Acorns Early Privacy Notice

Acorns Early Privacy Policy

Last Revised 18th November, 2024

GoHenry, Inc. (d/b/a “Acorns Early,” “we,” “our,” us”) respects your privacy, and we are committed to protecting it through our compliance with this privacy policy for U.S. residents (this “Privacy Policy”). This Privacy Policy describes the types of information we may collect from or about you and how we use, maintain, protect, and disclose that information. Please read this Privacy Policy carefully if any of the following applies to you:

• If you visit our website at www.acorns.com/early (“Website”);
• If you apply to receive any of our communications through any channel (inclusive of communications from both Acorns Early and GoHenry domains);
• If you use our Services (as such capitalized term is defined below),whether as a child, parent, or third party (such as a relative of a cardholder wishing to send money through our platform);
• If you otherwise use the Acorns Early app or the GoHenry app on your smartphone, tablet, and/or other device;² or
• If you apply for or are accepted for a position of employment with us.

For the purposes of this Policy, the Website, the Acorns Early and GoHenry mobile applications, communications, and payment platform for both Acorns Early and GoHenry are referred to as our “Services.” Please read this Privacy Policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing our Website and using the Services, you agree to this Privacy Policy.

I. COLLECTION OF INFORMATION

We collect personal information from you when you use the Services. When we use the term “personal information” in this Privacy Policy, we mean information that we collect from or about you or your devices. This includes information that identifies, relates to, describes, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with you or your device, as well as information we collect about the services you use, content you view on our Website and any details you submit. The personal information that we collect about you depends on whether you are a:

• Parent/guardian, relative, or customer of our Services;
• Child user of our Services
• Individual who gives money using our Services (“Gifter” or “Relative”);
• Visitor to our Website or prospective customer; or
• Job applicant or employee.

In addition, the type of information that we collect from you depends on your particular interaction with us.

A. Information We Collect Directly From You

In order to provide you with the Services, we may ask you to provide us with certain details or information. The personal information we collect about you depends on whether you are a parent/guardian (and customer of Acorns Early), a child user of our Services, a Gifter or Relative (who gives money using our Services), a visitor to our Website or prospective customer, or job applicant or employee.

Parents/guardians (who are customers of Acorns Early)

Please refer to our Child Privacy Disclosure Notice.

Users over the age of 13

Information that you submit through the Services or that we otherwise collect may include:

• Basic contact information, including name, phone number, email address, postal address.
• Account information, including date of birth, passwords, password hints, security questions and answers, and other similar information.
• Identification information, such as date of birth, photograph, or copies of passport, drivers’ license or other government identifications, or utility bills.
• Financial information, such as the last four digits and expiry date of your Acorns Early card, and other similar financial information.
• Phone contact information, such as names, email addresses and telephone numbers stored in your mobile contact list.
• Any other information you directly provide when filling out a form, corresponding with us (e.g., via email or conversations with our customer services team (“Customer Support”) or by phone or chat sessions), providing us with feedback, reviewing our products, and other similar information.

Gifters and Relatives (who give money to a user of our Services)

Information that you submit through the Services or that we otherwise collect may include:

• Basic contact information, including name, email address, postal address.
• Identification information, such as the date of birth of Relatives who create accounts.
• Financial information, such as bank account information, and other similar financial information.

Visitors to our Website or Prospective Customers

• Any information you directly provide when filling out a form, corresponding with us (e.g., via email or conversations with Customer Support by phone or chat sessions), providing us with feedback, reviewing our products, and other similar information.
  

Job applicants/employees

• Basic contact information, including name, phone number, email address, postal address.
• Professional and employment-related information, such as job title and company.
• Education information, such as the information included in your curriculum vitae.

B. Information We Collect Automatically

When you use our Services, or visit our Website, we automatically collect certain information that is sent to us by your computer, mobile phone, or other device. To do this, we may use cookies, pixels, web beacons/clear gifs, and other tracking technologies (“Tracking Technologies”). The information collect may include:

• Device and technical information, such as IP address, iOS IDFA, iOS IDFV, Android GPS, ADID, device user agent functionality, browser type and version, operating system and platform, hardware, and other similar information.
• Usage data, such as the full uniform resource locators (URLs), information about page response times, lengths of visits to certain pages, page interaction information (such as scrolling, clicks, mouse-overs), error reports and performance data (i.e., details of the software or hardware related to an error, content of files you were using when an error occurred), troubleshooting and help data, and other similar information.

To learn more how we use cookies and other tracking technologies, see the “Cookies and Tracking Technologies” section below.

