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MoneyWellth Learning+ Privacy POLICY

Last Updated Nov 11, 2024

This is the Privacy Policy for the educational organization or other customer (“Customer”) that govern access to and use of the budget simulation and financial education course and related websites, products and services (collectively, the “Course”) provided by MoneyWellth, LLC (“MoneyWellth”, “us”, or “we”) and your interactions with MoneyWellth in any manner. By using the Course or interacting with MoneyWellth, you consent to this Privacy Policy and our privacy practices. If you do not agree with this Privacy Policy, do not access or use the Course.

Our Privacy Promise

The Course is a budget simulation and financial education course available for use by schools and other educational organizations located in the United States. MoneyWellth knows that maintaining your privacy is key to helping you learn about budgeting and managing finances. We want you to have a very clear understanding of how we collect, protect, and use your information. Here is a summary of our privacy promise to you:

  • The Course is private by default. Users cannot see one another’s Personal Data, and User Personal Information is only accessible by the User’s teacher or administrator.
  • MoneyWellth will only send you marketing messages as permitted by the recipient and applicable laws.
  • MoneyWellth will never sell your Personal Data.
  • We only work with service providers and affiliates that meet or exceed our own privacy standards.
  • Any reporting we do on trends or content consumption is done using de-identified data or in the aggregate. User Personal Data is 100% anonymous in these reports.
  • You have the option to download and use the MoneyWellth App separate from your use of the Course. The Course is provided under its own Privacy Policy and Terms of Use.
  • The Course is designed for users located in the United States.
  • MoneyWellth welcomes your requests to exercise your applicable privacy rights.

Please note: MoneyWellth is not a financial institution or professional advisor or service provider. We are not subject to the Gramm-Leach-Bliley Act, which is a federal law that applies to Personal Data processed in connection with providing personal or household financial services. You are encouraged to read this Privacy Policy carefully to fully understand our privacy practices. This Privacy Policy is part of and governed by the MoneyWellth Learning+ Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. Any terms used in this Privacy Policy without being defined have the meaning given in the Terms. If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@moneywellth.com.  

  1. YOUR PERSONAL DATA

As used in this Privacy Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:

  • Identifiers (e.g., name, email, telephone number, address, username);
  • Commercial information (e.g., products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies);
  • Educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
  • Employment information (e.g., current or past employment);
  • Sensitive information (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
  • Legally protected information (e.g., race, citizenship, marital status, sex);
  • Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
  • Internet activity (e.g., browsing history; content interactions); and
  • Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behaviors, attitudes, intelligence, and aptitudes.

The Course will not collect all of the categories or types of Personal Data. Not all information about a person qualifies as Personal Data under privacy laws. For example, publicly available information, aggregated data, and anonymized information are often exempt from legal rights and protections.    

  1. STUDENT PRIVACY

The Course is available to Users who are at least 12 years old and who are granted access through a MoneyWellth Customer that is contracted to use the Course, in most cases the User’s school or other educational organization. By accepting the Terms and providing the Course to Users, the Customer consents to this Privacy Policy on behalf of its student and child Users, teachers, administrators, and other end users who access the Course through Customer. Customer is responsible for determining and obtaining any additional consent for students and children, including parental consent, that may be required under the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), or other applicable privacy laws. The Customer, not MoneyWellth, is responsible for providing the Course in compliance with these laws and for obtaining any legally required User, parent or guardian consent. 

  1. COLLECTION AND USE OF PERSONAL DATA

MoneyWellth will only collect and use your Personal Data with your consent as informed by this Privacy Policy and freely given by you, if we have a legitimate interest, or as authorized or required by law. We only collect, use, retain, and disclose Personal Data as is adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to provide the Course. We may also process Personal Data for other purposes that we disclose to you or as compatible with the context of how we collected your Personal Data. In the preceding 12 months, the Course has collected Personal Data in the categories of identifiers, educational information, and internet activity. We collect this information from sources and for purposes described below:

