Goalsetter App Privacy Notice
Last Updated: 12/30/2024
This Privacy Notice applies to the Goalsetter App and the associated financial savings and spending features (collectively, the “Services”) owned and operated by Students of Wealth, LLC., d/b/a Goalsetter. It is provided to help inform users of the Services (“Users,” “you,” “your”) about how we may collect, use, and share your personal information. It also explains your choices and rights with respect to the personal information we may collect about you and about your children whose personal information you may choose to share with us in order to access and use the Services.
By accessing or using the Services, you acknowledge that you have read and understood this Privacy Notice. If you do not agree with this Privacy Notice, please do not access, or use Services.
1. PERSONAL INFORMATION WE COLLECT FROM ADULTS AND KIDS
In order for you to create a profile and use the Services, we need to collect and process some personal information. Personal information (“Personal Information”) is information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with you, your children, or your household.
Depending on your use of the Services, that may include:
2. PERSONAL INFORMATION WE COLLECT FROM CHILDREN UNDER AGE 13:
Children under age 13 are not permitted to create an account without first receiving an invitation code authorized by a parent or legal guardian. We do not knowingly collect Personal Information from children under age 13 without first obtaining prior verifiable consent from the parent or legal guardian. We collect only the minimally required Personal Information from children under age 13, and we do not condition a child’s participation in the Services on collection of more Personal Information than is necessary in order to provide them with the Services.
Should we learn that we have inadvertently collected Personal Information from a child without prior, verifiable consent from the parent or legal guardian, we will take steps to promptly delete such information.
Usage Information
When you or your child access the Services, we may automatically collect certain information such as your Internet Protocol (“IP”) address associated with your browser, and your device ID. We may also collect information such as login timestamp, the operating system of the device and language, country, as well as areas in the Services visited most frequently, time spent, and features accessed most often (“Usage Information”). Usage Information is used to help us administer the Services and diagnose problems. We also aggregate and analyze Usage Information to better understand how the Services are used and to help us improve the Services. When Usage Information is in a format that identifies an individual, we treat it as Personal Information in accordance with this Privacy Notice.
To collect Usage Information, we use cookies. Cookies are small data files sent by a website and stored on the computer or device at the request of that site. Cookies store information related to your browser to enable us to recognize the browser on return visits to the Services, to remember your preferences, to understand how our Users interact with the Services, and to help improve the Services.
By using the Services, you agree to the use of these technologies.
Third Party Cookies and Similar Technologies:
We use third-party service providers to assist us in collecting and understanding Usage Information. Most browsers can be set to detect browser cookies and similar technologies and to let a user reject them, but refusing cookies and similar technologies may make it difficult to use the Services. To learn more about browser cookies, including how to manage or delete them, refer to the Tools, Help or similar section of your web browser.
3. USE OF YOUR PERSONAL INFORMATION
We will not sell or rent Personal Information. We use your Personal Information as described above and to:
4. INFORMATION SHARED WITH OUR PARTNER BANKS
As described above, in order to provide you with banking-related Services, we share your information with our partner Bank, Webster Bank, N.A., member FDIC (“Webster”). Goalsetter is a financial technology company, not a bank, and therefore such information sharing is necessary to provide you with the Services. You may access Webster’s privacy policy at: https://www.websterbank.com/privacy/
When we provide you with debit card services, your information is shared with our partner bank, Pathward, N.A, fka MetaBank, N.A., Member FDIC (“Pathward”). You may access Pathward’s privacy policy at: https://www.pathward.com/privacy-policy/
5. GOAL SUPPORTER INFORMATION
When you support a User’s financial goal within the Services (“Goalsetter’s Goal “) by sending them a GoalCard® (a digital gift card loaded with real money), you have the option of remaining anonymous or disclosing your name to the Goal
The amount(s) you give in support of the Goalsetter’s Goal(s) will be listed on the Goalsetter’s profile (unless you give a lump sum to the Goalsetter without designating how the funds should be allocated to the Goalsetter’s Goal(s), in which case, only the amount of lump sum will be listed on the Goalsetter’s profile).
6. WHAT’S PUBLIC
When you create your Goalsetter profile, you can elect to have your Goalsetter profile be public or private.
If you choose to make your Goalsetter profile public then it is searchable in the Services (in the “Give a Gift” section) and anyone may click on your name to see your Goalsetter profile.
