Privacy Policy

Why?

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Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

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What?

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The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number
• Income
• Assets
• Risk tolerance
• Wire transfer instructions
• Date of birth
• Account numbers
• Phone Number
• Email Address
• Names
• Job titles

When you are no longer our customer, we continue to share information about you as described in this notice.

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How?

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All financial companies need to share customer's personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers personal information; the reasons Savvy chooses to share; and whether you can limit this sharing.

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Reasons we can share your personal information

For our everyday business purposes - such as to process your transactions, maintain your accounts(s) or respond to court orders and legal investigations.

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Savvy Share? - Yes

Can you limit this sharing? - No

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For our marketing purposes - to offer our products and services to you

Savvy Share? - Yes

Can you limit this sharing? - Yes

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For joint marketing with other financial companies

Savvy Share? - No

Can you limit this sharing? - We don't share

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For our affiliates' everyday business purposes - information about your transactions and experiences

Savvy Share? - Yes

Can you limit this sharing? - No

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For our affiliates' everyday business purposes - information about your creditworthiness

Savvy Share? - No

Can you limit this sharing? - We don't share

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For nonaffiliates to market to you

Savvy Share? - No

Can you limit this sharing? - We don't share

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For Text Messages

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Opt-Out and Support Options 

You can unsubscribe from text messages at any time by replying with 'STOP.' Once we receive your request, you will be immediately removed from our messaging list and will no longer receive texts from us. A confirmation message will follow to confirm your successful unsubscription.

Wireless Carrier Rates and Services 

Wireless carrier message and data rates may apply and vary. Wireless carriers are not liable for delayed or undelivered messages. 

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Confidentiality 

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the stated categories in this privacy policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. However, for operational needs, we may share your name and mobile number with trusted service providers who support the delivery of our SMS communications. These providers are authorized to use your information solely to perform the services they offer on behalf of Savvy.

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SMS Terms & Conditions
By subscribing to Savvy, SMS services, you agree to receive text messages from us. Savvy will send SMS messages to communicate with clients on the status of accounts they have requested to provide a better overall customer experience. For HELP, please contact us. To opt-out of receiving messages, reply with “STOP” at any time. Message frequency may vary. Standard message and data rates may apply.

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To limit our sharing

Email: hello@savvywealth.com

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

How does Savvy protect my personal information?

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To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

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‍How does Savvy collect my personal information?

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We collect your personal information, for example, when you

• Open a new brokerage account
• Seek financial advice
• Make deposits or withdrawals from your investment account
• Tell us about your investment or retirement portfolios
• Provide account information
  

We also collect your personal information from other financial institutions to assist in serving you.  

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What happens when I limit sharing for an account I hold jointly with someone else?

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Your choices will apply to everyone on your account - unless you tell us otherwise.

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Why can't I limit all sharing?

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Federal law gives you the right to limit only

• sharing for affiliate's everyday business purposes-information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Affiliates

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Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Savvy does not have any affiliates.

Nonaffiliates

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Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Savvy does not share with nonaffiliates so they can market to you.

Joint Marketing

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A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Savvy does not jointly market.

Retention of Data

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We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

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Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Savvy will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

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Disclosure of Data

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We may disclose personal information that we collect, or you provide:

• Disclosure for Law Enforcement.
  Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

• Business Transaction.
  If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

• Other cases. We may disclose your information also:

1. to our subsidiaries and affiliates;
2. to contractors, service providers, and other third parties we use to support our business;
3. to fulfill the purpose for which you provide it;
4. for the purpose of including your companys logo on our website;
5. for any other purpose disclosed by us when you provide the information;
6. with your consent in any other cases;
7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

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Security of Data

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The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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Your Data Protection Rights Under General Data Protection Regulation (GDPR)

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If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. - See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at hello@savvywealth.com.

In certain circumstances, you have the following data protection rights:

• the right to access, update or to delete the information we have on you;
• the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
• the right to object. You have the right to object to our processing of your Personal Data;
• the right of restriction. You have the right to request that we restrict the processing of your personal information;
• the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
• the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

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Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

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CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The laws reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. - See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/

According to CalOPPA we agree to the following:

• users can visit our site anonymously;
• our Privacy Policy link includes the word "Privacy", and can easily be found on the page specified above on the home page of our website;
• users will be notified of any privacy policy changes on our Privacy Policy Page;
• users are able to change their personal information by emailing us at hello@savvywealth.com.

Our Policy on "Do Not Track" Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

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Service Providers

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We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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Analytics

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We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

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CI/CD tools

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We may use third-party Service Providers to automate the development process of our Service.

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GitHub

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GitHub is provided by GitHub, Inc.

GitHub is a development platform to host and review code, manage projects, and build software.

For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

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Behavioral Remarketing

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Savvy uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

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Twitter

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Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

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Facebook

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Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

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Payments

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We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

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PayPal or Braintree:

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Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

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Stripe:

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy

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Links to Other Sites

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Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

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Children's Privacy

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Our Services are not intended for use by children under the age of 18 ("Child" or "Children").

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

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Changes to This Privacy Policy

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We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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