Updated: April 18, 2022
Collection of Information
Information Collected Through Participation in the Program
If your employer participates in the Program, we will receive certain information about you from your employer, including your:
Full legal name
Social Security number or other taxpayer ID number
Date of birth
Permanent U.S. street address
We also collect other information through your participation in the Program or that you may otherwise voluntarily provide. For example, you may change your contact information through our website. We also receive your communications with us (such as through email, feedback, social media, or other forms).
Lastly, we may collect information from other government agencies. For example, to administer the Program and to prevent fraud.
Information Collected Automatically Through the Use of Our Website
As is true of most websites, we gather certain information about how you interact with our website.
When you use our website, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your Internet
Protocol (IP) address, browser type, browser language, the date and time of your request, the website pages you came from and exited to, and the operating system.
Our website and emails also use a standard technology called a “cookie” and other similar technologies (such as, pixels, tags and web beacons), which are small data files that are transferred to your computer when you use our website or interact with our emails. These technologies automatically identify your device whenever you interact with our website or emails.
a. Improve the user experience on our website; and
b. Track anonymous site usage and email activity.
The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser’s “Help” function or alternatively, you can visit http://www.aboutcookies.org, which explains, step-by-step, how to control and delete cookies in most browsers.
How do we use this information?
We use the information and data we collect principally in order to provide the Program and our website. More specifically, we may use your personal information to:
Administer the Program (including your accounts) and to operate our website;
Communicate with you regarding the Program and with respect to your questions and requests;
Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
Measure usage of the website;
Provide for the safety and security of the Program and our website;
Conduct research and similar activities to improve the Program and our website; and
Comply with our legal and regulatory responsibilities and to enforce our rights.
How is your information shared?
The Program is currently administered by Vestwell State Savings, LLC, dba Sumday Administration, LLC (“Sumday”). Your information will be shared with Sumday and others who support the Program, such as other government entities and service providers who may help us to verify your information or to detect fraud, professional advisors as well as to web-hosting providers, analytics providers, customer-relationship management software providers, and other similar information technology providers.
Your information is also shared with financial institutions with whom you invest through the Program.
Any court, governmental authority, law enforcement agency or other third parties where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.
To persons holding a legal or benefit interest relating to you or those acting in a fiduciary or representative capacity on your behalf.
How We Protect Your Information
The security of your personal information is very important to us. We have put in place reasonable operational, administrative, technical, and physical safeguards to protect the information we collect, as required by applicable law. We cannot guarantee, however, that all communications between us or information stored on our servers will be free from unauthorized access by third parties, such as hackers.
The Program and our website are not directed at children under the age of 13 and we do not knowingly collect personal information from children under the age of 13 through the Program and our website. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.
Links to Other Websites
The Program and our website may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using the Program and our website and click a link to another site, you will leave our website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites.
Updating and Correcting Your Information
Please note that you can make modifications to your information through the employee portal on our website once your account is established.
Contacting the CRSA