If you or your child’s Goalsetter profile is private it will only be discoverable by people who have you or your child’s unique profile name.
Here are some of the things that could be made publicly viewable on your
Goalsetter profile:
7. THIRD PARTIES
We may engage with third party partners to facilitate our delivery of the Services and to provide certain features on our behalf, such as data hosting, analytics, content delivery, maintenance, security, and similar functions. These third parties may require a certain amount of information, including Personal Information, in order to deliver their services on our behalf.
We do not disclose more Personal Information than is necessary for a third party to facilitate our delivery of the Services or to provide certain features on our behalf. Third parties may only use Personal Information for the sole purpose of providing their services to us in support of our delivery of the Services.
To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. These measures may include device safeguards and secured files to ensure information remains confidential and secure. Goalsetter maintains customer authentication procedures to protect your personal information and accounts from identity theft.
8. SECURITY
We implement physical, administrative, and technical safeguards to help protect the confidentiality, integrity, and availability of Personal Information. We host Personal Information in secure, third-party cloud-based environments that use firewalls, encryption of Personal Information in transit and at rest, and other industry-standard technologies in an effort to prevent interference or access from outside intruders. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably foreseeable and reasonably within our control.
You are responsible for maintaining the confidentiality of your User name and password. If you become aware of any unauthorized use of an account, loss of your or your child’s account credentials or suspect a security breach, notify us at hello@goalsetter.co.
9. DATA RETENTION
We retain Personal Information for as long as is necessary to provide the Services for the purpose for which it was provided or otherwise for as long as is legally required of us.
We may create and retain deidentified data by removing, obfuscating and/or otherwise altering the Personal Information. We may use de-identified data only for legally permissible purposes and may retain such data for longer periods than may be legally required.
10. EMAIL OPT-OUT
We send emails to you with information about our Services that we believe may be of interest. You may opt out of receiving email messages from us by contacting us at hello@goalsetter.co or by clicking on the “unsubscribe” link found at the bottom of every marketing related email that we send. We do not send marketing emails to children under 13.
If you have opted out of receiving marketing communications from us, we will still send you Service-related communications.
11. HOW YOU MAY MODIFY YOUR PERSONAL INFORMATION
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, you can contact us at hello@goalsetter.co to provide updated information, alternatively you may modify or delete the Personal Information you have provided to us by logging into the App and updating your profile.
Parents of children under age 13 have the right to request a copy of the Personal Information or types of Personal Information we have collected from your child, to request that we not collect further Personal Information from the child, or to request that we delete the Personal Information we have collected from the child. To make such a request, please email us at hello@goalsetter.co. We will take steps to confirm your identity before we are able to fulfill your request.
12. UPDATES TO THIS POLICY
As our Services evolve, we may make changes to this Privacy Policy. We will alert you to changes by providing notice within the Services or otherwise as required by law.
The “last updated” note at the top of this policy indicates when it was last revised, and updates will become effective when they are posted.
13. QUESTIONS
If you have questions about our privacy practices, please contact us at hello@goalsetter.co.
CALIFORNIA CONSUMER PRIVACY ACT NOTICE
At Goalsetter, we value your privacy and are committed to the protection of personal information. In this California Consumer Privacy Act Privacy Policy, we provide information regarding the collection, use, disclosure, and other processing of information relating to California residents by Students of Wealth LLC d/b/a Goalsetter, and its affiliates and subsidiaries (referred to herein as “Goalsetter,” “we,” or “us”).
Under the California Consumer Privacy Act (“CCPA”), “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident and includes certain categories of Personal Information discussed below that constitute “Sensitive Personal Information.” The CCPA, however, does not apply to certain information, such as information subject to the federal Gramm-Leach-Bliley Act.
The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to E-Mail Opt-Out above (located at https://goalsetter.co/policies).
Our Collection, Use, Disclosure, and Sharing of Personal Information
The following chart provides information about the categories of Personal Information that we collect and use, as well as the categories of Personal Information that we disclose to third parties for our operational business purposes, including in the past 12 months preceding the date this Privacy Policy was last updated.
