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Interested in becoming a financial innovator on Savvy Labs? Tell us a bit about yourself.

Privacy Policy

Last Updated and Effective October 11, 2023.

This Privacy Policy sets forth the privacy practices of Savvy Labs Inc. (“Savvy Labs,” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of Personal Information, including, but not limited to, Personal Information collected through each of our website(s) our mobile application(s) and any related URLs (each and collectively, as appropriate, the “Site”), how such Personal Information is used, and the circumstances under which such Personal Information may be shared and disclosed. This Privacy Policy is incorporated into, and is part of, our Terms of Use which govern your access to the Site and/or your use of the Site and of the Content (as defined in the Terms of Use) and the services made available on or through the Site. This Privacy Policy constitutes a legally binding agreement between you and Savvy Labs that conditions your use of the Site, where and as permitted by applicable law.

1. Personal Information We Collect

When you visit the Site and during our ordinary business activities, Savvy Labs asks you to voluntarily provide certain nonpublic personally identifying information (“Personal Information”) in order to help us create an account for you, manage our relationship with you, and to provide the Site’s features. The Personal Information we may collect from you includes your name, date of birth, residential or business address, mobile telephone number, and e-mail address. You have the right to refuse or withdraw consent to collection of Personal Information. Please note, however, that providing less information might ‒ and will ‒ limit your ability to access all of the Site’s features.

Savvy Labs also captures the following information through our Site:

User device type/year/make/model;
Viewed pages;
IP address;
Type of web browser;
Operating system;
Time and duration of Site visits;
Crash logs; and
Other information relating to Site usage.

2. Sources of Personal Information

We may collect Personal Information from:

Your communications with us;
Your transactions with us;
Services providers;
Affiliates;
Government entities; and
Other tools used as a means to service your account

3. How We Use Personal Information

We use Personal Information for the following business purposes:

Providing our products and services;
Processing your requests and inquiries;
Offering new products and services;
Processing transactions;
Periodic support and updates;
Marketing communications;
Account maintenance;
Confirming your identity;
Improving the Site or for other research and development purposes;
Protecting the security and integrity of the Site;
Preventing or investigating fraud or other unlawful activity, and detecting security incidents; and
Complying with and enforcing applicable legal and regulatory requirements.

4. How We Share Personal Information

Your privacy is important to us. Savvy Labs does not disclose any Personal Information except to third parties for website maintenance, upgrades, new releases, and/or data analytics, and to government agencies for tax purposes. Savvy Labs may also share Personal Information with its affiliated entities, including parent companies and subsidiaries. If Savvy Labs participates in a merger, stock purchase, asset purchase, or other acquisition, it may be required to share customer account information, which may include Personal Information, with the purchaser or surviving entity. Savvy Labs does not sell any Personal Information to third parties. Your Personal Information collected through our Site will be deleted once it no longer serves the above-mentioned purposes unless we are obligated by law to keep archival copies of your Personal Information.

5. How We Protect Personal Information

Savvy Labs seeks to carefully safeguard Personal Information. We use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to Personal Information only to those employees and personnel who must use Personal Information to provide our products or services.

6. Notice to Users in the Event of a Security Breach

If a user’s Personal Information is compromised as the result of a breach of security, we will use commercially reasonable efforts to attempt to notify affected users directly, or via the Site, of the breach if we determine that the information is sensitive, in accordance with this Privacy Policy and the Terms of Use, or as otherwise required by applicable law.

7. Use of Cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to collect and/or store information on your computer. Such text files and images are used to support the operation, and to enhance the functionality, of our digital offerings and for the technical convenience to store information on your computer. We may use information stored in such text files and images to customize your experience on our Site, monitor use of our Site and for anonymized analytics purposes. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts or use all features of our Site. You can disable cookies from your computer system by following the instructions on your browser or at http://www.allaboutcookies.org/. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our Site.

8. If you are a California resident, please read our Privacy Notice for California Consumers below:

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), is only relevant to residents of California, and applies only to the collection or use of “personal information” or “sensitive personal information” that is subject to the CCPA/CPRA.

Please note that the CCPA/CPRA does not apply to personal information collected or processed by financial institutions (like Savvy Labs) pursuant to the federal Gramm-Leach-Bliley Act (GLBA), the Fair Credit Lending Act, and other federal privacy rules and regulations. Consequently, the CCPA/CPRA does not apply to most of the information that Savvy Labs collects. However, where we collect information for some purpose other than providing a financial product or service, such as when we collect information for marketing purposes, our information collection must meet the requirements of the CCPA/CPRA.

