PRIVACY POLICY
Last Updated: August 18, 2010
We at TILE Financial Inc. (“TILE”) care deeply about your privacy while you use the services (the “Services”) that are available on our website www.spendgrowgive.com (the “Site”). This privacy policy (“Privacy Policy”) details the types of information we gather about you, and your usage of the Site, how we collect it and how we use it in connection with providing the Services and operating the Site. On the Site, TILE does not collect any Personally Identifiable Information. Any Personally Identifiable Information used by TILE is collected off-site by a Member’s Financial Advisor. If you have any questions about this policy or our privacy practices, you can contact us at info@tilefinancial.com. We are always willing to discuss them with you.
TILE is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build users’ trust and confidence in the Internet by promoting the use of fair information practices. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.
If you have questions or concerns regarding this statement, you should first contact TILE’s help desk at info@tilefinancial.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://watchdog.truste.com/pvr.php?page=complaint&url=www.spendgrowgive.com TRUSTe will then serve as a liaison with TILE to resolve your concerns.
TYPES OF INFORMATION COLLECTED
The purpose of the Site is to teach Members about how to responsibly Spend, Grow, and Give their money. Members are able to track their spending over different time periods, learn about what types of investors they want to be, and donate to nonprofit organizations that work on issues they care about. Through the Site, Members get a complete look at their financial life.
Account Data, Sign-In Data and Optional Member Data (collectively “Personal Data”) are considered personal data by TILE.
Technical Data, Usage Data and Aggregate Data (collectively “Non-Personal Data”) are considered non-personal data by TILE.
Personal Data
Account Data: In order to use the Site and the Services, your financial adviser must provide certain personal information to us such as your first and last name, email address, telephone number, home address, age and gender, as well as financial account information that may include your bank accounts, investment accounts and credit card accounts (collectively “Account Data”). This Account Data will be provided offline by your financial adviser to TILE and will not be collected through the Site. A Member cannot receive Sign-In Data (see “Sign-in Data” below) before his or her Account Data has been collected. This Account Data, as it identifies you personally, will never be shared with or sold to any outside company for any commercial purpose or for any financial benefit to TILE.
Sign-In Data: Before you use the Site for the first time, your financial adviser will collect Personal and Financial Information from you that is necessary to create a TILE Account. Once TILE has received that information, your TILE Account will be created and a Username and Password (together, “Sign-In Data”), which allows you to routinely access the Site, will be sent to your provided email address. This Sign-in Data is securely stored on TILE’s servers and can be accessed only by authorized TILE security personnel. It is your responsibility to ensure the confidentiality of your Sign-in Data. If you have forgotten or lost your Password, click on the “Forgot password?” link on the log-in screen, and an email will be sent to you with instructions on how to reset your Password. If you believe your Username or Password has been stolen, please immediately contact us at info@tilefinancial.com
Optional Member Data: As you explore the Site, you may have the option to share other personally descriptive information about you with TILE, such as your interests, nickname, and your favorite nonprofit organizations (collectively “Optional Member Data”). Entering this information is not necessary for you to use the Site or the Services, but it will enable you to have a more individually tailored experience.
Non-Personal Data
Technical Data: While you use the Site and the Services, we may collect technical information such as your browser type, number of pages clicked, frequency of Site visits and time spent on the Site (collectively “Technical Data”). This information cannot uniquely identify you, but provides useful insight to TILE into how the Site is being used and how it can be improved.
Usage Data: As you continue to use the Site over time, your use of the Services will provide data on your spending, growing and giving habits and expenses, including information associated with the outflow and inflow of money, your interaction with the features of the Site; and financial transaction trends over different time periods (collectively, “Usage Data”), that may be collected by TILE. Usage Data may also include data such as transaction information, financial trends, budgeting goals and portfolio allocations. An example of Usage Data might be the number of months in a year that a Member went over his or her set budget or which stores are most frequented by a Member. Usage Data will be stripped of any personally identifiable information.
Aggregate Data: As TILE’s membership grows, so will the diversity of its Members. To facilitate future interactive Member features of the Services, Personal Data such as age, gender and interests of individual Members may be compiled together to form an anonymous set of data (“Aggregate Data”). Individual Members are not identified within the Aggregate Data nor can the information be traced back to an individual Member.
MAIN USES OF INFORMATION
TILE uses the information collected from you to improve the Site and the Services and to tailor them to the individual Member. Our use of the data is meant to help you achieve the best possible experience while using the Site, while not compromising our values on privacy, security or Member control.
Personal Data is used by TILE to help create a personal Member experience that is unique to you. In this regard, Personal Data will be used to direct your attention to relevant material, compare yourself to similar Members and identify vital learning curriculum. This unique experience may be created by looking at your Optional Member Data and matching it with TILE content, aggregating Personal Data to allow comparison of trends and similarities, comparing your portfolio contents to your financial learning progress, and through other methods that integrate our Services with your Personal Data.
Non-Personal Data is used by TILE to improve upon and create better features of the Services. Non-Personal Data allows TILE to improve the technology of our Site, identify and correct security issues, update the design and functionality of the Site, and create new features and content of the Site and Services.
ADDITIONAL USES
Partner Organizations
We may provide TILE’s partners, such as non-profits and financial institutions, with relevant Non-Personal Data that could increase the effectiveness of our Services. Anyone with whom we share this information will be bound by this Privacy Policy. By accepting our Terms of Service you give explicit permission to TILE to provide its partners with your Personal Data as it relates to facilitating the financial and charitable components of the Services. If you choose not to give your consent, you may instead need to directly provide your Personal Data to these outside organizations to facilitate certain features of the Site.
