Privacy Statement for Wisely with ADP™

This Privacy Statement explains how we use and disclose “Personal Information” that ADP collects from people who use the Wisely with ADP™ mobile application (the “App”). This Privacy Statement also applies to our former customers, for so long as we maintain their Personal Information.

ADP has a Global Privacy Policy that applies to all ADP companies worldwide. This Privacy Policy requires ADP, LLC and its affiliates to respect privacy and protect the Personal Information that is entrusted to it. This Privacy Statement explains how ADP collects, uses and discloses Personal Information in connection with the Wisely mobile application. Other ADP companies have their own privacy statements, although their practices are always governed by the ADP Global Privacy Policy.

If you have additional questions about privacy or information security, please contact us at Privacy@ADP.com.

  1. How We Collect Personal Information
  2. This Privacy Statement explains our practices with regard to “Personal Information” collected by ADP in connection with the Wisely mobile application (the “App”). Personal Information is any information that can be used to identify, locate or contact you. Personal Information also includes other information that may be associated with your Personal Information.

    The Wisely mobile application is designed to help you to better manage your finances and control spending by providing access to a set of tools whereby you may set up budgets and savings goals. Wisely is accompanied by a reloadable General Purpose Reloadable (“GPR”) prepaid card that you may direct a portion of your net pay in the form of a payroll deduction and use the card to spend such funds. You may also fund the reloadable GPR prepaid card through your bank account by providing your debit card account information into Wisely. Wisely will not store your bank account credentials or account information.

    When you register to use the Wisely mobile app, we confirm your Personal Information such as name, address, email, phone number and last 4 digits of SSN by asking you to provide your Personal Information or authenticate yourself using your ADP login credentials. We may also collect other information such as your demographic (such as age, home address, income range, etc.) and pay statement information using the ADP login credentials for the purpose of suggesting a budget plan personalized for you.

    As you interact with us online, we use cookies and other technological tools to collect information about your computer and your use of our website and applications. We treat this information as Personal Information when it is associated with your Contact Information. For more information about cookies and other technologies, please see the section Cookies and Other Data Collection Technologies below.

  3. How ADP uses Personal Information
  4. ADP uses your Personal Information to provide the Wisely services, and for related activities, such as product and service delivery, customer service, account management, support and training and to provide other services related to your relationship with ADP.

    ADP, LLC may provide you with marketing communications to help you to better understand your spending patterns and habits. You may always opt-out of receiving our marketing communications.

    We also use your Personal Information to manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, and business continuity.

  5. Why Personal Information is disclosed by ADP and your rights to limiting sharing
  6. ADP understands that you do not want to us to provide your Personal Information to third parties for their own marketing purposes. We limit our sharing of your Personal Information as follows:

  7. Cookies and Other Data Collection Technologies and Analytics
  8. When you visit our website or use our mobile applications (including the Wisely App), we collect certain transaction information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

    For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.

    We collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website or mobile application, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet.

    In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

    In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. For example, when you use the App we will associate a unique identifier with your Personal Information so that we can understand how long you spend using the App and what pages you visit. This Privacy Statement applies to the information when we associate it with your Personal Information. ADP uses third-party vendor Mixpanel. ADP and/or Mixpanel may collect personally identifiable information about you (including your first name; email and telephone number) to optimize your use of the Wisely services. For information on how Mixpanel uses data please visit https://mixpanel.com/privacy.

    ADP has relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third party advertising companies may place cookies on your computer when you visit our website or other websites so they can display targeted advertisements to you. These third party advertising companies do not collect Personal Information in this process, and we do not give any Personal Information to them as part of this process. However, this Privacy Statement does not cover the collection methods or use of the information collected by these vendors. For more information about third party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org. You can opt out of being targeted by many third party advertising companies by visiting www.networkadvertising.org/consumer/opt_out.asp or http://preferences.truste.com/truste/.

    One of ADP’s third party advertising vendors is Omniture. If you would like more information on how to remove yourself from the tracking and reporting functions performed for this website by Omniture, please visit the Omniture Opt-Out Page at http://www.omniture.com/en/privacy/2o7 and follow the relevant instructions.

    Third Party Advertising Companies and Browser Tracking

    ADP does not collect third party online behavioral web browsing information (data collected over time across web sites owned or operated by different entities for purposes of delivering advertising based on preferences or interests known or inferred from the data collected) for use by ADP or our clients for advertising purposes (often referred to as Online Behavioral Advertising or OBA). ADP does, however, use third-party advertising vendors that use first-and third-party cookies to gather information as individuals interact with ADP's and other websites.