C. Information We Collect from Third Parties

We may obtain payments data from your third-party bank, including the name of your issuing bank, cardholder name, card expiry date, country of issue, card payment method, name and location of merchant, and similar information in connection with your use of the Services. Any information that we receive from third-party sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s privacy practices.

II. HOW WE USE PERSONAL INFORMATION

• Service delivery.
  We may use your personal information to:
  • provide, operate and improve the Services and our business;
  • fulfill your requests for products and services;
  • communicate with you about the Service, including by communicating with you through text messages, chat features, sending announcements, updates, security alerts, money alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience with the Service and our communications;
  • facilitate your invitations to friends who you want to invite to join the Service;
  • support our legal or regulatory reporting obligations and risk management procedures (e.g., in relation to anti-money laundering or know your customer (KYC) requirements); and
  • troubleshoot and provide support for the Service, and respond to your requests, questions and feedback.
• Marketing and advertising.
  We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
  • Direct marketing. We may send you direct marketing communications, including through text message or email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
  • Interest-based advertising. We may engage third-party advertising companies that use cookies and other technologies to collect information about your interaction (including the data described in the Automatic Data Collection section above) over time across the Service, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share users’ contact data with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your Privacy Rights and Choices section below.
  • Promotions. We may use personal information to provide the promotional programs that we offer. We may provide these programs in collaboration with affiliate brand partners and other businesses, websites, mobile applications or third parties. Each such program will be subject to and governed by our Cardholder Terms, Terms of Use, this Privacy Policy, and any other applicable rules or terms and conditions that we or the relevant third parties may post or make available to you.
• Research and development.
  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. We may process your personal information as well as the personal information of other individuals from whom we collect such information by creating aggregated or deidentified data. Such aggregated or deidentified data is non-personal information. We may use this aggregated or deidentified data and disclose it to other parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
• Compliance and protection.
  We may use your personal information to:
  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including fraud, cyberattacks and identity theft.
• Retention.
  The length of time we retain particular categories of personal information is determined based on whether it is sufficient to fulfill the purposes for which we collected it, including to satisfy legal, regulatory, accounting, or reporting requirements, establish or defend legal claims, enforce our agreements, resolve disputes or fraud prevention, or as otherwise permitted under applicable law.

III. HOW WE SHARE PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Service providers that provide services on our behalf or help us operate the Service or our business (such as mail delivery, hosting, information technology, chat feature support, customer support, email delivery, text message delivery, marketing, consumer research, website analytics, maintenance, analysis, audit, payments, fraud detection, marketing and development); and/or subcontractors (such as companies we have hired to assist in protecting and securing our system and services may need access to personal information to provide those function). We enter into contracts with our service providers that require them to handle your personal information only as consistent with this Privacy Policy.

Financial institutions. Our banking partners such as Community Federal Savings Bank, card processor, issuing bank, investment services providers, payment services provider, risk and security system providers.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Affiliate brand partners. When you make a purchase on one of our affiliate brand partner sites, we may share information about you with those affiliate brand partners to operate the relevant promotional program, for example, so that we can credit your account with any earned rewards.

Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with affiliate brand partners or other third-parties with whom we are collaborating in our promotional programs or to offer you additional services. We will share personal information that is needed for these other companies to make the promotion available, provide the services that you have requested and track participation in the promotion or service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Parties (and their advisors) to business transactions or proposed transactions involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Acorns Early or our affiliates (including, in connection with insolvency, bankruptcy or similar proceedings).

IV. CHILDREN’S PRIVACY

In line with children’s privacy laws, we require your consent to our child privacy notice complete account activation.

When you create an account for a child under the age of 13 (“Child Account”), the account will be accessible from the internet and via our mobile application.

In order to carry out these online activities, we must collect a modest amount of information from these devices directly in order to deliver the features and functionality of the Acorns Early account, which is legally defined as "Personally Identifiable Information" under the Children’s Online Privacy Protection Act ("COPPA").

Your consent is required for the collection, use, or disclosure of information we collect online from your child directly, and we will not collect, use, or disclose any personal information from a child under 13 without the parent’s consent. You can provide your consent either on the website or via the Mobile app when you activate your child’s Acorns Early Card.

In addition to the information requested at the time you set up the Child Account, such as the name of the child and his or her date of birth, or telephone number, if available, our website or mobile applications will collect information from the connected device, including the following information necessary to participate in our services:

• name, telephone number, date of birth (as you as parent provide);
• account-related security information such as passwords, password hints, or other authentication related items;
• one or more persistent identifiers that can be used to recognize a user over time, and across different websites and online services;
• transaction information, senders and receiver’s names and registration information as well as other similar transaction information;
• device and technical information, such as IP address, device user agent functionality (browser type and version, operating system and platform, hardware used) and other similar device and technical information;
• website or mobile app technical usage information, such as the full uniform resource locators (URLs), information about page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), error reports and performance data (i.e. details of the software or hardware related to an error, content of files you were using when an error occurred), troubleshooting and help data plus other similar usage information;
• and account-related activity data, such as purchases, budgeting information (if the child chooses to use budgeting tools).

