Privacy Notice

Effective October 28, 2016

Society of Grownups is committed to maintaining your confidence and trust. And that means ensuring you understand how we collect, use, and disclose personal information about you in connection with your use of our SocietyofGrownups.com website, our social media pages, our educational services, and other services we may offer.

This notice sets out our privacy policies and practices with respect to information that we collect about visitors to and users of our SocietyofGrownups.com website, courses, digital tools, and social media pages.

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Contents

1. Collection and Use of Your Information
2. Sharing of Your Information
3. Your Choices
4. Security of Your Information
5. Social Media and Third Party Sites
6. Children's Online Privacy
7. Changes
8. Contact Us

1. Collection And Use Of Your Information

Personal Information We Collect

We collect your Personal Information – which means information that can be used to identify you as an individual – when you access our website. However, the types of Personal Information that we collect will vary depending on the extent of your use of our website and the services that you may receive from us.

Society of Grownups Website Users. You become a user of our SocietyofGrownups.com website simply by visiting any of the website’s pages. You also can become a member of Society of Grownups by creating an online account on the website. By creating an account, you gain access to additional features of the website, including functionality that allows you to take a detailed look at your current financial picture by linking your accounts from different financial institutions (we call this our “account aggregation functionality”).

When you create your online account, we collect the information you provide, including your name, email address, date of birth, and gender. Once you have established your account, you have the option to provide additional information, such as about your employment, income, spouse, family, and financial goals.

If you decide to use our account aggregation functionality, we collect user names and passwords for the bank accounts, credit cards, investment accounts, loans and other financial accounts that you want to link, in order to access your information from those financial institutions for you to view through our website. We do not store your usernames or passwords for these financial institutions on our servers. Once your financial accounts are linked to our aggregation functionality, we collect information about your accounts, including the name of the financial institutions, account balances, transactions, and holdings. You also can manually enter account types and account balances into the aggregation functionality without linking accounts.

We may collect information about you from other sources for various business purposes, including to provide you with any services you request or to help us comply with our legal obligations.

How we use your personal information

We use the Personal Information that we collect about you for a variety of business purposes, including for example:

• To verify your identity for purposes of providing you access to certain areas and features of the website;
• To develop and display content on the Society of Grownups website tailored to you;
• For users of our aggregation functionality, to pull your financial information from third-party financial institutions for you to view on the Society of Grownups website;
• To send you administrative communications and other notifications;
• To send you marketing communications about Society of Grownups services, company developments and news, or about other third-party products or services that you may be interested in;
• To perform research and analysis about your use of our website and services, and your potential interest in different products or services that could be offered by us or others;
• For customer service, by responding to any questions you have if you contact us; and
• For any other purpose disclosed at the time you provide Personal Information or otherwise with your consent.

If you choose not to provide certain Personal Information to us, your use of the Society of Grownups website may be substantially limited.

Other Types of Information We Collect And Use

Usage Information. When you visit and navigate through the Society of Grownups website, we or our third-party service providers use a variety of technologies that automatically collect certain information about your equipment and browsing activity. The information collected may include your browser type, device type, operating system, application version, access times, the webpages you visited, the links you click, and your use of other features or functionality on the website. This information helps us keep the Society of Grownups website fresh and interesting to our visitors and allows us to tailor content to a visitor’s interests.

Device Identifier Information. We also automatically collect your IP address or other unique identifier for the device used (computer, mobile phone, tablet, or other device) to access the Society of Grownups website. We may use this information to, among other things, administer the website, help diagnose problems with our servers, analyze trends, track users’ webpage movements, help identify users’ interests, and gather broad demographic information for aggregate use.

The technologies we use for this automatic information collection may include:

Cookies. A cookie is a small file placed on the hard drive of a device used to visit the Society of Grownups website. We or our third-party service providers use cookies for a variety of reasons, including for security purposes, to facilitate site navigation, to perform analytics, and to personalize your experience while visiting the website (such as allowing us to select content that is most likely to appeal to you, based on your interests, preferences, location, or demographic information).

Because an industry-standard Do-Not-Track protocol has not yet been established, our information collection practices will continue to operate as described in this Privacy Notice regardless of any “Do Not Track” signals that may be sent by certain browsers. However, you may refuse to accept cookies in order to prevent tracking activities by activating the appropriate setting on your browser. Please refer to your browser’s tools or help menu for instructions on how to disable cookies. If you select this setting, you may be unable to access certain features of the Society of Grownups website.

Pixel Tags. Pages of the Society of Grownups website, and promotional and other emails that we send to you, may contain pixel tags, which are small electronic files that allow us to track the number of users who have visited specific pages of the website, downloaded a particular document, or opened a Society of Grownups-related email. This information helps us to determine, among other things, the popularity of certain content.

Other Technologies. We may use third-party technology such as Google Analytics to analyze visitor traffic to and track activity on our website and social media pages. You can opt out of Google Analytics by downloading an opt-out browser add-on directly from Google.

We do not collect Personal Information from you through these automatic information collection technologies.

2. Sharing of your Information

We share your Personal Information with third parties only as described in this Privacy Notice or with your specific consent. We share Personal Information we collect about you with our affiliated companies and service providers. We may share other information, such as aggregate data that does not identify you, with our affiliated companies and third parties. WE DO NOT SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES.

Authorized Third-Party Service Providers. We share your Personal Information with authorized third-party service providers that perform business-related functions on our behalf, including but not limited to pulling and displaying financial information from your financial institutions for you to view through our website, supporting website functionality, and conducting research and data analysis for us. These service providers have access to your Personal Information only as needed for them to provide services on our behalf and are not permitted to use your Personal Information for any other purpose.