  1. User Accounts. Users submit their name, username, email address, and password (“Account Details”) to create an account to access the Course. A student’s User account allows the User to use the financial simulations available through the Course. The Course is a simulation only and does not collect or process any student personal information or financial information. A student Users’ Personal Data and Course data is only viewable by that student’s teacher or administrator for the Course.
  2. Admin Site. Teacher and administrator Users will have access to a dedicated administrator website hosted at app.moneywellth.com (the “Admin Site”). Teachers and administrators create and access their User accounts by submitting Account Details on the Admin Site. They can also use the Admin Site to manage and facilitate use of the Course by Customer’s Users, classes, and schools and load student User Account Information for assessment and grading purposes.
  3. AI Features. Certain Course features may be powered by artificial intelligence technology (“AI Features”). If you interact with AI Features, we will collect any Personal Data that you choose to include in a prompt or other input (“Inputs”) to the AI Feature. We will only use your Inputs to generate the requested content outputs and to provide and improve the AI Feature or the Course. By interacting with an AI Feature, you consent to this collection of your information for these purposes.
  4. Customers. The educational organization or other Customer that grants you access to the Course may choose to input User Personal Data to the Course as part of their own privacy practices. We collect this information to achieve our legitimate interest of meeting our contractual obligations to the Customer and we only use it for that purpose. Please contact the Customer if you have questions.
  5. Your interactions with the Course, with a legitimate interest. MoneyWellth’s mission is to expand access to financial education and resources so that every individual can live a life free of financial worry. A key part of achieving this mission is providing Customers and their Users with access to rich financial wellness content through the Course and our other products and services. MoneyWellth may collect non-identifying usage information from your interactions with the Course, such as the simulations run and outcomes, content viewed, and session details. We collect this information to achieve our legitimate interest of providing and improving MoneyWellth products and services.
  6. Your communications with MoneyWellth, with your consent. If you interact with MoneyWellth via social media or contact us in any way, we will collect identifiers like your name and email address, along with any other Personal Data that you choose to include in your communication to us. We use this information to respond to your inquiries and to send you marketing messages according to your stated communication preferences.

In addition to the specific uses described above, we reserve the right to use your Personal Data to (i) protect your privacy and the privacy of others; (ii) comply with a law, regulation, legal process, or order; (iii) monitor your compliance with this Privacy Policy and your agreements with us; (iv) if we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to MoneyWellth, or to others; or (v) for any other purpose with your consent. MoneyWellth will not collect additional categories of Personal Data or use your Personal Data for purposes that are incompatible with the purpose stated at the time of collection without first notifying you by updating this Privacy Policy or through other means.

  1. CUSTOMER PRIVACY PRACTICES

The Customer that grants you access to the Course may collect and process Personal Data about you as part of their own privacy practices or legal requirements. MoneyWellth has no control over the type or scope of Personal Data collected, used, or stored by Customers. Personal Data processed by Customers belongs to the Customer and is collected, processed, stored, shared, and disclosed by each Customer according to its own terms of use and privacy policies. Personal Data processed by Customers is not subject to this Privacy Policy, and MoneyWellth is in no way responsible for such information.

  1. RETENTION OF PERSONAL DATA

MoneyWellth retains data only as long as it is necessary and relevant to our operations. for example, Account Information is retained while the User account is active. When data is no longer needed, we securely delete or deidentify it. MoneyWellth reserves the right to retain Personal Data for longer periods if necessary to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms and conditions, or take other actions permitted by law.

  1. DISCLOSURE OF PERSONAL DATA

To provide the Course, we sometimes need to disclose certain Personal Data to trusted third parties as described in this section. In the preceding 12 months, MoneyWellth has disclosed Personal Data in the categories of identifiers, educational information, and internet activity with third parties for a business purpose, including:

  1. Our Service Providers. MoneyWellth uses service providers like data analytics companies, payment processors, and email and data hosting providers. Our service providers may require access to certain Personal Data to perform their contractual obligations to MoneyWellth. Our service providers are contractually required to protect your Personal Data, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Data. The type of information that we provide to a Service Provider will depend on the service that they provide to us.
  2. Law Enforcement. We reserve the right to disclose your Personal Data to law enforcement or other government agencies as permitted or required by law.
  3. Other Third Parties. MoneyWellth may disclose your Personal Data to other third parties in certain circumstances as permitted by applicable law, for example: (i) if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); (ii) to comply with a legal requirement or a court order; (iii) when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; (iv) to exercise or defend our legal claims; or (v) for any other reason with your consent.
  4. Aggregated and Deidentified Information. MoneyWellth reserves the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.
  1. YOUR PRIVACY CONTROLS

MoneyWellth gives you the ability to directly control the Personal Data we collect and hold about you through the methods described below. If you need assistance, please visit the Help Center or contact learning@moneywellth.com.

  1. Your Account. You have the option to access, correct or update, or delete the Personal Data in your account profile by logging into your account and saving your desired changes.
  2. Text/SMS Messages. If you opt-in to text/SMS notifications, MoneyWellth may use your Personal Data to send you text/SMS messages containing information about the Course or other matters related to the Course through Braze. You may cancel text/SMS messages at any time by replying STOP or UNSUBSCRIBE to any of these text messages, but doing so may limit or eliminate your access to your App account. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
  3. Device Settings. You can control the data collected via cookies and related technologies by adjusting your device settings.
  4. Emails. We may send you informational or support emails related to your use of the Course. Some emails may be generated through our use of Braze services. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails or send a request to learning@moneywellth.com. Note that if you opt out of marketing communications, we may still send you non-promotional communications related to your use of the Course.
  5. Block Location Tracking. You can stop all collection of information via an app by uninstalling the Course. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the Course or withdrawing your consent through your device settings.
  6. Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.
  7. Privacy Requests. If you are a User and you wish to exercise your privacy rights or have questions about the Course, please contact your educational organization or other Customer that granted you access to the Course. Otherwise, you can contact MoneyWellth at privacy@moneywellth.com. If you submit a privacy request to us, we will relay it to the Customer. In any case, MoneyWellth may only legally fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
  1. YOUR PRIVACY RIGHTS

Depending on where you reside, you may be entitled to additional controls over your Personal Data. This section provides courtesy information about privacy rights that may be available to you. Please contact Customer that granted you access to the Course with any questions about your privacy rights.