Cookies
Cookies are small packets of information that are stored on your computer that relay important information to TILE about you and your preferences. TILE uses cookies to store technical data relating to the delivery of the Services. Cookies enable you to more securely and easily access the Site and the Services. TILE does not store personally identifiable information in cookies.
Third-Party Generated Statistics
We use a third-party tracking service that uses cookies and web beacons to track non-personally identifiable information about visitors to our site to create aggregate usage and volume statistics for technical and security assessments. These assessments are used to improve the Site and Services provided to the Member.
Legal Disclosure of Information
TILE reserves the right in its sole discretion to disclose all or any portion of your Personal Data when such disclosure is necessary or relevant: to satisfy a legal process (such as a subpoena or court order); to aide in a law enforcement investigation; to seek to prevent illegal or harmful actions; or to enforce our rights against you or in connection with a violation of our Privacy Policy or Terms of Use Agreement.
ACCESS TO THE SITE
The person or persons who transfer money to the Member’s TILE Account (the “Funders”) and Members each access different areas of the Site and have varying levels of control over the Personal Data and Usage Data of the Member. These varying levels of access will depend upon the decisions by the Funders, the Financial Adviser, and the Member. In each Member’s “My Account” section, one is able to easily see which parts of the Site are viewable and/or editable by the Member and the Funders.
CHANGES TO PERSONAL INFORMATION
On the Site you will find a “My Account” section which displays your current Personal Data and allows you to modify your Password and some Optional Personal Data. Members cannot change any Personally Identifiable Information through the Site. In order to change that information, you must contact the appropriate person (either your Funders or Financial Adviser) with your request. TILE cannot change that information for you.
Members may change information such as Nickname, Password, School Information, Financial Profile, Interests, and Alert Preferences. Funders can change the Funding Allocations only by sending an email request to the financial adviser – they cannot change the Funding Allocations online. Financial Advisers can modify information regarding the Member’s Full Name, Physical Address, Birth Date, Gender, Financial Accounts, Financial Funding Source, and Funding Allocations by contacting TILE – these modifications cannot be initiated through the Site.
PREFERENCES AND NOTIFICATIONS
To better tailor the Site experience and Services to your needs, there are many ways to customize the way TILE interacts with you through the Site’s preferences and notifications pages. This is an easy and accessible part of the Site that lets you be in control of the flow of information. You have control over how you receive notifications from us (such as through email and SMS) and and what type of notifications you’ll receive (such as fund transfers, budgets, new content, announcements and messages). Currently you are only able to opt out of notifications pertaining to new messages through the Site, but if you wish to not receive other types of notifications, just email us at info@tilefinancial.com. You will not be able to opt-out of notifications about important updates regarding TILE, your account, or the Site.
SECURITY
The security of your personal information is important to us. When you enter information (such as financial account information and sensitive personal information) on the Site, that information is encrypted using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
OUTSIDE LINKS
While TILE does provide links to outside websites that contain interesting videos, articles, images, and other content, this Privacy Policy does not apply to those websites. Each website will have its own Terms of Use, Privacy and Security Policies that you should familiarize yourself with before using the website. If you are uncomfortable with its policies, then you should not use the site. We try to provide safe, reliable and appropriate links, but we are not responsible for how your information is treated on these external sites.
CHILDREN UNDER 13
The Site and Services are designed for use only by people over the age of thirteen (13) years old. TILE does not knowingly collect or store any personal information on, or allow access to, children under thirteen (13) years old.
CLOSING YOUR ACCOUNT
You have the ability to close your TILE account and cancel your membership at any time. If you choose to do so, you have the option to delete your Personal Information from our records by contacting TILE at info@tilefinancial.com. We will need to contact your Funder and Financial Adviser to complete the request. After we receive your notification, it will take up to 72 hours for us to fully comply with your request. However, some Personal Information may remain after the 72 hour time period because of data backup systems in place that ensured your information was always readily available and secure. If we later discover this to be the case, we will promptly delete this Personal Information from the backup systems. Non-Personal Data collected during your use of our site (“Remaining Data”) cannot be removed when you close your account or cancel your membership as we cannot identify your specific Remaining Data. Even after you close your TILE account and cancel your membership, you give TILE permission to continue to use your Remaining Data as outlined previously in this Privacy Policy.
ACQUISITION OF TILE
If TILE is ever transferred to a third party company because of a sale, merger, reorganization or other transaction, we will seek to ensure that the new owner or partner follows this Privacy Policy. If such a transfer does occur, we will notify you so that you are able to decide if you wish to continue to use the Services. In the event that you wish to close your account and cancel your membership, simply notify us and your Personal Information will be deleted in the manner stated in the Closing Account section above.
CHANGES TO PRIVACY POLICY OR SITE
As TILE grows and develops new additions to its Services, we may find it necessary to update this Privacy Policy. When such updates occur, they will be incorporated into this document and posted at www.spendgrowgive.com/about/privacy-policy with the date the policy was last updated visible at the top of the page. If we deem an update to this Privacy Policy to be a significant change, we will notify the Members here, by email, or by means of a notice on our home page. By continuing to use the Site or the Services, you are consenting to this Privacy Policy and any future updates that are made to it even if you do not read them.
TILE’S CONTACT ADDRESS FOR PRIVACY QUESTIONS
We’d love to hear from you. If you have any questions, concerns or suggestions regarding this Privacy Policy or our practices, please feel free to contact us at:
TILE Financial Inc.
41 East 11th Street, 11th Floor
New York, NY 10003
info@tilefinancial.com
1-877-311-TILE (8453)