Date Last Revised: October 21, 2014
The Lampo Group (we, Lampo) care deeply about our relationship with you and are committed to maintaining the confidentiality, integrity, and security of personal information you provide when using our services and products. This Privacy and Security Policy explains how we protect personal information provided through www.everydollar.com (the “Site”) and how we use that information in connection with our service (the “Service”) offered through the Site. “Personal Information” for purposes of this Policy is defined as information that identifies you, such as your name, address, phone number, photo, or email address. We regularly re-evaluate our Privacy and Security policies and adapt them to address new challenges.
1. Our Collection and Use of Personal Information
We do not and will not sell, trade, or rent your personal information. We use and disclose your personal information only as follows:
- to analyze Site usage and improve the Service;
- to deliver to you communications relevant to your use of the Service, any administrative alerts, and other alerts you have opted-in to receive;
- to fulfill your requests for certain products and services;
- for market and product research, project planning, troubleshooting problems, detecting and protecting against error, fraud, or other criminal activity;
- to third-party contractors, services, partners or platforms providing services that support the Site or are critical for Site functionality and are bound by these same privacy restrictions;
- as otherwise set forth in this Privacy and Security Policy.
Certain features of the Site and Service may require registration, which involves provision to Lampo an email address, a password, and a zip code, (collectively the “Registration Information”). To fully benefit from a subscription to our premium service (“EveryDollar Plus”) you must provide your third-party account credentials (“Account Credentials”) to allow Lampo to access your account data at those other financial institutions (“Account Information”) for your use. At various times we may request other personal information to provide you with other benefits of the Service. That information will only be used for the stated purpose. We may make anonymous or aggregate personal information and disclose that data in a non-personally identifiable manner to:
- Advertisers, marketers and complimentary product and service groups within Lampo;
- Users of the Services for purposes of comparison of their personal financial situation relative to a broader group.
Your Registration Information, Account Credentials, Account Information, and other personal information you provide is strictly restricted and is used internally only to operate, develop, or improve the Service. These individuals have been selected in accordance with our security policies and are under strict confidentiality obligations. We may also use third party vendors or service providers to help us provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a particular feature or functionality of the Service. Our contracts with these third party vendors or the Terms of Service under which we operate outline the appropriate use and handling of personal information and prohibit them from using any of your personal information for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information we provide to them.
If you are an EveryDollar Plus member or are subscribing to a service that requires payment, we ask for your debit card number or checking account information to process your initial payment and all subsequent payments. We will use your e-mail address as our primary source of contact with you regarding the Service.
2. Information About Your Computer and Browser
Lampo may collect technical and navigational information such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site in order to analyze trends, administer the Site, and provide efficient and specific technical support. We gather broad demographic information to improve the Service, and to format e-mail communications to align best with your computer’s capabilities. This information is collected in a generic aggregate format and is not linked to personally identifiable information.
“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. Lampo may set and access cookies on your computer to track and store preferential information about you. Lampo may gather information about you through cookie technology. For example, Lampo may assign a cookie to you, to limit the amount of times you see a particular offer or to help better determine which offer to serve to you. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Service may be impaired for you.
3. Blogs and Other Forums on EveryDollar.com
If you use a bulletin board, blog, commenting system or other messaging system on our Site, you should be aware that any information you submit there can be read, collected or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums. These forums may be hosted by Lampo or by one of our third party service providers on Lampo’s behalf.
4. Contests, Giveaways, and Surveys
From time to time, we may offer you the option to participate in contests, giveaways, surveys or other promotions. If you would like to participate, we may ask you for contact information, preferences, or other information. This information may be used to conduct research, improve our Site or Service, or award prizes. Any information submitted in connection with such activities will be treated in accordance with this Privacy and Security Policy, except as specifically set forth in the rules for those contests, giveaways, surveys or promotions.
5. Disclosure or Transfer of Your Information
Lampo reserves the right (and you authorize Lampo) to share or disclose your personal information when Lampo determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:
- To prevent prohibited or illegal activities; or
- When required by any applicable law, rule regulation, subpoena or other legal process.
Your information may be transferred in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets or otherwise) of all or a portion of a business operated by Lampo or its affiliates.
6. Email Communications From Us
We may provide our registered customers with regular Account Information updates and email alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting Lampo or Lampo-related goods or services. EveryDollar.com subscribers have the ability to opt-out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts but may not end the transmission of account-critical or triggered emails such as password reset verification.
7. Data Security and Communication Encryption
The Lampo Group and our Service partners employ a multi-layer security approach including firewall barriers, data encryption techniques, authentication procedures, data transmission encryption, among other hardware, software, and procedural methods. When you register for the Service, Lampo requires a password from you for your privacy and security. Lampo transmits information such as your Registration Information for EveryDollar.com or Account Credentials securely. Our technology infrastructure resides in world-class, highly secure data centers utilizing state-of-the art electronic surveillance and multi-factor access control systems. These data centers are staffed 24x7 by trained security guards, and access is authorized strictly on a least privileged basis.
From the time you submit your email address and password, these communications between your computer and EveryDollar.com are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.
8. Updates to the Privacy and Security Policy
We update this Privacy & Security Policy periodically. The date last revised appears at the top of the Policy. Changes take effect immediately upon posting on EveryDollar.com.
If you have questions, comments, concerns, or feedback about this Privacy and Security policy or any other privacy or security concern, please contact us at firstname.lastname@example.org.