Introduction
Welcome to Snowball! We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Snowball Finance, Inc., collect, including through Snowball’s website (www.snowball.money) and our mobile applications for iOS and Android devices. It also explains why we collect your information and how we use it. This privacy policy notice is included with and supplements our website Terms of Service.
Privacy is important to Snowball. We will never rent or sell your information to anyone. If you have any questions or if you believe that Snowball has not adhered to this privacy policy, please send us a note at support@snowball.money.
For users that are citizens of the European Union ("EU"), this privacy policy is subject to the provisions of the General Data Protection Regulation ("GDPR") and other applicable privacy laws. In such case, we agree that under the GDPR, we are a data “Controller” and you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” We will take commercially reasonable steps to maintain compliance with GDPR requirements as applicable. Your Personal Data may identify you as a person, and thus is often referred to as “personal information” or “personally identifiable information”.
Information We Collect and Why
In order to provide a high-quality service, Snowball collects various types of information when you visit the website or mobile app, sign-up as a customer, or otherwise engage with Snowball.
Visitor Information
We collect various types of anonymous information about visitors to Snowball, such as device-related information (including browser type) and server log information (including the date and time of day of your visit, average time spent on the Snowball site, browsing activity, and any site that referred you to Snowball). We also collect personal information that you input into our website, (e.g., by beginning the account application process or by commenting on the Snowball blog). We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance the Snowball service.
Customer Information
When you choose to create an account with Snowball, we collect certain personal information, including your full legal name, email address, permanent address, phone number, date of birth, social security number and information about financial status. We are required by law to collect this information to provide you with financial services. The personal information about you that we collect does not include any special types of information (e.g., health-related) as defined in the GDPR. If you do not provide this personal information to us, we will be unable to provide our services to you and you cannot become a Snowball customer. Our collection and processing of your personal information is pursuant to our contract with you to provide you with our services, as established when you create your Snowball account subject to our Terms of Service.
If you use the third party Plaid services to link a bank account when signing up for a Snowball account, you acknowledge and agree that the information you provide to Snowball through Plaid will be treated by Plaid in accordance with their respective privacy policies (located at https://plaid.com/ legal/#privacy-policy) and by Snowball according to this privacy policy. Snowball will abide by all GDPR rules as a processor of your personal information that we receive from Plaid, where applicable.
We may also provide links to other third party websites that you may click-on from our website (e.g., social media sites). Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.
Other Ways We Collect Information
Apart from through the account opening process and from visitors to the site, we may collect various other types of personal information if you or a friend engages with Snowball. We collect your email address as part of our customer referral service or if you subscribe to the Snowball blog. We may also collect personal information if you enter it into our live chat program or contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our customer support team). Further, we may collect information regarding your browsing activity when you visit Snowball’s website and actions you take within your Snowball account while logged in to your Snowball account.
Cookies and Pixels
Cookies are small pieces of data that are stored on your computer, mobile phone or any other device used to access the Internet. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.
We use these technologies to customize Snowball and improve your experience with the site. Cookies store anonymous information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Snowball and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites or devices to better customize our marketing and advertising campaigns.
Cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept any cookies or pixels to use this site. However, refusing to accept cookies or pixels will make the use of Snowball more cumbersome and less accessible.
Advertising Companies
Snowball advertises our services on websites not affiliated with Snowball, and we contract with third-party advertising companies to display these ads. These third-party advertising companies, along with data exchanges and similar providers, may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. We do not provide any information to these advertising companies that could personally identify our users or clients, and they do not collect such information for us.
Where permissible, Snowball and third-party advertising companies may use the data collected to provide you with ads relevant to you and personalized content while you are on Snowball or other sites. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page. Please note that even if you choose to remove your information by opting out, you will still see advertisements while you are browsing online.
Additionally, many network-advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The third party NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
Because mobile devices may vary in how they operate and may not use cookies, the choice management options listed above may not work for all mobile devices and mobile apps.
Analytics Services
We use third-party analytics tools, including “Google Analytics” (such tools collectively referred to as “Analytics Services”) to collect information about the usage of this site. The Analytics Services collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve this site.
These Analytics Services collect the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on here.
How We Use Your Personal Information
Snowball uses your personal information to enhance your customer experience, provide customer support, operate and maintain your account in accordance with US and other applicable laws, investigate and understand how Snowball is used, monitor and protect the security and integrity of Snowball, and better market and advertise Snowball’s services. You understand and agree that Snowball will compare your identifying information with government-provided lists of suspected terrorists.
