Updated: February 25, 2019
LEAF College Savings, LLC (“Company” or “We” or “Us” or “Our”) respects your privacy and is committed to protecting it through our compliance with this policy.
We want you to understand how we handle the personal information about you that we may obtain and the high standards we employ to safeguard this information. This policy describes the types of information we may collect from you or that you may provide when you visit the websites www.leafsavings.com, portal.leafsavings.com, and www.leafbenefits.com (our “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On these Websites.
- In email, text, and other electronic messages between you and these Websites.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
This policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party; or
- any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites.
The information we may collect on the Websites includes:
- Personally identifiable information (“personal information”), such as: name, mailing address, billing address, email address, telephone number, driver’s license number, social security number, date of birth, and demographic information, such as age, gender, hometown, household income, education, and interests. The personal information may be your personal information or the personal information of others (for example, the recipients of gift cards that you purchase).
- Unique identifiers such as usernames, account numbers, and passwords
- Payment information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date, billing address) that we may collect when you purchase, order, receive refunds, or request information about our services from the Websites.
FINANCIAL ACCOUNT INFORMATION
- Information about your financial accounts such as your savings account numbers, 529 college savings account numbers, student loan information and types of investments.
- Information about your interests in various products or services offered by Us or communication or marketing preferences; usage activity such as purchase history.
- Information about your internet connection, the equipment you use to access the Websites, and usage details, including IP address, browser type, operating system, access times, areas of the Websites you viewed, what content you viewed on the Websites, and the pages you viewed directly before and after accessing the Websites.
We collect the foregoing information:
- When you provide it to us.
- Automatically as you navigate the Websites.
INFORMATION YOU PROVIDE TO US
We collect information you provide directly to us, for example, when you create an account, participate in interactive features of the Websites, fill out a form, respond to a survey, request customer support, or otherwise communicate with us via the Websites.
INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE WEBSITES
When you access or use the Websites, we automatically collect information about you, including the following:
- We log information about your use of the Websites, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before and after navigating to the Websites.
- We use various technologies to collect information, including sending cookies to your computer or mobile device and placing web beacons on pages of the Websites.
- Cookies are small data files stored on your hard drive or in device memory that help us to improve the Websites and your experience, see which areas and features of the Websites are popular, and count visits. Most browsers are set to accept cookies by default.
- Web beacons are small electronic files (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related Websites statistics (for example, recording the popularity of certain Websites content and verifying system and server integrity).
THIRD PARTY VENDORS
We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Websites through the use of first party cookies and third-party cookies to, among other things, analyze and track users’ use of the Websites, determine the popularity of certain content, and better understand online activity.
- We may use Google AdSense to serve ads on this site. When you view or click on an ad a cookie will be set to help better provide advertisements that may be of interest to you on this and other websites. You may opt-out of the use of this cookie by visiting Google’s Advertising and Privacy page: http://www.google.com/privacy_ads.html.
By accessing the Websites, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their respective privacy policies and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor’s website or Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Websites to:
- Fulfill and manage purchases, orders, payments, and other transactions related to the Websites.
- Send you an order confirmation or contribution confirmation.
- Assist law enforcement and respond to subpoenas.
- Create and manage your account.
- Deliver targeted advertising, newsletters, and promotions, and other information regarding the Website and our mobile application to you.
- Communicate with you regarding your account or order.
- Send you technical notices, updates, security alerts, and support and administrative messages.
- Generate a personal profile about you to make future visits to the Websites more personalized.
- Increase the efficiency and operation of the Websites.
- Monitor and analyze usage and trends to improve your experience with the Websites.
- Notify you of updates to the Websites.
- Offer new products, services, and/or recommendations to you.
- Perform other business activities as needed.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Process payments and refunds.
- Request feedback and contact you about your use of the Websites.
- Resolve disputes and troubleshoot problems.
- Respond to product and customer service requests.
- Provide, maintain, and improve the Websites.
- Process and deliver contest entries and rewards.
- Link or combine with information we get from others to help understand your needs and provide you with better service.
- Fulfill any other purpose for which you provided the information.
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
BY LAW OR TO PROTECT RIGHTS
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
THIRD-PARTY SERVICE PROVIDERS
We may share your information with third parties that perform services for us or on our behalf, including mailing services, payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. Such third parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
OTHER THIRD PARTIES
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.
SALE OR BANKRUPTCY
You may at any time review, correct, or delete the information in your account or terminate your account by:
Logging into user account settings and updating the user account.
Contacting us using the contact information provided below.
EMAILS AND COMMUNICATIONS
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
Noting your preferences at the time you register your account with the Website.
Logging into your account settings and updating your preferences.
Contacting us using the contact information provided below.
If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting those third parties directly.
COOKIES AND WEB BEACONS
Most web browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Websites. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. Be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
You can always choose not to provide information when you are prompted to do so. Note that if you do not provide us with certain mandatory information, then you may be unable to take advantage of certain features on the Websites.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Websites, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Websites, but please be aware that the data may not be completely or comprehensively removed from our systems.
In compliance with the European Union (“EU”) General Data Protection Regulation (“GDPR”), we may rely upon one or more legal bases defined in the GDPR to collect, use, share and otherwise process the personal information of individuals located in the EU, including where:
- Necessary to perform a contract we have with you, such as our terms of engagement, and to provide the services;
- You have consented to the processing (in which case you may revoke your consent at any time);
- Necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims;
- Necessary to protect your vital interests or those of others;
- Necessary in the public interest; and
- Necessary for the purposes of LEAF College Savings, LLC or a third party’s legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms. Where we collect, use, disclose and otherwise process your information based on legitimate interests, we may rely on the following interests:
- Marketing our products: We use your information as necessary to pursue our legitimate interests in marketing our products to you. For example, where permitted by digital marketing law, we may contact you by email to let you know of products you might be interested in.
- Providing, improving and developing our products: We use your information as necessary to pursue our legitimate interests in tailoring and improving our products. For example, we may send you a survey or questionnaire to understand your experience in purchasing from LEAF College Savings, LLC. If you are located in the EU, under certain circumstances, you may have certain legal rights under the GDPR, including:
- To access the personal data we maintain about you
- To receive information about how we process your personal data
- To correct your personal data
- To have your personal data erased
- To object to or restrict how we process your personal data
- To request your personal data be transferred to a third party
- To withdraw any consent you may have given us to process your personal data
If you are an EU resident, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. If you are located in the EU and you believe that LEAF College Savings, LLC has infringed your rights under the GDPR, please contact us by sending an email to [email protected] or calling us at: 800-645-5323.
You have the right to lodge a complaint with a supervisory authority, in particular in your applicable Member State.
It is our policy to do its best to keep any information you provide to us secure.
We industry standard security measures that are reasonably designed to help protect your information from loss, unauthorized access, or disclosure. More specifically, the Websites are hosted on a secure server behind a firewall. Further, we use SSL technology for information collected during the Websites product checkout process.
While we take the issue of protecting your privacy seriously, you should exercise discretion in what information you transmit to the Websites. We cannot guarantee that information sent over the Internet is fully secure. We are not responsible for the security of information sent to us over the Internet.
We do not knowingly solicit information from or market to children under the age of 13. If you are under 13, do not use or provide any information on these Websites or on or through any of its features. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
LEAF College Savings, LLC
1300 17th St N Ste 1800
Arlington, VA 22209