Our Services are designed to create the best place to manage your financial life. Our Services enable you to connect and view your various online or app-based financial and finance related accounts in one place. Our Services may also permit you to analyze these accounts, set up automated savings or debt payments, view and monitor your credit information, transfer funds between your accounts, and receive offers relating to various financial products and services, including loans, payments, money transmission, and passive investment and savings vehicles from third parties.
We may collect your personal data and other information from you in the following circumstances:
Information You Provide. We collect personal data from you when you voluntarily provide this information to us, such as when you register for access to our Services, contact us with inquiries, link your accounts, and respond to offers from third parties, or when you authorize our Services to collect this information about you from your financial institution or from credit bureaus. Personal data that you voluntarily provide may include your name, address, email address, phone number, tax identification number (such as U.S. social security number) or other government-issued ID number, date of birth, annual income, and other information about your finances and employment.
Other Information We Collect:
Non-Identifiable Data.When you interact with our Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store this information itself or it may be included in databases owned and maintained by our agents or service providers. Our Services may use this information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, and the domain names of our visitors' Internet service providers. It is important to note that your personal data is not is available or used in this process.
Aggregated Personal Data. In an ongoing effort to better understand and serve our users, we may conduct research on our customer demographics, interests, and behavior based on personal data and other information provided to us This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
Location Information. Our Services may collect and use your location information (for example, by using the GPS on your mobile device) in order to help us authenticate activity related to your account. We may also use your location information in an aggregate way, as described below in the “Aggregated or De-Identified” section. We do not share your location information with other users of the Services.
We may also use your personal data and other personally non-identifiable information collected through our Services to help us improve content and functionality, to better understand our users, and to improve our Services. We may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or wish to have your name deleted from our mailing lists, please contact us as indicated below.
We are committed to protecting your personal data. We consider this to be a vital part of our relationship with you. We commit that if we share your data, it will be only in the following circumstances.
At Your Request. We may share your data where you have consented or otherwise given us permission to share your data. For example, if you want us to retrieve your credit report on your behalf, we will need to share your personal data with third party credit bureaus for the purpose of retrieving your credit report. We will not share your name, address, email address, phone number, or tax identification number (such as U.S. social security number) with third party product providers without your express consent. Note that when you decide to pursue an offer from a third party product provider, you may be asked to provide information directly to that provider, including your personal data. Using our Services does not require you to provide any information directly to such providers, unless you wish to.
As Aggregated or De-Identified Information. Although we will not share your name, address, email address, phone number, or tax identification number (such as U.S. social security number) without your consent or unless you opt in to such sharing, we may share information that is aggregated or de-identified, so that it cannot reasonably be used to identify you. For example, we may include certain financial information about you (e.g., your rate of return for a security, token or currency) in a leaderboard that is accessible publicly, but your personal data will not be associated with such information unless you consent or opt-in to having your personal data associated or otherwise claim the profile associated with such information. In addition, we may share aggregated or de-identified information with third party providers to permit them to make offers that are more relevant to you.
Your Public Profile. When you choose to create or claim a public profile on any of the Services, certain parts of your personal data will be publicly displayed. You consent to our public display of any personal data or other data that you include in your public profile or that is associated by default with your public profile at the time you create or claim your public profile.
With Third Parties Needed to Provide Our Services.We may share your information with third party service providers whom we use in delivering our Service. Examples include providers who provide us with technology services such as hosting, identity verification, support, payment, and email service. We provide these providers with only the information they need to perform their specific function. For example, we may use third parties to gather your information from financial institutions.
For Legal Reasons. We may share your information if required by applicable law or legal process, or if we believe it is in accordance with applicable law or legal process. This can include protecting the rights, property, and safety of Empower, our users, and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims.
As Part of a Corporate Change. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, your personal data may be part of the transferred assets
You agree to promptly update your account information in the event of any change. If you need to update your personal data, please contact us at email@example.com. We will take reasonable steps to update or correct your personal data in our possession that you have previously submitted through our Services. You can also update your own data in our mobile app using the edit feature.
You may also choose not to provide us with your personal information, but you may as a result not be able to use some of our Services. You may terminate your account with us at any time by submitting a request to firstname.lastname@example.org. Please note that we may retain your personal data and other information beyond the end of your relationship with us in accordance with our internal record-keeping policies and with applicable law, including to comply with legal reporting obligations.
We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not submit personal data to us. If you have reason to believe that a child under the age of 13 has provided personal data to us, please contact us and we will endeavor to delete that information from our databases, subject to applicable law.
We take reasonable steps to protect your personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These include policies designed to protect the confidentiality and security of your personal data such as industry-standard encryption and authentication measures. We also limit access to your personal data to employees and service providers that have a business reason to know such information. However, no Internet or email transmission is ever fully secure or error free.
Your access to and use of our services is also subject to our Terms of Service which may be found at www.empower.me/terms
|FACTS:||WHAT DOES Empower Finance, Inc. ("Empower") DO WITH YOUR PERSONAL INFORMATION?|
|Why?||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.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include:|
|How?||All financial companies need to share consumers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers' personal information; the reasons Empower chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Empower share?||Can you limit this sharing?|
|For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus||Yes||No|
|For our marketing purposes — to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||Yes||No|
|For our affiliates’ everyday business purposes — information about your transactions and experiences||Yes||No|
|For our affiliates’ everyday business purposes — information about your creditworthiness||Yes||Yes|
|For our affiliates to market to you||Yes||Yes|
|For our affiliates to market to you||No||We don't share|
|To limit our sharing|
|Questions?||Call 833-399-5945 or go to empower.me/prviacy|
|Who we are|
|Who is providing this notice?||Empower Finance, Inc.|
|What we do|
|How does Empower protect my personal information?||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.|
|How does Empower collect my personal information?||We collect your personal information, for example, when you:|
|Why can’t I limit all sharing?||Federal law gives you the right to limit only|
|What happens when I limit sharing for an account I hold jointly with someone else?||Your choices will apply to everyone on your account.|
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.|
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.|
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.|
|Other important information|
|You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.|
For California residents: In accordance with California law, we will not share information we collect about you with companies outside of our corporate family, except as permitted by law, including, for example, with your consent or to service your account. We will limit sharing among our companies to the extent required by California law.
For Vermont residents: In accordance with Vermont law, we will not share information we collect about you with companies outside of our corporate family, except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness within our corporate family except with your authorization or consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.