Privacy Policy

SmartPath, Inc. (“SmartPath”, “we”, “us”, or “our”) understands that your privacy is an important concern, especially for a personal finance site. SmartPath is committed to protecting the privacy of all of our users. This Privacy Policy explains how SmartPath uses, shares, and protects the information you provide to us through our websites.

Last Updated: November 21, 2024

1. How we use and share your Personal Information.

“Personal Information” refers to any non-public information that can identify you, including information and data that you provide to us through the websites JoinSmartPath.com and OnSmartPath.com.

Personal Information may include, without limitation, the following personal data about you:

  • Full name including aliases;
  • Phone number;
  • Mailing address;
  • Email address;
  • User login ID and credentials;
  • Online identifiers; or
  • Other information that specifically identifies you.

We may use your Personal Information, and/or share your Personal Information with third party vendors who provide services to us. These third parties agree to comply with applicable privacy laws and would only receive Personal Information for the following purposes:

  • To fulfill your requests for our products, services, and applications;
  • To provide access to our accounts, transaction history, and other information related to our products, services, and applications;
  • To communicate with you about our services and products;
  • To improve our sales and marketing;
  • To improve and/or develop our products and services;
  • To enable our business affiliates, partners, contractors, and/or contracted third parties to improve and/or develop their products and services;
  • If you are accessing SmartPath’s services through a partner or third party-sponsored plan, to provide your name, employer identification number, participation levels, participation dates, and/or other standard information about your participation in our plans/programs to such employer or such third-party;
  • In conjunction with a sale of our company or our assets, in which case, we may transfer some or all of the Personal Information to the acquiring company;
  • To comply with law enforcement, applicable law, and when disclosure is required by a court, government agency, or regulator;
  • In any manner consented by you in writing;
  • To enforce our Terms of Use; and/or
  • As otherwise set forth in this Privacy Policy.

We work with a number of third-party vendors who act as service providers to SmartPath. The list of vendors, together with the list of types of Personal Information we disclose, and the reason(s) for this disclosure is available here.

2. We do not sell your Personal Information.

We do not sell (or share) your Personal Information without your consent. This means that we will not disclose your Personal Information to third parties who do not require this data to provide goods or services to SmartPath.

If we need to disclose your Personal Information in a way that is different from the original purposes related to providing goods or services to you, we will obtain your consent before doing so. 

This does not apply to any situation where SmartPath is required to disclose Personal Information to law enforcement, a regulatory body, external investigator, or auditor to comply with a court order, or if required by applicable regulatory compliance purposes.

3. We will take reasonable steps to keep your Personal Information safe.

We take reasonable steps to keep your Personal Information safe from loss, unauthorized activity, or other misuse. We implement measures to ensure a level of security appropriate to risks inherent in handling your Personal Information. All Personal Information submitted to us is secured using bank-grade 256-bit SSL in a secure datacenter. Additionally, we adhere to SOC2 standards and maintain annual Type 2 attestations.

Even with all of the security measures we do have in place, the nature of the Internet and its methods of data transmission means that we cannot guarantee or warrant the security of Personal Information or any other information or data.

4. You have the legal right to ask us to disclose to you the Personal Information we collect, use, and disclose, and opt out of the sale of your Personal Information.

If you are a resident of a U.S. state with a privacy law that is applicable to the Personal Information we obtain from you, then under such privacy law, you may request us to disclose: 

  1. what Personal Information we have about you, 
  2. the types of Personal Information we are collecting from you, 
  3. what we do with that Personal Information, 
  4. to delete your Personal Information, and 
  5. not to sell your Personal Information.

Please refer to the applicable state below to read the notice outlining your additional privacy rights:

This notice is provided to residents in the State of California in compliance with the California Consumer Privacy Act (CCPA). It is intended to supplement and support the SmartPath Privacy and Personal Information Security Policy, which details how we collect, use, disclose (share), and protect the information you provide to us through our websites and our services.

The Right to Know: 

Under this Right, you may submit a formal request to us asking for the types of Personal Information we have collected from and about you. This includes any Personal Information we may have collected about you through any of our third-party service providers or vendors, such as:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmarthPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.

Additionally, you also have the right to know the following:

  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartP|ath disclosed about you for a business purpose.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

Under CCPA, the Personal Information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity easily.