Our Affiliated Companies. We may share your Personal Information with our affiliated companies, including our ultimate parent company, Massachusetts Mutual Life Insurance Company, as permitted by law for their research and analysis. Your Personal Information will not be used by our affiliated companies to market directly to you or to establish your creditworthiness or eligibility for products or services that they may offer. For California residents, we will only share your Personal Information with our affiliated companies as permitted by law and, if the law requires us to obtain your consent or give you the opportunity to opt out of some types of sharing, we will do so before engaging in that type of sharing.

Business Transfers. We may share your Personal Information with another entity as a result of a merger, acquisition, reorganization, sale or other change of control of our business. In the event that such a transaction occurs, your Personal Information may be part of the assets transferred to the other entity.

Legal and Regulatory Purposes. We may share your Personal Information with third parties to comply with a legal obligation; when we believe in good faith that the law or a governmental authority requires it; to enforce our Terms of Use or other agreements; to address suspected fraud or other wrongdoing; to respond to an emergency; or to otherwise protect the rights, property or safety of our employees or others; and as may otherwise be permitted by law.

At Your Direction or With Your Consent. Otherwise, we share your Personal Information with third parties only with your specific consent or at your direction.

3. Your Choices

Not to Use Certain Features. You can control the Personal Information that you provide to us. However, certain Personal Information is required by us in order for you to create an online account on the Society of Grownups website and to use our aggregation functionality. As a result, you will not be able to take advantage of some features of the Society of Grownups website if you choose not to provide us with your Personal Information.

Update Your Personal Information. If your Personal Information such as your email address changes, you can update the information by logging into your online account on the Society of Grownups website and going to the Account Settings section.

Opt Out of Sharing. Federal law gives you the right to limit the sharing of your Personal Information in certain circumstances with our affiliated companies and other nonaffiliated third parties. State laws may provide you with additional rights. However, we do not share your Personal Information in any way that affords you the right to opt out of the sharing. Consistent with the commitments set forth in this Privacy Notice, if any sharing that we do of your Personal Information will require us to provide you the option to opt-out or opt-in to the information sharing, we will provide you with this option in advance of the sharing.

Not to Receive Marketing Emails. We will use your name and email address to send Society of Grownups-related promotional emails to you. You can direct us to stop sending you promotional emails by following the “unsubscribe” instructions included in a Society of Grownups-related promotional email you receive. Your opt-out request will be processed within 30 days of the date on which we receive it. Opting out of receiving promotional emails will not affect your ability to continue to receive other service- related, non-promotional emails from Society of Grownups, which you will not be able to opt-out from.

Delete Account. You can request to be removed from our systems by logging into your online account on the Society of Grownups website, going to the Account Settings section, and selecting the “Delete Account” button. After you delete your account, you will not be able to log into the Society of Grownups website or access any of your Personal Information. While we will work to remove your information from our systems, it is not always possible to completely remove or delete all of your Personal Information without having some residual data remain on our systems for some time. Also, if we shared your information with any third parties as described in this Privacy Notice, those companies are not required to delete your information.

If you were an investment advisory client of ours at any point, we will delete your account but need to retain certain Personal Information of yours in order to comply with our legal and regulatory obligations. After we delete your account, we will continue to adhere to our privacy policies and practices as described in this Privacy Notice with regard to any of your Personal Information still in our possession.

4. Security of Your Information

We take information security seriously and use reasonable security measures, including employing certain physical, electronic, and procedural safeguards, to help protect the Personal Information that we collect or you may provide to us. We restrict access to your Personal Information to authorized employees for permitted business purposes only and require our third-party service providers to protect your Personal Information and use it exclusively for the purpose of performing certain business functions on our behalf.

However, no electronic data transmission or storage of information can be guaranteed to be 100 percent secure. Although we take steps to secure your information, we cannot ensure or promise that the information you transmit to us will remain secure.

You need to maintain the confidentiality of your Personal Information too. You should be careful in how you share your Personal Information with others and avoid sending your Personal Information through unsecure, unencrypted email. You also should not provide your username and password to the Society of Grownups website to others. If you become aware of any suspicious activity associated with your online account on the SocietyofGrownups.com website, contact us immediately at info@societyofgrownups.com.

5. Social Media and Third-Party Sites

The Society of Grownups website includes functionality that allows you and other users to post publicly viewable comments to and communicate about our content. In addition, we use Society of Grownups-branded social media pages to promote and share events, developments, news, and other content. Any information that you post on our website’s message boards or on our social media pages is publicly accessible, can be used and collected by others, and is not subject to the provisions of this Privacy Notice.

Additionally, we may refer you through the Society of Grownups website, our social media pages, or other marketing materials to entities or websites that we do not own or operate. We do not control and are not responsible for these third parties, their content, or their privacy policies and practices. These third parties may solicit and collect Personal Information from you, and may use their own automatic information collection technologies, such as cookies, to independently collect other information from you. If you visit these third-party websites or provide any information to these third parties, your information is governed exclusively by their privacy policies.

6. Children’s Online Privacy

Our website and services are not directed to children. We do not knowingly collect personally identifiable information from anyone younger than 13 years of age. If a parent or guardian becomes aware that his or her child younger than 13 has provided us with personally identifiable information without his or her consent, he or she should contact us at info@societyofgrownups.com. If we become aware that we have unknowingly collected personally identifiable information from a child younger than 13 years of age, we will make reasonable efforts to delete such information from our records.

7. Changes

We may update this Privacy Notice from time to time to reflect changes in our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by posting the updated notice on the Society of Grownups website prior to the change becoming effective. We encourage you to periodically review the Society of Grownups website for the latest information on our privacy practices.

This Privacy Notice will continue to apply after you are no longer a user of our website, or an advisory client or other customer of ours.

8. Contact Us

If you have any questions or concerns about this Privacy Notice, please contact us at info@societyofgrownups.com.