Privacy Policy

Privacy Policy for Users Who Apply or Sign Up for a BMM Account

Last updated: October 25, 2022

The Privacy Policy describes the information Best Money Moves LLC and our affiliates (collectively, “BMM,” “we,” and “us”) collect when a person or business (“you,” “your”) applies or signs up for a BMM account; accesses or uses in any manner any BMM application, product, service, feature, technology, content, or website (collectively, “Services”); or otherwise contacts or interacts with us.

Scope and Consent

By applying or signing up for a BMM account, including through a computer or mobile device (“device”), you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described herein (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation, and consumer protection laws.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last updated” date above. The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email at the email address you provide. Where these changes would cause material detriment to you, you may of course cancel your account at any time. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you and to contact us if you have any questions about these changes. Your continued use of our Services constitutes your acceptance of any amendment of this Privacy Policy.

Collection of Information

Our Services may be used by a broad range of industries in connection with their products, services, activities and administrative functions, whether they are involved in government, retail, health, politics, human resources, technology or anything else. Accordingly, a broad range of information (including information about you) may be uploaded to or sent through our Services.

Without information about you, we may not be able to provide you with the Services or the support you request.

Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information about children under the age of 13. Users must be 18 to use the Services.

Information You Provide

We collect information you provide when you apply or sign up for a BMM account and when you provide information as part of our identity or account verification process. We collect information about you, including:

  • Identification information, such as your name, email address, mailing address, cell phone number;
  • Financial information about loans, debts, bank accounts;
  • Information on your level of financial stress that you provide to us through our Stressometer;
  • Payroll data, made available to us by your employer;
  • Other historical, contact, and demographic information; and
  • Other information necessary or required for providing the Services.

We collect information you provide when you participate in contests or promotions offered by BMM or our partners, respond to our surveys or otherwise communicate with us.

Information We Collect from Your Use of our Services

We collect information about you when you use our Services, including:

Location Information.

Through our applications, we may collect information about the location of your device. For more information and to learn how to disable collection of location information, please see “Your Choices” below.

Device Information.

We collect specific information about your device when you access our Services, including your hardware model, operating system and version, unique device identifier, mobile network information, and information about the device’s interaction with our Services. We may also identify other software running on the device for anti-fraud and malware-prevention purposes (but will not collect any content from such software).

Use Information.

We collect information about how you use our Services, including your access time, browser type and language, and Internet Protocol (“IP”) address. We also collect information relating to which piece of content you access, or tool you use, and for how long.

Customer Surveys and Polls.

We may contact you for surveys and polls. These surveys assist us in making the site better and to gather information that will be useful for our sites. The information you provide us will be kept confidential, although the results of the survey may be used by us and distributed in press releases and for other uses on our sites. Your participation in any survey or poll will be voluntary. Survey and poll responses will be combined or used in a meaningful way, but will not include the name or other identifiable information related to our site visitors or customers.

Information Collected by Cookies, Web Beacons, and localStorage.

We use various technologies to collect information when you use our Services, including sending cookies to your device, using web beacons, and localStorage. Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. For more information and to learn how to manage and/or block or delete cookies used in the Services, please see “Your Choices” below. We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, track the number of visits to our website, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. LocalStorage allows large amounts of data to be stored locally.

Information We Collect from other Sources

We receive information from your employer, including your name, address, phone number, email address, age, work classification (if any), title, and other payroll data. We collect this information and connect it to your account. AT NO TIME DOES ANY OF YOUR PERSONAL INFORMATION GET SENT TO YOUR EMPLOYER.

We may, depending on the Services provided, also collect information about you from third parties, including third-party verification services, credit bureaus, mailing list providers, and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification number. By applying or signing up for a BMM account, you authorize and consent to our obtaining from, and disclosing to, third parties, from time to time, any information about you in connection with the processing of any credit investigation, identity or account verification, fraud detection, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment and personal reporting agencies.

Use of Information

We may use information about you to provide, maintain, and improve our Services, such as:

Developing new products and Services; and

Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages.

We may use information about you to improve, personalize and facilitate your use of our Services. For example, when you sign up for a BMM account, we may associate certain information with your new account, such as information about other accounts you have listed with BMM. We also may use information about you to measure, customize, and enhance our Services, including the design, content, and functionality of our applications and websites, or to track and analyze trends and usage in connection with our Services.