We use your personal information to determine what services we may provide to you and in making financial decisions regarding your account. Our services may make automated decisions using your personal information such as making credit determinations, and identifying benefits that may apply to you.
As part of this process, we may from time to time include, compile, or aggregate some of your personal information in certain data analysis, reports, or other interpretations of investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it is not identifiable to any particular customer.
Additionally, we may use your personal information to contact you regarding our own services, resources, or Snowball job openings that we think may be of interest to you. If you no longer wish to receive such marketing communications from Snowball, please click the “unsubscribe” link that can be found at the bottom of each such email message. Please note that if you hold an account with Snowball, you cannot opt-out of certain communications related to the administration of your account, including communications related to billing, statement and trade confirmation delivery or certain regulatory matters.
How We Share Your Information
We do not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.
In order to provide financial services and in connection with our everyday business purposes and activities, we may share your personal information with third parties who perform services on our behalf. Examples of these third parties and services include consumer identification verification services, public accounting firms and other professional firms, and certain other vendors and service providers who perform marketing, advertising, research and analytics services on our behalf. We have entered into agreements that require that these third parties keep this information confidential. We may also disclose your information to other third-party financial institutions, e.g., if you ask to transfer assets from Snowball to such financial institutions. If you choose to use Snowball’s charitable giving feature, we will share your name and email address with the recipient charity, which the recipient charity may use to contact you.
We may also disclose personal information in response to service of legal process, such as a court order, summons, or subpoena, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), front-running or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Terms of Service or customer agreements.
Furthermore, we may disclose personal information in specific other cases with your consent. We may transfer your personal information to our successor-in-interest in the event of an acquisition, sale, merger or bankruptcy.
You may also elect to share certain personal information with individuals or with the public via your use of the website. For example, the website may make it possible for you to publicly share information via social media such as Facebook or Twitter. Be aware that when you choose to share information with friends, public officials, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the website. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the website.
How Your Personal Information is Protected
Snowball works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Snowball to agree to keep your information confidential.
Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. In general, we store your personal information for as long as reasonably required for its purpose or for any additional period required by law (if any). Account information is no longer accessible when you or when we delete your account. We may store information longer for legitimate business reasons (for example, personal information may remain in backups for a reasonable period of time), or as legally required. Due to US regulatory requirements, we may not immediately delete residual copies of closed accounts, and may preserve all customer data for a minimum of three (3) years. Otherwise, we store your personal information until you request us to remove it from our servers. We store our logs and other technical records indefinitely.
If you maintain a Snowball account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.
How You Can Access or Change Your Personal Information That We Have Collected
Once you have registered with Snowball, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at support@snowball.money. Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three (3) years.
If you are an EU citizen and believe that we have misused your personal information, you have the right to contact the European Data Protection Supervisor (“EDPS”) to ask the EDPS for advice on how to exercise your rights or to ask the EDPS to investigate your complaint. For more information, see EDPS Complaints.
Other Important Information
Former Customers
If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.
How We Respond to Do Not Track Signals
Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Customers using certain modern browsers have the ability to activate a “Do Not Track” signal. Snowball does not currently respond to the “Do Not Track” signal.
How You Accept This Policy
By using and continuing to use the Snowball websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version.
Changes to the Policy
We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting, except as otherwise prohibited by law. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app. Your continued use of our website after receiving our notice of changes to this Privacy Policy means you accept such changes. Please check the effective date below to determine if there have been any changes since you have last reviewed the Snowball privacy policy.
Children
Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Snowball and/or provided us with personally identifiable information, please contact us at support@snowball.money. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.
Your Rights as a California Resident
Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at support@snowball.money. Your request should specify your full name and the email address you used when submitting personal information to us.
Your Rights as a California Resident
We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into our Customer Agreement, please contact us at support@Snowball.money. Please note, however, that we will not be able to provide you with services through Snowball without the ability to share this financial information.
International Visitors
This Service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information on our website, you consent to: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside (i.e., outside the European Economic Area ("EEA")); and (ii) permitting the use of your personal information in accordance with this privacy policy.
If you have any questions on the privacy policy, please contact us at:
Snowball Finance Inc.
Inc.399 Fremont St.
San Francisco, CA 94105
support@snowball.money
LAST AMENDED DATE: Aug. 1, 2018
Introduction