    You may set your computer's Internet browser settings so you will be notified when you receive any third party cookie, which includes ADP's cookies, and be given the choice to block the cookie. In addition, there are also other controls within certain browsers or available through third parties that enables more extensive blocking of cookies. Some new browsers have a 'do-not-track' feature. When this feature is turned on, ADP treats this as if you had opted out of our online advertising products. To learn how to manage your browser based settings and cookies, please visit your browser’s support page for more information. :

  9. Location Based Data and Push Notifications
  10. When you download the Wisely application, you may choose to allow us to obtain your precise location from your mobile device. We use this information to deliver personalized content to you and for our internal analytics purposes.

    We may also offer automatic (or "push") notifications. We will provide push notifications only to those individual who opt-in to receive such notifications from ADP. You do not have to provide precise location information to ADP or enable push notifications to use any of our mobile apps. If you have questions about location and notification privacy, please contact your mobile service provider or the manufacturer of you device to learn how to adjust your settings.

  11. Your Choices
  12. You can always limit the information you provide to ADP. You can also limit the communications that ADP sends to you. To opt-out of commercial emails, simply follow the unsubscription instruction of any email we send you.

    Please note that even if you opt-out of promotional emails, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations and account statements.

    If you have any questions about your choices or if you need any assistance with opting-out, please contact us via email to Privacy@ADP.com. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.

  13. Access and Correction
  14. ADP respects your right to access and correct your Personal Information. If you have an online account, you can log into your account at any time to access and update the information you have provided to us. Additionally, ADP complies with all laws regarding access and correction. If you need assistance updating your Personal Information, please contact us via email to Privacy@ADP.com. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.

    We will only retain your Personal Information to fulfill the purpose for which it was collected or as required for legitimate purposes permitted by law.

  15. Information Security
  16. ADP has implemented an information security program that contains administrative, technical and physical controls that are designed to safeguard your Personal Information. For example, we use industry-standard encryption technology to secure sensitive Personal Information when it is being collected and transmitted over the Internet as well as firewalls, site monitoring and intrusion detection software.

  17. Privacy Policies of Third Parties
  18. This Privacy Statement only addresses the use and disclosure of information by ADP. Other services that may be accessible via the Wisely application may be offered by other companies that have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

  19. Changes to this Privacy Statement
  20. From time to time, we may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to this Privacy Statement. Additionally, if the changes will materially affect the way we use or disclose previously-collected Personal Information, we will notify you about the change by sending a notice to the primary email address associated with your account.

  21. How to Contact Us
  22. Please contact us if you have any questions or comments or complaints, if you believe that ADP has not handled your Personal Information properly, or that it has breached its privacy obligations. Your complaint may be directed to ADP Data Privacy and Governance at Privacy@ADP.com. Privacy will investigate any complaint and notify the individual within a reasonable timeframe of the outcome of the investigation.

You can reach us via mail to:

ADP
Data Privacy and Governance
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA

Effective as of: October 2017

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FACTS

WHAT DOES WISELY WITH ADPSM DO WITH YOUR PERSONAL INFORMATION

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security Number and employment information
  • account balances and purchase history
  • transaction history and account transactions

When you are no longer our customer, we continue to share your information as descrived in this notice

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons we choose to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Wisely with ADP Share?

Can you limit this sharing?

For our everyday business purposes:
such as to process your transactions, maintain your account(s), respond to court orders, fraud and legal investigations, or report to credit bureaus.

Yes

No

For our marketing purposes:
to offer our products and services to you.

Yes

No

For joint marketing with other financial companies:

No

We don't share

For our affiliates’ everyday business purposes: information about your transactions and experiences.

No

We don't share

For our affiliates’ everyday business purposes: information about your creditworthiness.

No

We don’t share

For our nonaffiliates to market to you.

No

We don’t share

Questions?

Call 1-888-373-5714 or go to wisely.adp.com

Who we are

Who is providing this notice?

The business units of ADP, LLC that provide and support Wisely with ADP

What we do

How does Wisely with ADP protect my personal information?

To protect your personal information from unauthorized access and use, we use secruity measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Wisely with ADP collect my personal information?

We collect personal information, for example, when you

  • Open an account or provide acount information
  • Pay your bills or give us your contact information
  • Make deposits or withdrawls from your account

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • Sharing for affiliates everyday business purposes- information about your credit worthiness
  • Affiliates from using your information to market to you
  • Sharing for non affiliates to market to you.

State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Wisely with ADP does not share with our affiliates so they can market to you

Non affiliates

Companies not related by common ownership or control. They can be financial or nonfinancial companies.

  • Nonaffiliates we share with can include service providers performing marketing services on our behalf

Joint Marketing

A formal agreement between non affiliated financial companies that together market financial products or services to you.

  • Wisely with ADP does not jointly market