We may use information about you to send you news and information, or to conduct surveys and collect feedback, about our Services and to communicate with you about products, services, contests, promotions, discounts, incentives, and rewards offered by us and select partners, based on your communication preferences and applicable law. We also may contact you to resolve disputes, collect fees, and provide assistance for problems with our Services or your BMM account.

We may use information about you:

  • To protect our rights or property, or the security or integrity of our Services;
  • To enforce the terms of our General Terms or other applicable agreements or policies;
  • To verify your identity (e.g., some of the government-issued identification numbers we collect are used for this purpose);
  • To investigate, detect, and prevent fraud, security breaches, and other potentially prohibited or illegal activities;
  • To comply with any applicable law, regulation, legal process, or governmental request;

For any other purpose disclosed to you in connection with our Services.

We may, and we may use third-party service providers to, process and store your information in the United States, Japan and other countries.

Sharing of Information

We may share information about you as follows:

With BMM and other affiliates, for the purposes outlined above;

With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, and other entities in connection with the payment or money transfer process;

With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services or as otherwise permitted by law;

With other users of our Services with whom you interact through your own use of our Services. For example, we may share information when you make or accept a payment, appointment or money transfer using our Services;

In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business;

If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce or comply with the terms of our General Terms or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services, or (iv) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities; or

With your consent, we also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

Your Choices
Personal Information

You may access, change, or correct information about you by logging into your BMM account at any time or by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information.

Deactivating Your Account

If you wish to deactivate your BMM account, you may do so by logging into your BMM account or by emailing us using the contact details provided below. BMM generally retains information about you only as long as reasonably necessary to provide you the Services. However, even after you deactivate your BMM account, we may retain archived copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.

Location Information

In order to provide certain mobile applications, we may require location information, so if you do not consent to collection of this information, then you cannot use our corresponding Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove all BMM mobile applications from your device.

LocalStorage

We try to make your experience with BMM simple and meaningful. When you access or use the Services, our web server may use localStorage to collect information from device. We may use localStorage to:

Remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users.

Customize elements of the promotional layout and/or content of our website or application.

Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Most web and mobile device browsers are set to automatically accept localStorage by default. Please note, however, that by blocking or deleting localStorage as it is used in the Services, you may not be able to take full advantage of the Services.

Cookies

We try to make your experience with the Services simple and meaningful. When you access or use the Services, our web server may send a cookie to your device. Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We may use cookies to:

  • Remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users.
  • Customize elements of the promotional layout and/or content of our website or application.
  • Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.
  • Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. We currently do not respond to DNT signals. We may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

Promotional Communications

You may opt out of receiving promotional messages from BMM by following the instructions in those messages or by changing your notification settings by logging into your BMM account. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

California Privacy Rights

California law permits residents of California to request certain details about information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us at the address listed below.

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you at our own premises and with the assistance of third-party service providers. We restrict access to personal information to those BMM employees, contractors, and agents who need to know that information in order to transmit, store, or process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy, and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with this Policy and other appropriate confidentiality and security measures.

Nevertheless, BMM cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

BMM takes security and confidentiality seriously. BMM never shares an individual’s information with anyone. Period. In addition, BMM takes steps to ensure the system is available and fast.

Availability
  • AWS Service 2 Pack
  • Realtime database mirroring
  • Automatic horizontal scaling
  • Full DR Plan with communications policies
  • Monitoring software includes CloudFlare, Airbrake, Scrutinizer, New Relic, Dialog and others
Confidentiality

We take the following measures:

  • Data is encrypted in transit and at rest
  • Forced password complexity (in progress)
  • 2FA (in progress)
  • No one has access to an individual’s data except the individual
  • We do not sell emails or access to them
  • Store only name, email and mobile phone (do not store sensitive PII, not even address).
  • We comply with GDPR
Integrity
  • We perform monthly COMODO scans
  • We are located in the Key Management System at AWS
  • We maintain logs on separate server
  • We have passed numerous third-party audits
  • Our SOC2, HIPPA and ISO27001 compliance is in progress
Revisions

We reserve the right to revise, amend or modify our policies at any time and from time to time. However, our commitment is to maintain sites where your personal information is not sold to third parties.

Contact

Please contact our Privacy Department with any questions or concerns regarding this Privacy Policy.

Samuel J. Tamkin

Best Money Moves LLC

395 Dundee Road

Glencoe, IL 60022, U.S.A.

If you have any questions or concerns regarding our policy, or if you believe our policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our Privacy Department listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.