Privacy Policy

Effective date: November 7, 2022

This Privacy Policy (“Policy”) describes how Sagewell Financial, Inc. (“Sagewell,” “we,” “us” or “our”) collects, uses, and shares personal information in connection with your use of our website or application (the “Service” or “Services”).

Personal Information We Collect

Information you provide to us. Personal information you may provide us includes:

• Contact details, such as your first and last name, email, and phone number.
• Account data, such as the username and password that you may use to establish an online account with us.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Financial information, such as your income, current and past loan and credit card information, current and past loan offers, bank account balances and credit scores. For additional information relating to your choices about financial information specifically, see our GLBA Consumer Privacy Notice.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Our Services may use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Data brokers that provide us with basic information to allow us to better tailor our Services to you.
• Financial institutions that operate any financial accounts or products that you connect to your Sagewell account.
• Credit agencies that provide us with your credit score and other relevant financial history.

How We Use Your Personal Information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

• Provide, operate and improve our Services and our business;
• Process payments and complete transactions;
• Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
• Understand your needs and interests, and personalize your experience with the Services and our communications; and
• Provide support for our Services, and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We, our service providers, and our third party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you Sagewell-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. We may engage third party advertising companies, such as Google, to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for our Services to them or similar users on other online platforms. This is called interest-based advertising.  You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.

Compliance and protection. We may use your personal information to:

• Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern our Services; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Comply with law. We may use your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Your Personal Information

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Our financial partners. Companies with whom we partner to offer you financial products and services that you request, including banking account and loan products. These companies’ privacy and information sharing practices are set forth in their respective privacy policies.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Sagewell (including, in connection with a bankruptcy or similar proceedings).

Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above, that may collect information on our website through cookies and other automated technologies.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our Services, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

Your Choices

Access, correct or delete. If you have a Sagewell account, you can review and update certain account information by logging into your account. You may also contact us to request deletion of your account and certain personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to limit or decline access and deletion requests, for example, where we need to retain your information for security, compliance, fraud prevention, and safety purposes. If we delete your account, you will not be able to access it. If we delete your information, it will generally be deleted from our active databases, and the information may remain for a period of time in our backup files and in unstructured files until these records are deleted in the ordinary course of business. 

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. You may continue to receive service-related and other non-marketing emails.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Online tracking opt-out. There are a number of ways to limit the tracking of your online activity and collection of device data through automated means, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Platform opt outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
  • Google: adssettings.google.com
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites: optout.aboutads.info
  • Digital Advertising Alliance for Mobile Apps: www.youradchoices.com/appchoices
  • Network Advertising Initiative: optout.networkadvertising.org/

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

Financial Information. For additional information relating to your choices about financial information specifically, see our GLBA Consumer Privacy Notice.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through our Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

Job Applicants

When you visit the “Careers” portion of our websites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and  to respond to surveys.  We may also use this information to provide improved administration of our websites, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites and online services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

You can reach us by email at help@sagewellfinancial.com or at the following postal addresses:

Sagewell Financial, Inc.
955 Massachusetts Ave. #220
Cambridge, MA 02139

GLBA Consumer Notice