Last revised: May 11, 2023
Information Provided by You Upon Registration. Upon registration, you may be required to provide some or all of the following personally identifiable information ("PII"):
Passively Collected Information. When you interact with us through a Site, we receive and store certain additional information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Examples include IP addresses, browser types, domain names, and other anonymous statistical data involving your use of a Site and/or our services.
Call Recording. Advertiser understands that all calls to or from SmartFinancial, including, without limitation, Call Transfers, may be monitored or recorded for the purpose of review and analysis by SmartFinancial. Advertiser consents to this recording and agrees to obtain the consent of its agents, employees, contractors, and anyone else who may be recorded on any call to or from SmartFinancial. Call recordings may be stored and analyzed by SmartFinancial for an indefinite period of time.
Use of PII. If you provide PII for a certain reason, we will use the PII in connection with the reason for which it was provided. For example, we will use the PII you input during the registration process to administer your access to a Site. We may also use the registration data that you provide to personalize your experience with us and for verification purposes. We also use contact information from your registration data to send you information about us and to keep you informed of our other products and services that may be of interest to you. Your contact information is also used to reach you, when necessary, regarding issues concerning the use of the Sites and/or our service.
When you view content on our website, we automatically collect PII about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. We use this information to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
We use PII collected through the Sites to help us improve the Sites and our products and services, and to better understand our users. We may use your PII to create aggregate data. Aggregate data is data that describes the demographics, usage or other characteristics of a Site's users as a group without disclosing PII. We reserve the right to transfer and/or sell aggregate or group data about a Site's users for lawful purposes. We may also create internal reports on user demographics and traffic patterns and share these reports with our advertisers and partners. We may include your PII in our reports. This information allows our third-party advertisers and partners to deliver, and our users to receive, more relevant advertisements.
We use your IP address to help diagnose problems with our server, and to administer the Sites. Your IP address is also used to gather broad and specific demographic information as well as for validation purposes. From time to time, and in order to provide you with the best service possible, we may use your PII for automated decision making.
Use of Information That is NOT PII. We may pool information that is not PII with other information in order to track, for example, the total number of visitors to a Site, the number of visitors to each page of a Site, the domain names of our users' Internet service providers. No PII is available or used in this process.
Amended Telemarketing Sales Rule. With your consent, by submitting your e-mail address via a Site and/or obtaining services from us, you agree to receive e-mail marketing from us and our third-party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR 310 et seq. (the "ATSR"). Notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the ATSR. Moreover, by registering with, or requesting information from, a third-party advertiser at or through a Site, such action shall constitute a purchase, an inquiry and/or an application with the respective third-party advertiser for purposes of the ATSR and you may be contacted via e-mail, direct mail and/or telemarketing by such third-party advertiser in accordance with the ATSR.
Third Party Advertisers. We are able to offer our services to you, in part, based on your willingness to be reached by our third-party advertisers. By allowing us to make the information you supply available to these third parties, you will receive free information on products and services that may be of interest to you. This information may also be shared with advertisers on an aggregate basis. Please keep in mind, though, that we do not control, and are not responsible for, the practices of our third-party advertisers.
Third-Party Offers. We may provide you with the opportunity to receive special offers, products and/or services from third-party companies. To receive such offers, products or services, your PII will be shared with such third-party companies, so that they may provide their products and/or services to you without requiring that you first fill another registration form. You may opt-out of receiving these communications by emailing us at service@SmartFinancial.com.
Third-Party Newsletter. With your use of a Site, you may receive a complimentary copy of the Privacy Safety Newsletter via email. You may unsubscribe from the Newsletter at any time by emailing service@SmartFinancial.com. Any questions or concerns regarding the Privacy Safety Newsletter should also be sent to service@SmartFinancial.com.
Service Providers. We, like many businesses, sometimes hire other companies ("Service Providers") to perform certain business-related functions. Examples include mailing information, maintaining databases, and hosting services. When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include PII and other information that you provide to us via a Site. All information that we provide to a Service Provider, as well as information that you share directly with a Service Provider, will be governed by such Service Provider's privacy policies. When you call a Service Provider using a phone number available via a Site, we, or our third party service providers, may record these phone calls and share such recordings with the applicable Service Provider. The recordings shall be maintained by the Service Providers in accordance with their privacy policies.
Legal Requirements: We may disclose PII if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any Site or the public, or (d) protect against legal liability. Moreover, you hereby consent to disclosure of any record or communication to any third party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time.
Business Transfers: 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, PII may be part of the transferred assets.
Categories of Information Collected, Disclosed or Sold in the Past 12 Months
Whether we have sold to a third party, or disclosed for a business purpose, the category of Personal Information; and the categories of third parties to whom the information was disclosed or sold. The table does not include Personal Information provided to us by partners or other customers in a business-to-business context.
|Category of Personal Information Collected||Sold or Disclosed?||Category of Third Parties to Whom the Personal Information was Sold or Disclosed|
|Identifiers, including your name, name, IP address, email address, phone, address||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Customer records information, including signature, bank account number, address,||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Characteristics of Protected Classifications||Not Sold or Disclosed|
|Commercial Information, including records of services that you have purchased in the past||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Internet or Other Network Activity Information, including information about how you interact with our website||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Geolocation Data||Not sold or Disclosed|
|Professional or Employment-Related Information, including your job title and organizational affiliation||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
California residents may:
We will not discriminate against users for exercising these rights. We may charge users different prices, or provide different levels or quality of goods or services, if the difference is reasonably related to the value of their data. We may also offer financial incentives for the collection, sale, or deletion of your Personal Information. In addition, some Personal Information is essential for us to provide the Services. For example, we cannot provide you with an insurance quote without first collecting some Personal Information about you. In such instances, your refusal to provide the necessary Personal Information will result in the inability to use our Service.
To stop receiving future communications from us or to opt out of having your PII shared in any way, including with third parties, please send an e-mail with your Login Name and e-mail address to service@SmartFinancial.com.To unsubscribe from our service, please send an e-mail with your Login Name and e-mail address to service@SmartFinancial.com. Please contact us at service@SmartFinancial.com. if you would like to request access to the PII that we have collected online from you, or to correct factual errors in such information.
If your PII changes, or if you no longer desire our services, you may correct, update or delete your PII, and/or deactivate your account, by emailing our Customer Support at service@SmartFinancial.com.
Other Websites. The Sites may contain links to third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such websites. We suggest that you contact these third parties directly for information regarding their privacy, security and data collection and distribution policies prior to providing them with any information.
Testimonials. We may post customer testimonials on the Sites which may contain PII such as the customer's name. We obtain the customer's consent to post his/her PII along with the testimonial, prior to posting the testimonial. If you want to remove your PII that is being displayed on a Site under public pages, please send your request to service@SmartFinancial.com.
Security. We take commercially reasonable steps to protect PII from loss, misuse, unauthorized access, disclosure, alteration and destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from a Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any PII to us or to any other party via the Internet.
Minors. Visitors under 16 years of age are not permitted to use and/or submit their personal information at any Site. We do not knowingly solicit or collect information from visitors under 16 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.