In our records, this information will be paired with name or other identifying information you provide to us. We use this information only to deliver our Service, and will not disclose it to third parties, except for business partners who are bound by contractual or other obligations to only use the information for such purposes, and to keep the information confidential.

“Limit Ad Tracking” will be on by default for Child Accounts. This means that children do not receive targeted advertising. A Child Account will not be able to opt in to receive marketing materials from Acorns Early. We will notify the parent cardholder of material changes to the service or issues with the account, rather than the Child Subaccount holder.

We may also use personal information for internal purposes such as auditing, data analysis, and research. We may use, transfer, and disclose non- personal information about child accounts (i.e., information that does not include IP Address, name, or other persistent identifiers) for any purpose.

You can review your child’s personal information, ask us to delete it (consistent with any independent regulatory obligations to maintain books and records), or refuse to allow further collection or use of your child’s information at any time.

VI. YOUR PRIVACY RIGHTS AND CHOICES

In this section, we describe the rights and choices available to all users.

If you are a California resident, please click here to see the additional terms that apply to you. Privacy laws, other than the CCPA, apply to much of the personal information that we collect, use, and disclose. When these other laws apply, personal information may be exempt from, or outside the scope of the privacy rights described below. For example, information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability, is exempt from CCPA rights requests. We therefore may decline all, or part of your request related to exempt personal information. This means that we may not provide some, or all, of this personal information when you make a right to access request. We may also not delete or correct some, or all, personal information when you make a deletion or correction request.

Certain Nevada consumers may opt out of the sale of “personally identifiable information” for “monetary consideration,” as defined under Nevada law, to a person for that person to license or sell such information to others. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any future sales under Nevada law by contacting us as detailed in the “Contact Us” section above. Please note we take reasonable steps to verify your identity and the authenticity of the request.

Access or update your information.

If you have an Acorns Early account, you can review and update information in your account settings.

Privacy rights.

Depending on where you live, applicable law may provide you with certain rights regarding your personal information:

• Right to access. You can request a copy of certain personal information that we have collected about you and have it provided in a portable, machine-readable manner.
• Right to deletion. You can request that we delete personal information that we collected from you.
• Right to correction. You can request that we correct inaccurate personal information that we have collected about you.
• Right to opt-out. You can request to opt-out of disclosures of your personal information that constitute “selling” of your personal information as defined in applicable law.

Please note that our ability and/or obligation to fulfill such requests may be limited by applicable law. You may submit requests to exercise your right to access, deletion and correction by emailing Customer Support at help@acornsearly.com or writing to Acorns Legal, 5300 California Ave., Irvine, CA 92617. The rights described above are not absolute, and in certain cases, we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Based on where you live, you may have additional rights in relation to your personal information that we have collected about you.

Identity verification.

We need to verify your identity to process your requests to exercise your rights to access, deletion, and correction, and we reserve the right to confirm your entitlement to exercise these rights under the laws in your jurisdiction. To verify your identity, we may require you to log into your Acorns Early account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email address or telephone number used to make the request, provide government identification, and/or to provide a declaration under penalty of perjury, where permitted by law.

• Marketing Preferences
  If you are a user of our Services, you can update your preferences with regard to marketing by either logging into your account or by contacting us at: unsubscribe@acornsearly.com.
• Opt-out of marketing communications.
  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at: unsubscribe@acornsearly.com. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP as further set forth below.
• Mobile location data.
  If you have previously opted into sharing your device’s precise geolocation information, you can opt-out in your mobile device’s settings. Blocking web beacons. Most browsers offer settings that allow you to configure your device to prevent images that would include web beacons/clear GIFs from loading.
• Interest-based advertising.
  Steps you can take to opt-out out of use of your personal information for interest-based advertising include:
  • Browser settings. Blocking third-party cookies in your browser settings.
  • Privacy browsers/plug-ins. Using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings.
  Using Google’s and Facebook’s opt-out tools to opt-out of their use of your information for interest-based advertising:
  • Google: https://adssettings.google.com/
  • Facebook: https://www.facebook.com/about/ads
• Ad industry tools.
  Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance: optout.aboutads.info.
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
  • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to opt-out. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the ad industry opt-out mechanisms that we linked to above.

