Privacy Policy

Types of Data Collected

Personal Data

While using our Service, we may ask you or your data controller to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• First name
• Last name
• Email address
• Date of birth
• Hire date
• Job title
• Team
• Location
• Contact phone number
• Profile photo
• Cookies and Usage Data

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Use of Data

The legal basis for the processing of the above information is consent. Betterment Inc. uses the collected data for various purposes:

• To provide and maintain our Service.
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so.
• To provide customer support.
• To gather analysis or valuable information so that we can improve our Service.
• To monitor the usage of our Service.
• To detect, prevent and address technical issues.
• Allows automatic generation of messages such as welcome to new hires and also recognition of work anniversaries based on hire date information.
• Provide an ability to report and provide trends on employee feedback based on tenure, team, age profile, location.

Statistical Data Use – Betterment Inc. does not claim ownership of the Customer Data or personally identifiable data provided during the operation of the Service. Financial Literacy Group may however utilize anonymous usage statistics and performance metrics to improve and administer the Service, for Betterment Inc.’s internal use and other lawful purposes. Such data may include, without limitation, the number of records held in the Service, the number and types of transactions, configurations, reports processed in the Service and the performance results for the Service . Nothing herein shall be interpreted as prohibiting Betterment Inc. from utilizing the aggregated statistics for the purposes of operating v’s business, provided that Betterment Inc.’s use of aggregated statistics will not reveal the identity, whether directly or indirectly, of Customer, any individual or any specific data entered by Customer or any individual into the Service.

Retention of Data

Betterment Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Our policy is that the information held for each user is only held while the user is an active user of the system. When a user leaves the organization that is a customer of Betterment Inc. the user is removed from the Betterment Inc. system and all personal data is immediately deleted. Aggregate data not identifiable to a user is held after a user has been deleted for the purposes of protecting the integrity of reporting systems.

Where it is necessary to retain Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies then we will do so.

Betterment Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Ireland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Ireland and process it there.

Your consent to this Privacy Policy represents your agreement to that transfer.

Betterment Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Legal Requirements

Betterment Inc. Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Betterment Inc.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security Of Data

The security of your data is important to us, and we undertake to keep the Personal Data confidential and take all appropriate technical and organizational measures to ensure a level of security for the Personal Data which is appropriate to the risks to individuals that may result from the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the Personal Data

Your Rights

Betterment Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact a member of the project team in your company to make the required changes. Betterment Inc. will support the team with these requests.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact a member of the project team who will contact Betterment Inc..

In certain circumstances, you have the right:

• To access and receive a copy of the Personal Data we hold about you
• To rectify any Personal Data held about you that is inaccurate
• To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to Betterment Inc. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

If Betterment Inc. receives any request from any data subject made under the Data Protection Legislation relating to the Personal Data, Supplier will provide a copy of that request to the Customer within five (5) working days.

Betterment Inc. will also provide all reasonably necessary assistance to the Customer to enable it to deal with any Personal Data requests in accordance with Data Protection Legislation.

Betterment Inc. will also provide all reasonably necessary assistance to the Customer to enable it to deal with any communications from any Supervisory Authority relating to the Personal Data within any time frame specified by the Supervisory Authority.

Please note that we may ask you to verify your identity before responding to such requests.

We do not use any of your personal information for direct marketing.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Notification of breaches

On becoming aware of any data breach Betterment Inc. will immediately notify the Customer and Data Protection Commissioner where applicable. If the data breach affects an individual user then this user will be notified by Financial Literacy Group Limited.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.