In the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing general consumer privacy rights. For example, California, Colorado, Connecticut, Iowa, Nevada, Utah, Virginia, and other states require companies to inform consumers about their privacy rights and provide a method to exercise those rights. MoneyWellth will respond to and fulfill your request to the extent required by applicable law. MONEYWELLTH IS CURRENTLY EXEMPT FROM CERTAIN STATE PRIVACY LAWS. Depending on where you live, you may be entitled to some or all of the following privacy rights.

  1. Right to Know. You have the right to know how we treat your Personal Data. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.
  2. Right to Access. You have the right to request confirmation that we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and readily usable format. Please note that MoneyWellth may be prohibited by law from disclosing certain pieces of Personal Data, and we may be limited in the number or frequency of requests we must fulfill. 
  3. Right to Correct. You have the right to request that we correct inaccurate Personal Data about you on our systems. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
  4. Right to Deletion. Upon your request and where we are required to do so by law, we will delete your Personal Data that we collected and retained, with certain exceptions. We may permanently delete, deidentify, or aggregate the Personal Data in response to a request for deletion.
  5. Right to Disclosure. You may have the right to request that we disclose information to you about our collection and use of your Personal Data, such as: (i) the categories of Personal Data we have collected about you; (ii) the categories of sources for the Personal Data we have collected about you; (iii) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (iv) the categories of third parties with whom we share that Personal Data; and (v) if we sold or shared your Personal Data under the CCPA, two separate lists stating: (A) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (B) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.  
  6. Limited Use and Disclosure of Sensitive Personal Data. MoneyWellth does not seek to collect sensitive Personal Data about any individual, and in no case do we disclose any sensitive Personal Data for inferring characteristics about you or otherwise use your sensitive Personal Data without your consent. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to opt-out or limit our use and disclosure of sensitive Personal Data.
  7. No Selling or Sharing. MoneyWellth does not sell your Personal Data or share your Personal Data with third parties for cross-contextual advertising purposes.
  8. No Profiling. MoneyWellth does not process your Personal Data to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you.
  9. Health Data Rights. The Course does not collect any health data.
  10. Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.
  11. Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.

Only you or someone legally authorized to act on your behalf may make a verifiable Privacy Request related to your Personal Data. You may also make a verifiable privacy request on behalf of your minor child. You may designate a third party to exercise your rights – an authorized agent – however we will require written proof of the authorization and potentially proof of your identity.

  1. DATA TRANSFER

The Course is owned and operated in the United States and is only permitted for use by Users living in the United States. We do not warrant that the Course is appropriate or authorized for use in any other jurisdictions. If you use the Course from outside of the United States, you do so at your own risk and the Personal Data we collect about you will be transferred to our servers in the United States and maintained there indefinitely.

  1. DATA SECURITY

MoneyWellth works to protect your Personal Data by using reasonable and appropriate technical, administrative, and physical security practices and procedures to help protect Personal Data from unauthorized or illegal access, destruction, use, modification, or disclosure. We have implemented and maintain internal policies to govern the collection, processing, access, and handling of data. Our security measures are appropriate to the volume, scope, and nature of the Personal Data processed and designed to meet our duty of care with respect to your Personal Data.

MoneyWellth encrypts user data using industry-standard Transport Layer Security (TLS) technology and stores all data on secure cloud servers. We also perform regular scans of all systems to detect and remedy vulnerabilities on MoneyWellth information systems. MoneyWellth personnel responsible for handling user inquiries are informed of applicable privacy law requirements.

Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Data for improper purposes. The security of your Personal Data also depends on how you use the Course. MoneyWellth encourages you to take steps to safeguard your Personal Data by signing off your device after use and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.

  1. THIRD-PARTY SERVICES

This Privacy Policy applies only to information collected by MoneyWellth when you use the Course. The Course may include or provide links to third-party content or services, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third parties. MoneyWellth is not responsible for the privacy practices of any third party, and your access to and use of third-party websites is governed by the privacy notices of those websites.

  1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes to how we treat your Personal Data, we will post the revised Privacy Policy on this page. The date that this Privacy Policy was last revised is identified at the top of the page. Your continued use of the Course after we make changes is deemed to be your acceptance of those changes. You are responsible for periodically visiting this Privacy Policy to check for any changes.