Do not track.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals except where we expressly indicate otherwise. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

• Declining to provide information.
  We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
• Close your account.
  To request that we close your Service account or delete your personal information associated with your account, please close your account in the Acorns Early App by navigating to the ‘Family Settings’ screen within the ‘Account’ section or by contacting Customer Support to request account closure. Certain personal information associated with your account may be retained after account closure in accordance with our data retention policies where required or permitted by applicable law.
• Other sites and services
  The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
• Security
  We employ, test and regularly re-evaluate appropriate technical, organizational and physical safeguards designed to protect the confidentiality, integrity and security of the personal information we collect, both when we receive it and during transit, such as by encrypting credit card numbers and other sensitive personal information that you enter into the Service. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

VII. SMS TERMS

• Opting in: if you want to opt-in to a text message service, text JOIN to 20148. Message frequency may vary.
  
• Opting out: if you wish to opt-out from a text message service, you can do so at any time by texting STOP to 20148. After you send the message “STOP” to us, we will send you a reply to confirm that you have been unsubscribed. After this, you will no longer receive messages from us. If you want to join again, just sign-up as you did the first time, and we will start sending messages to you again.
• Help: if at any time you forget what keywords are supported, just text “HELP” to 20148. After you send the message “HELP” to us, we will respond with instructions on how to use our service, as well as how to unsubscribe.

Before opting in to a text message service, please be aware of the following terms (the “ SMS Terms”):

For text messaging in the US, by requesting, joining, agreeing to, enrolling in, signing-up for, acknowledging, or otherwise consenting to receive one or more text messages (“Opting In”), you accept these SMS Terms.

We will always use reasonable commercial efforts to deliver the automated marketing text messages to the number you provide through compatible wireless carriers. Carriers and Acorns Early are not liable for delayed or undelivered messages. The short code we use for some text message services may not be supported on all US carriers.

The list of participating carriers is as follows: AT&T, Verizon Wireless, Sprint, T-Mobile, U.S. Cellular, Boost Mobile, MetroPCS, Virgin Mobile, Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central, IL (ECIT), Cellular One of Northeast Pennsylvania, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless).

As always, please know that message and data rates may apply for any messages sent to you from us, and to us from you. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

By Opting In to a text message service, you:

• consent to the handling of your personal information as described this privacy policy, and agree to resolve disputes with Acorns Early as described in our Cardholder Terms available on www.acorns.com/early/cardholder-terms/;
• expressly authorize Acorns Early to use autodialer or non-autodialer technology to send text messages to the cell phone number associated with your opt-in;
• expressly authorize Acorns Early to include marketing content in any such messages;
• consent to the use of an electronic record to document your opt-in; and
• confirm that you are the subscriber to the relevant phone number, or that you are the customary user of that number and that you are authorized to opt-in. Acorns Early may terminate any text message service or your participation in it at any time with or without notice.

These SMS Terms still will apply if you withdraw the consent mentioned above or opt-out of the text message service.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

For all questions about the text message service, please do not hesitate to contact us on help@acornsearly.com or call us on (855) 739-2859.

VIII. DATA SECURITY AND DATA RETENTION

We have developed, implemented and seek to maintain an information security program with administrative, technical, and physical safeguards designed to protect you information. You should take measures to protect your personal information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the section entitled “Contact Us” below.

We will retain your information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required, or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as provided by law.

IX. LINKS TO EXTERNAL SITES

We may provide links to third-party websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. Information you provide on public or semi-public venues, including information you share on third-party social media platforms (such as Facebook or Instagram) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

X. CHANGES TO PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you via email or in-app notifications. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. IF YOU DO NOT AGREE TO ANY UPDATES TO THIS PRIVACY POLICY PLEASE DO NOT ACCESS OR CONTINUE TO USE THE SERVICES.

XI. INTERNATIONAL USERS

This Privacy Policy applies to individuals located in the United States. If you are not located in the United States, please review the applicable privacy notice for your jurisdiction.

XII. CONTACT US

Should you have any questions about our privacy practices, including as they pertain to child accounts, or this Privacy Policy, please contact us at:

Acorns Early
Customer Support
5300 California Avenue, Irvine, CA 92617 USA
help@acornsearly.com

or via our toll-free number:

(855) 739-2859

¹ As set forth below, this Privacy Policy applies to users of both the Acorns Early app and the GoHenry app, and who may have either an Acorns Early account or GoHenry account. As used herein, “account” or “your account” is inclusive of both Acorns Early and GoHenry account holders.

² This Privacy Policy applies to both the “Acorns Early” app and the “GoHenry” app.