SEB MOBILE APP PRIVACY POLICY
SEB MOBILE APP PRIVACY POLICY
Last modified: August 30, 2024
Introduction
Spectrum Employee Benefits, Inc. (the “Company”, “we”, “our”, “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy. This policy describes:
• The types of information we may collect or that you may provide when you download, install, register with, access, or use our SEB mobile application (the “App”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect in the App and in email, text, and other electronic communications sent through or in connection with the App.
This policy DOES NOT apply to information that:
• We collect offline or on any other Company apps or websites, including websites you may access through the App.
• You provide to or is collected by any third party (see Third-Party Information Collection).
Our websites and other apps, and those of third parties, may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App. By downloading, registering with, or using the App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the App after we revise this policy means you accept those changes, so please check the policy periodically for updates.
Individuals Under the Age of 18
The App is not intended for individuals under 18 years of age, and we do not knowingly collect personal information from individuals under 18. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us via one of the methods described in Contact Information, below.
Information We Collect and How We Collect It
We collect information from and about users of our App:
• Directly from you when you provide it to us, and indirectly from you when you connect the App to your registered account with us.
• Automatically when you use the App.
Information You Provide to Us
When you download, register with, or use the App, we may ask you to provide information:
• By which you may be personally identified, such as your name, postal address, email address, telephone number, social security number, and date of birth (“personal information”).
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• That is about you but does not individually identify you, such as your employer’s name.
This information includes:
• Information that you provide by filling in forms in the App. This includes information provided at the time of registering your online account with us and connecting that account with the App. We may also ask you for information when you report a problem with the App.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Details of transactions you carry out through the App, such as rebalancing your retirement plan assets among the various investment fund options offered by the plan.
When you register to use the App, you will be asked to connect the App to the retirement plan account that you have registered with us. By doing so, the App will collect and display information regarding your retirement plan account, such as:
• Your retirement plan account balance.
• Your contribution and withdrawal history under the retirement plan.
• The investment funds in which your retirement plan assets are invested and the amount currently invested in each.
When you use the App, this account-related information is periodically collected by the App from our retirement plan recordkeeping software—which we use to maintain your account and which is currently provided by our vendor Schwab Retirement Technologies—so that the App can display up-to-date information regarding your retirement account.
Information We Collect Through Automatic Data Collection Technologies
When you download, access, and use the App, it may use technology to automatically collect:
• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data and other communication data and the resources that you access and use on or through the App.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Location Information. The App does not collect real-time information about the location of your device.
If you do not want us to collect this information, do not download the App or delete it from your device. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
The technologies we use for automatic information collection may include:
• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related
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App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).
Third-Party Information Collection
When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
• Your mobile device manufacturer.
• Your mobile service provider.
These third parties may use tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. While the App does not contain third-party advertisements, they may use this information to provide you with interest-based (behavioral) advertising or other targeted content outside of the App.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
• Provide you with the App and its contents, and any other information, products, or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.
For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
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In addition, we may disclose personal information that we collect or you provide:
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business (such as the vendor of our retirement plan recordkeeping software) and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our App users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the App’s terms of service.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
• Tracking Technologies. You can set your device to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
We do not control third parties’ collection or use of your information to serve interest-based advertising outside of the App. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the App and visiting your account profile page.
Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.
Your State Privacy Rights
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California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Either limit (opt-out of) or require consent to process sensitive personal data.
The exact scope of these rights may vary by state. To exercise any of these rights, or to appeal a decision regarding a consumer rights request, please contact us via one of the methods described in Contact Information, below.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to via one of the methods described in Contact Information, below. However, please know that we do not currently sell our users’ personal information, so our activities do not trigger that statute’s opt-out requirements.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to the App and/or your online retirement plan account with us, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account.
The date that this privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, or to register a complaint or concern, please contact us via one of the following methods:
• U.S. mail, addressed to:
Spectrum Employee Benefits, Inc.
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PO Box 290
Breckenridge, MN 56520
Attn.: Privacy Officer
• Email, addressed to: jennifer@spectrumeb.com
• Telephone call to: (888) 641-1140