Information We May Collect. In the past twelve (12) months, we may have collected some of the following categories of sensitive personal information or other personal information about California consumers:

Category	Examples
A. Identifiers	A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers.
B. Other personal information categories, as listed in the California Customer Records statute	A signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, citizenship, marital status, sex, veteran or military status.
D. Commercial information	Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information	Although Savvy Labs does not collect these, phone carrier may when User accesses FaceID functionalities.
F. Internet or other similar network activity	Limited to activity on consumer interactions with website and application.
G. Geolocation data	Physical location or movements.
H. Professional or employment-related information	Current or past job history or performance evaluations.
I. Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf.
J. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
K. Sensitive personal information	Personal information that reveals or involves: A consumer’s social security, driver’s license, state identification card, or passport number. A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. The processing of biometric information for the purpose of uniquely identifying a consumer.

We do not knowingly collect, solicit or sell personal information from anyone under the age of sixteen (16).

Purposes for Collection and Use of Personal Information. We may collect, retain or use the sensitive personal information and other personal information we collect as reasonably necessary and proportionate to fulfill the intended features of our Site, including for one or more of the following purposes:

Providing you with information about our products and services;
Providing performance and other updates;
One or more of the following business purposes:
- Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
- Legal compliance;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Debugging;
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our services; and
- Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer.

Sharing Personal Information. We may disclose sensitive personal information and other personal information in one or more of the categories identified above to:

Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus;
Affiliates;
Business partners;
Legal or government regulatory authorities as required by applicable law; and
In connection with a potential business transfer or in order to service your account under agreed terms.

In the past twelve (12) months, we have not sold any sensitive personal information or any other personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers. The CCPA/CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:

The right to request (a) the categories and specific pieces of sensitive personal information and other personal information we collect about you, (b) the categories of sources from which we collect your sensitive personal information and other personal information, (c) our business or commercial purposes for collecting, selling or sharing your sensitive personal information and other personal information, (d) the categories of personal information disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose, (d) the categories of your sensitive personal information and other personal information (if any) that we have either sold or shared, and (e) the categories of third parties to whom personal information has been sold or shared;
For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past twelve (12) months and the names and addresses of those third parties;
The right to request that we delete the personal information we have collected from you or maintain about you;
The right to opt out of any sale(s) (if any) of your personal information; and
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA/CPRA.

You may designate an authorized agent to make a CCPA/CPRA request on your behalf. In such a case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf, in addition to other eligibility requirements. In addition, we will ask you to (1) verify your identity directly with us in the manner described above and (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.

9. Notice for Residents of the European Economic Area and United Kingdom

Savvy Labs does not currently offer its products to natural persons resident in the European Union, Switzerland or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation or similar laws in Switzerland or the United Kingdom (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR.

10. International Visitors

Savvy Labs and its servers are located in the U.S. Our services are directed toward the U.S. market, and our Privacy Policy complies with applicable U.S. laws. If you are an international visitor, you should note that by providing your personal information on or through the Site, you are: (1) consenting to the transfer of your personal information from regions outside the U.S. to the U.S., which may not have the same data collection and protection laws as the country in which you reside; and (2) consenting to the use of your personal information in accordance with this Privacy Policy.

11. Children’s Privacy

This Site is not intended for, or designed to attract, children under the age of thirteen (13). Consequently, we do not intentionally gather information from individuals who are under the age of thirteen (13). Upon notification that a child under thirteen (13) has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records.

12. Updating Your Personal Account Preferences and Disabling Your Account

To update your Personal Information, adjust/cease the frequency by which you receive Savvy Labs communications, or disable/delete your account, please contact us at support@savvylabs.com

13. Changes to this Policy

We reserve the right at any time to update this Privacy Policy without any notice to you. If we update the Privacy Policy, we will indicate at the top of the page the date the Privacy Policy was last updated. Any such updates will be effective immediately upon posting on the Site. Each time you use the Site, the current version of this Privacy Policy will apply. You understand and consent that your continued use of the Site after we have made any such updates constitutes your acceptance of the most current Privacy Policy, as amended. You can always refuse to accept the updates to our Privacy Policy by terminating your use of the services.

14. Contact Us

If you have any questions or comments about this Privacy Policy, please feel free to contact Savvy Labs at support@savvylabs.com or (240) 366-2924.

California residents, you may submit requests relating to your exercise of rights under the CCPA/CPRA to us: Via phone (888) 803-3368; or email support@savvylabs.com

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum, your telephone number and mailing address. If we are unable to verify your identity, we will need to deny your request.