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under CCPA to provide you with the information you request. However, if your request is extensive and will take considerably more time to process, we are permitted up to an additional ninety (90) days under CCPA to fulfill your request.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to use our services.

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under CCPA to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional ninety (90) days under CCPA to fulfill your request.

Take note that there are exceptions to your right of deletion, which can be found under Section 1798.105(d) of CCPA.

Do Not Sell: 

Under CCPA, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights under CCPA. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the CCPA.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

This additional data privacy rights page applies to customers in the following states, in accordance with the following applicable laws:

  • Colorado Privacy Act
  • [Connecticut] An Act Concerning Personal Data Privacy & Online Monitoring
  • Delaware Personal Data Privacy Act
  • Maryland Online Data Privacy Act
  • Montana Consumer Data Privacy Act
  • Nebraska Data Privacy Act
  • New Hampshire Data Privacy Act
  • Oregon Consumer Data Privacy Act
  • Rhode Island Data Transparency and Privacy Protection Act
  • Texas Data Privacy & Security Act
  • Virginia Consumer Data Privacy Act

Under these laws, if you are a consumer residing in one of these states, you have the following privacy rights:

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.

The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information: 

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is no longer required to provide you with services.

Right of Correction:

If any of the Personal Information we have about you is correct, you may contact us to make corrections to reflect the accuracy of the Personal Information we have about you. Please note the following limitations on this right of correction:

  • This only applies to any factually incorrect Personal Information
  • Any incorrect or inaccurate Personal Information about you that originates from a third-party source cannot be corrected. For instance, if a report about your finances contains inaccurate information, we cannot correct that data. However, we may choose to annotate the records to note that the data is inaccurate and was challenged by you.

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

Right Against Profiling & Automated Decision-Making:

We do not use your Personal Information to perform any “profiling” on our customers. This means that we do not create profiles intended to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We also do not make any fully-automated decisions affecting your rights, privileges, or access to our services using automation without human intervention.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

This additional data privacy rights page applies to customers in accordance with the Florida Digital Bill of Rights (FLDBOR). Under FLDBOR, you have the following privacy rights:

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.
  • To opt out of the collection of your Personal Information from voice or face recognition technologies.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information:

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is no longer required to provide you with services. 

Right of Correction:

If any of the Personal Information we have about you is correct, you may contact us to make corrections to reflect the accuracy of the Personal Information we have about you. Please note the following limitations on this right of correction:

  • This only applies to any factually incorrect Personal Information
  • Any incorrect or inaccurate Personal Information about you that originates from a third-party source cannot be corrected. For instance, if a report about your finances contains inaccurate information, we cannot correct that data. However, we may choose to annotate the records to note that the data is inaccurate and was challenged by you.

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right Against Profiling:

We do not use your Personal Information to perform any “profiling” on our customers. This means that we do not create profiles intended to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

This additional data privacy rights page applies to customers in accordance with the Indiana Consumer Data Protection and the Tennessee Information Protection Act.

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information:

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is no longer required to provide you with services. 

Right of Correction:

If any of the Personal Information we have about you is correct, you may contact us to make corrections to reflect the accuracy of the Personal Information we have about you. Please note the following limitations on this right of correction:

  • This only applies to any factually incorrect Personal Information
  • Any incorrect or inaccurate Personal Information about you that originates from a third-party source cannot be corrected. For instance, if a report about your finances contains inaccurate information, we cannot correct that data. However, we may choose to annotate the records to note that the data is inaccurate and was challenged by you.

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

Right Against Profiling & Automated Decision-Making:

We do not use your Personal Information to perform any “profiling” on our customers. This means that we do not create profiles intended to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We also do not make any fully-automated decisions affecting your rights, privileges, or access to our services using automation without human intervention.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

This additional data privacy rights page applies to customers in accordance with the Iowa Consumer Data Protection Act and the Kentucky Consumer Data Protection Act.

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including: 

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information:

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is no longer required to provide you with services. 

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

This additional data privacy rights page applies to customers in accordance with the Utah Consumer Privacy Act.

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information:

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is no longer required to provide you with services. 

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

This additional data privacy rights page applies to customers in accordance with the New Jersey Data Privacy Act.

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information:

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to the following:

  • racial or ethnic origin;
  • religious beliefs;
  • mental or physical health diagnosis;
  • sexual orientation; 
  • citizenship or immigration status;
  • genetic or biometric data;
  • children's data;
  • precise geolocation data (within 1,750 feet); or
  • financial information, including but not limited to account number, account log-in credentials, financial account, or credit / debit card number, in combination with any required code or password permitting access to your financial account

If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is not longer required to provide you with services.