We do not sell Personal Information, and we do not share Personal Information for purposes of cross-context behavioral or targeted advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated. Without limiting the foregoing, we do not sell or knowingly share the Personal Information relating to minors under 16 years of age.
| Categories of Personal Information | Categories of Third Parties to Whom Information is Disclosed for Our Operational Business Purposes | Categories of Third Parties to Whom Information is Shared for Cross-Context Behavioral Advertising |
| Identifiers, such as name, postal address, IP address that can reasonably be linked or associated with a particular California resident or household, email address, account name, online identifiers, and government-issued identifiers (e.g., Social Security number) | affiliates; service providers; ad networks; business partners; marketing partners; credit bureaus; legal authorities; other parties in litigation | none |
| Personal information as defined in the California customer records law, such as name, contact information, and financial information | affiliates; service providers; ad networks; business partners; marketing partners; credit bureaus; legal authorities; other parties in litigation | none |
| Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, marital status, and veteran or military status | affiliates; service providers | none |
| Commercial Information, such as transaction information and purchase history | affiliates; service providers; ad networks; business partners; marketing partners; credit bureaus; legal authorities; other parties in litigation | none |
| Internet or network activity information, such as browsing history, search history, and interactions with our online properties, applications, or ads | affiliates; service providers | none |
| Geolocation Data, such as device location | affiliates; service providers | none |
| Audio, Video, and Similar Data, such as call and video recordings | affiliates; service providers | none |
| Education Information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information | affiliates; service providers | none |
| Professional and Employment Information, such as current or past job history or performance evaluations | affiliates; service providers | none |
| Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences or characteristics. | affiliates; service providers | none |
| Sensitive Personal Information. ● Personal Information that reveals an individual’s: (1) Social Security, driver’s license, state identification card, or passport number; (2) account log-in, financial account, credit or debit card number in combination with any required security or access code, password, or credentials allowing access to an account; (4) racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; (5) the contents of mail, email, and text messages unless we are the intended recipient of the communication | affiliates; service providers | none |
We may also disclose Personal Information to a third party in the event of a reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Purposes for Our Collection, Use, Sharing, or Other Disclosure of Personal Information We may collect, use, share, or disclose Personal Information in order to:
● operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives;
● develop, improve, repair, and maintain our existing and future products and services;.
● personalize, advertise, and market our products and services;
● operate, maintain, and improve our website and other online services or applications;
● conduct research, analytics, and data analysis;
● plan and manage human resources, including, but not limited to, ensuring appropriate staffing, processing payroll, managing benefits, conducting workforce assessments, reporting and analytics, and succession planning;
● process and evaluate job applications and recruit employees;
● undertake quality and safety assurance measures;
● conduct risk and security control and monitoring;
● protect the safety of our customers, business contacts, employees and job applicants, and other individuals;
● detect and prevent fraud and identity verification;
● facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
● perform accounting, audit, and other internal functions, such as internal investigations;
● comply with law, legal process, contracts, and internal policies;
● maintain records; and
● exercise and defend legal claims.
Our Use of Sensitive Personal Information
Subject to your consent where required by applicable law, we may use Sensitive Personal Information for purposes of providing goods or services as requested by you; ensuring security and integrity; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, and providing storage, or providing similar services on behalf of our business.
Our Retention of Personal Information
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria that we consider in determining our retention periods include:
● The length of time we have an ongoing relationship with you and provide services to you (e.g., for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
● Whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
● Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Sources of Personal Information
We collect Personal Information from you and from affiliates, third-party service providers, business partners, consumer reporting agencies, publicly available databases, social media, operating systems and platforms, internet service providers, ad networks, data analytics providers, and joint marketing partners, when they share the information with us.
Individual Requests
If you are a California resident, you may, subject to applicable law, make the following requests:
We will not unlawfully discriminate against you for exercising your rights under the CCPA. To make a request described above, please contact us by e-mail at hello@goalsetter.co or by calling 866-445-1842. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
Authorized Agents
If you would like an agent to make a request on your behalf to the extent permitted under applicable law, the agent may use the request methods listed above. Not all kinds of requests can be made by authorized agents. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.
De-Identified Information
Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.
Changes to this Privacy Policy
We may change or update this Privacy Policy from time to time. When we do, we will post the revised Privacy Policy on this page with a new “Last Updated” date.
Contact Us
If you have any questions regarding this Privacy Policy, please contact us at hello@goalsetter.co