who host our Website, analyze our data, provide marketing assistance, and provide customer service.  

4.3. Third-Party Products and Services.  We share all categories of information set out in this Privacy Policy with third-parties including affiliated entities, service providers, and data aggregators with your information with third-parties who will provide you with their opportunities, products, or services.  

4.4. Anonymized information.  We share aggregated anonymous information about you, combined with Service Providers and other third-party vendors and clients for their analysis, promotion, and marketing.  This includes demographic information and behavioral information.

4.5. Legal Process.  We disclose your information if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. 

4.6. Acquisition or Merger.  We may disclose and transfer your information to a third-party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.  In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of, such information in a transaction approved by the court. 

5. THIRD-PARTY COLLECTION AND USE OF INFORMATION.

5.1. Third-parties collect and use information about you on or through our Website in the following way:

(a) Advertisers.  Advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own cookies, Web beacons, and other technology, to collect information about you.  We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you. 

(b) Hyperlinks.  Our Website and email messages sometimes contain hypertext links to websites owned by third-parties.  We are not responsible for the privacy practices or the content of such other websites.  These links are provided for your convenience and reference only.  We do not operate or control any information, software, products, or services, available on these third-party websites.  The inclusion of a link on our Website does not imply any endorsement of the services, products or website, or its sponsoring organization. 

(c) Analytics.  As described above, we use Service Providers to monitor, analyze and report on the traffic to, from and within our Website and email messages. 

(d) Disclaimer.  Our Website offers links to other websites, including links embedded in advertisements and links to various news sources not under our control.  These other websites may have information policies and practices different from ours.  In addition, certain companies associated with our Website have their own privacy policies.  We do not own or control such companies and websites and are not responsible for the privacy policies or practices or the content of websites.

5.2. Storage and Security of Information.  We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties.  Although these measures are typically effective, use of the Internet and related computer systems is inherently vulnerable to unauthorized access.  No guarantee can be given that all information you provide to us will not be accessed by unauthorized persons.  Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure.  Any transmission of data to use or through our Website is at your own risk. 

5.3. Changes to Privacy Policy.  We reserve the right to make material changes to the substance of this Privacy Policy.  We will post those changes through a prominent notice on the website, so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

5.4. Opting Out.  If, at any time, you prefer not to receive email marketing information or newsletters from us, simply click the unsubscribe link at the bottom of each email.  

6. CALIFORNIA RESIDENTS RIGHTS.

6.1. Shine the Light.  California’s Shine the Light Law provides California residents with the right to receive, once a year, information about third-parties by category with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared.  California residents also have the right to know if we respond to do not track signals or cookies.  We do not respond to such signals or cookies.  California customers may request further information about our compliance with this law by sending us an email at [email protected].  Please note that we are only required to respond to one (1) request per customer each year, and we are not required to respond to requests made by means other than through this email address.

6.2. California Consumer Protection Act of 2018.  The California Consumer Protection Act (“CCPA”) provides California residents with specific rights regarding their personal information.  As described above, we collect the following categories of personal information about California residents, as defined by the CCPA: Inferences, Identifiers, Commercial Information, and Electronic Network Information.  We collect these categories of personal information for the purposes described above and we may share personal information with our service providers and contractors, as well as other third-parties, as outlined above.  

Under the CCPA, California residents have certain rights to their information listed below.  However, the right to access or delete are not absolute and may be subject to certain exceptions.  For example, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information or of our business systems network.

(a) Right to Know About Personal Information Collected, Disclosed, or Sold.  California residents have the right to request that we disclose to them: (i) the categories of personal information we have collected about them; (ii) the categories of sources from which personal information is collected; (iii) the business or commercial purpose for the information collection; (iv) the categories of third-parties with whom we have shared personal information; and (v) the specifics of personal information we hold about an individual.

(b) Right to Request Deletion of Personal Information.  California residents have a right to request the deletion of their Personal Information if we have collected or maintained it in the past twelve (12) months, unless the personal information is necessary for us or our service providers to complete a transaction for which the personal information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer; detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible); debug to identify and repair functionality errors; exercise or ensure the right of another to exercise free speech or another legal right; comply with the California Electronic Communications Privacy Act (“ECPA”), which compels the production of or access to electronic communication information or electronic device information with a search warrant; engage in research in the public interest where the consumer has provided informed consent; comply with a legal obligation; or otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it.

(c) Right to Opt-Out of the Sale of Personal Information.  You have the right to opt-out of any sale of your Personal Information by us.  If you are requesting a product or service, this is an exemption from this right, and we will process your request.  However, you have the right to cease all further sale of your Personal Information.

(d) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.  You have a right not to receive discriminatory treatment by us for the exercise of these privacy rights conferred by the CCPA.  As such, we will not deny you goods or services, charge you different prices or rates for goods or services, or deny you discounts or other benefits; nor will we provide you a different level or quality of goods or services or recommend a different level or quality of goods or services.

6.3. Contact us.  For more information or with any questions either through our California Consumer Portal or by email at [email protected] or use this link to exercise any of these rights: 

6.4. Response Time and Response Format.  We make every effort to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons why we cannot comply with a request, if applicable.  We will provide our response in a manner that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance to you.