Right of Correction:

If any of the Personal Information we have about you is correct, you may contact us to make corrections to reflect the accuracy of the Personal Information we have about you. Please note the following limitations on this right of correction:

  • This only applies to any factually incorrect Personal Information
  • Any incorrect or inaccurate Personal Information about you that originates from a third-party source cannot be corrected. For instance, if a report about your finances contains inaccurate information, we cannot correct that data. However, we may choose to annotate the records to note that the data is inaccurate and was challenged by you.

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

Right Against Profiling & Automated Decision-Making:

We do not use your Personal Information to perform any “profiling” on our customers. This means that we do not create profiles intended to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We also do not make any fully-automated decisions affecting your rights, privileges, or access to our services using automation without human intervention.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

Under the Minnesota Consumer Data Privacy Act, you have the following privacy rights:

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information SmartPath has collected about you.
  • The categories of sources from which SmartPath collected the personal information.
  • SmartPath’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom SmartPath shares personal information.
  • The specific pieces of personal information SmartPath has collected about that consumer.
  • The categories of personal information that SmartPath has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that SmartPath disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information:

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is no longer required to provide you with services.

Right of Correction:

If any of the Personal Information we have about you is correct, you may contact us to make corrections to reflect the accuracy of the Personal Information we have about you. Please note the following limitations on this right of correction:

  • This only applies to any factually incorrect Personal Information
  • Any incorrect or inaccurate Personal Information about you that originates from a third-party source cannot be corrected. For instance, if a report about your finances contains inaccurate information, we cannot correct that data. However, we may choose to annotate the records to note that the data is inaccurate and was challenged by you.

Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

Right of Non-Discrimination:

SmartPath will not discriminate against you if you choose to exercise your privacy rights. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.

Personal Information of Minors:

SmartPath does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

Right Against Profiling & Automated Decision-Making:

We do not use your Personal Information to perform any “profiling” on our customers. This means that we do not create profiles intended to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We also do not make any fully-automated decisions affecting your rights, privileges, or access to our services using automation without human intervention.

If or when we use your personal information for automated decision-making and profiling purposes, you have the following additional rights:

  • You may question the result of certain profiling decisions we make using automated decision-making tools;
  • You have the right to be informed of the reasoning that the profiling resulted in specific decisions made about you; and
  • You have the right to be informed of what actions you could have taken to secure a different decision in the future.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. 

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

You can exercise your request rights yourself or through an authorized agent by contacting us by email to: support@joinsmartpath.com, Subject: SmartPath Privacy Policy. If you choose to exercise such rights, you shall not receive discriminatory treatment or a lesser degree of service from us.

You may opt out of receiving marketing email communications at any time by clicking on the unsubscribe link included at the bottom of our emails or sending us mail or email at the address below.

5. Your non-personal information may be used to improve our service.

Like many other websites, JoinSmartPath.com and OnSmartPath.com may collect technical information about you, such as what browser you are using or how much time you spend on a certain page or screen, to help us understand how you use our websites. Similarly, our websites employ an Internet technology called “cookies.” Cookies are small files which save information about your visit to our website. None of this information is used to identify you personally, and is not considered to be Personal Information, but such information is used in the aggregate to help us improve the websites’ performance, design, and stability. Some state privacy laws require us to let you know how we respond to web browser Do Not Track (“DNT”) signals. We do not currently respond to DNT signals.

6. Your Personal Information is stored in the United States.

We are located in the United States. If you are a resident of any country outside the United States, you understand and agree that we store and process your Personal Information on computers located in the United States, and that by providing any information to us, you consent to the transfer of such information to the United States.

7. Our services are to be used only by persons in the United States.

Our services are to be used only by persons located in the United States and are not designed for use, offered to, or intended to be used by, any persons outside of the United States.

8. Have questions? Contact us.

We may decide to change this Privacy and Personal Information Security Policy at our discretion, but if we do, we will post the changes here. If you have any questions about this Privacy and Personal Information Security Policy, you can contact us at:

SmartPath, Inc.
2451 Cumberland Pkwy. SE, STE 3608
Atlanta, GA 30339

Email: support@joinsmartpath.com