ACORNS PRIVACY NOTICE

Effective January 1, 2020

FACTS	WHAT DOES ACORNS DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and account balances Transaction history and income Account transactions and checking account information When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Acorns chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Acorns share?	Can you limit this sharing?
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes — to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don’t share
For our affiliates’ everyday business purposes — information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes — information about your creditworthiness	No	We don’t share
For our affiliates to market to you	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?

Call 855.739.2859 or go to https://www.acorns.com/support/contact/

Who we are
Who is providing this Privacy Policy?	This privacy notice is provided by Acorns Advisers, LLC, Acorns Securities, LLC, Acorns Pay, LLC, and Acorns Grow Incorporated.

What we do
How does Acorns protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Acorns collect my personal information?	We collect your personal information, for example, when you: Pay your bills or make deposits or withdrawals from your account; Provide account information or give us your contact information; Show your government issued ID. We also collect your personal information from other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only: sharing for affiliates’ everyday business purposes — information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with an Acorns name.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include direct marketing companies.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial service companies.

Other important information

California: If your Acorns account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.

Vermont: If your Acorns account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.

Acorns Master Privacy Policy

This Privacy Policy sets forth how personal information is collected and used, that is provided on Internet Web site located at www.acorns.com (the “Site”) and our mobile application (collectively, “Acorns Technology”). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Acorns Technology by Acorns Grow Incorporated, Acorns Advisers, LLC, Acorns Securities, LLC, Acorns Pay, LLC, or any of their respective affiliates (together, for purposes hereof, “Acorns”). By using the Acorns Technology, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future (see "Change to this Privacy Policy" below).

Acorns is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy Policy explains how we protect personal information provided through the Acorns Technology and how we use that information in connection with our service offered through the Acorns Technology (the "Service"). "Personal information" for purposes of this Privacy Policy means information that identifies you, such as your name, address, phone number, fax number or email address.

Acorns stresses its privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.

Personal Information Collected

We collect the following personal information from you:

contact information such as name, email address, mailing address, phone number;
billing information such as credit card number, and billing address;
financial information such as bank or brokerage account numbers, types of investments;
Social Security number;
driver's license number;
unique identifiers such as username, account number, password;
preferences information such as product wish lists, order history, and marketing preferences; and
demographic information such as age, education, gender, interests, and zip code.

When you visit the Site or download and use our Services, we may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include the type of device you use, operating system, the device identifier (or "UDID"), your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our website, and other available information. We may also collect information about your use and interaction with the Site, our mobile application, or our Services. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account.

Information Use and Sharing

Acorns uses and discloses your personal information only as follows:

to analyze site usage and improve the Service;
to deliver to you any administrative notices, money alerts, and communications relevant to your use of the Service;
to fulfill your requests for certain products and services;
for market research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;
to third-party contractors that provide services to Acorns and are bound by these same privacy restrictions;
to enforce Acorns's Terms of Use; and as otherwise set forth in this Privacy Policy.

In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.

In addition, we may, from time to time, offer promotions with various businesses, websites, mobile applications or third parties, which may include opportunities for you to earn deposits within your Acorns account. Each such promotion will be subject to and governed by our Terms of Use, this Privacy Policy, and any applicable rules or terms and conditions we may post online, post in our mobile application, include within e-mail or other communications, or otherwise make available to you. To the extent you elect to participate in any such promotion or otherwise make any purchase subject to a promotion, we may share personal information such as name, e-mail address, purchase dates, and other related information with the applicable third party for the limited purpose of allowing the parties the make the promotion available and track participation within such promotion.

We may use information you provide to connect you with people you may already know. For example, through our mobile application we may identify contacts within your address book as potential new users of Acorns. We may match the contact information you provide to the information provided by other users to improve the Service, including making it easier to find contacts you may refer to Acorns that are not already customers.

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If Acorns Grow Incorporated is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Third Party Services

Acorns uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Acorns and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

If you choose to apply for an Acorns VisaTM debit card, you understand that such card is issued by Lincoln Savings Bank and you conform acceptance of Lincoln Savings Bank’s privacy policy.

In addition, when you activate your Acorns debit card, you will be asked to enroll in Local Found Money, a card-linked offer program offered in partnership with Empyr. Acorns and Empyr will use transaction information from your Acorns debit card in connection with the Local Found Money program as follows:

to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a Local Found Money offer;
to share transaction data with a participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or you have earned a particular reward; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
to provide participating merchants or Empyr aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and Empyr to assess the results of their campaign(s);
to create a record of the transaction data and thereafter maintain and use data in connection with operating the Local Found Money program;
to conduct analysis for the improvement and optimization of the Local Found Money program; and
to provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

If you choose an account with an Acorns debit card and confirm agreement to the Local Found Money Terms, you authorize the sharing, exchange and use of transaction data described above and herein by and among Acorns and Empyr, applicable payment card networks and applicable merchants. See Local Found Money Terms to learn more about the data collection, use, and sharing practices in connection with the Local Found Money program. If you would like to opt out of card linking and transaction monitoring in connection with the program, please see the Local Found Money Terms.

When you navigate to the “Acorns Merch Shop”, you are leaving Acorns.com. The Acorns Merch Shop is hosted by Shopify Inc. and any use of such page is governed by the Shopify privacy policy found at https://www.shopify.com/legal/privacy

User Access and Choice

If the personal information on file for you changes, or if you no longer desire our service, you may correct or update it by making the change on our customer information page or by emailing Acorns Customer Service.

We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at the information below.

Cookies / Tracking Technologies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Site. We do not link the information we store in cookies to any personally identifiable information you submit while on the Site.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.

If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as contests or surveys, may be limited.

The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and/or service providers use session ID cookies to make it easier for you to navigate the Site.

We employ (and/or our third-party advertising partner employs) a software technology called clear gifs (sometimes known as web beacons or web bugs), that help us better manage content on the Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. At this time, we do not recognize or respond to DNT signals.

Security

The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us.

California Collection Notice

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)), other than the personal information we collect in connection with providing financial products and services.

Depending on how you interact with our website and services, we may collect the following categories of personal information about you, in addition to the information we collect in connection with providing financial products and services:

Identifiers, such as your name and contact information, IP address, and mobile device identifiers
Commercial information such as purchase history
Internet usage information, such as browsing history, access history, and use and interaction with our website.

This information is used and disclosed for the purposes and to the categories of third parties described in the main privacy policy, above.

Your California Privacy Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.

California consumers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.

To exercise your rights, please send us an email at support@acorns.com. You will need to provide additional information to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Additional Information for California Residents

The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months. We do not sell information that directly identifies you such as your name and email address. We share certain information as set forth in the Information Use and Sharing section, above, and allow third parties to collect certain information about your activity, for example through cookies, as explained in Cookies / Tracking Technologies section, above. You can control these cookies through browser settings and other controls. We do not believe these activities are a sale of personal information.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about our Privacy Policy, please contact Acorns Customer Service at:

privacy@acorns.com

Acorns Grow Incorporated
5300 California Avenue
Irvine, CA 92617