Stash101® Privacy Policy

Last updated: September 16, 2021

Introduction

Welcome to Stash101! This Stash101 Privacy Policy (the “Privacy Policy”) solely covers Boulay LLC (“Stash101”) and the financial education and related products and services offered to you by Stash101. This Privacy Policy is supplemental to Stash Financial, Inc.’s Privacy Policy (the “Stash Privacy Policy”), which can be found at https://www.stash.com/theprivacypolicy. The Stash Privacy Policy expressly applies to Stash Financial, Inc., and any products and services offered by the following affiliates of Stash Financial, Inc.: Stash Investments LLC (our registered investment adviser), Stash Capital LLC (our registered broker dealer), Stash Cash Management LLC (our banking services affiliate), and Stash Insurance Services LLC (our insurance services affiliate) (such entities collectively shall be referred to hereunder as “Stash”). Please refer to the Stash Privacy Policy for more information on how your information is collected by Stash.

Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The personal information you share with us helps us provide a great experience with Stash101. That’s why we want to keep you informed of what personal information we collect, how it’s used, and when it’s shared. We are dedicated to protecting the personal information we collect from you and ensuring that it is handled with care and attention.

This Privacy Policy describes how Stash101 collects, uses, processes or discloses your personal information. Stash101 services are available to you through a variety of platforms, including, but not limited to stash101.com, stash.com/stash101 , and our mobile applications, which are accessible through a variety of connected devices. The website(s) and applications are collectively referred to as the “Stash101 Platform”. The term “Services” shall mean any product or service offered by Stash101 through the Stash101 Platform or that otherwise links out to this Privacy Policy.

This Privacy Policy applies to visitors of the Stash101 Platform, who view publicly accessible content and users who have created an account to use the Services. By visiting or browsing the publicly accessible areas of the Stash101 Platform, visitors are acknowledging that they have read, understood and agree to be legally bound by this Privacy Policy and our Terms of Use. If you do not agree to any of the terms in this Privacy Policy or the Stash101 Terms of Use, you may not access or use the Stash101 Platform. By signing up, or using the Stash101 Platform or our Services, you are agreeing to the terms of this Privacy Policy and the Terms of Use. Further, if you are signing up for the Services and creating accounts on behalf of one or more students, or if you’re agreeing to these Terms of Use on behalf of an organization or entity (for example, if you’re an administrator agreeing to these Terms of Use on behalf of your district), you represent and warrant that you’re authorized and have received any required consent to use the Services, and bind any student, organization or entity to this Privacy Policy.

1. What is COPPA ?

COPPA is the acronym for Children’s Online Privacy Protection Act (“COPPA”) – created and put into effect on April 21, 2000. This act applies to students under the age of 13 in the US to protect their personal information. A website operator must include in its privacy policy when and how to seek parental consent and what responsibilities the website operator, such as Stash101, has to protect its students’ privacy and safety online.

2. How Stash101 Complies with COPPA

To comply with COPPA, Stash101 does the following:

3. Privacy Policy Overview

Stash101 takes student privacy seriously; that is why we collect only the minimal amount of information from a student to provide the Services – just the unique code they have been given by their teacher/parent to connect with a classroom, their first and last name, username, and password. We do not ask for other information, such as gender, SSN, email, address, student ID, or age. Below, we give an overview of the Stash101 Platform, its educational function, and how we protect and secure student privacy.

“Personal information” is any information you provide to us that personally identifies you, such as your first and last name or email address, or other information that could be linked to such identifying information by us, or your child (in the case of a parent). We will only collect, use, and share your or your child’s personal information in accordance with this Privacy Policy.

This Privacy Policy applies whenever you (or your child) use the Services. Moreover, this Privacy Policy covers Stash101’s treatment of any personal information about our users that teachers, parents or other services might share with us (including any of the Stash entities listed above).

This Privacy Policy does not apply to websites or services or practices of companies that Stash101 doesn’t own or control, such as third party services you might access through links or other features (e.g., social media buttons, lesson plan resources, etc.) on the Stash101 Platform. These other services have their own privacy policies, and we encourage you to review them before providing them with personal information.

Please take the time to get to know our privacy practices. If you have any questions, you can contact us using the contact information provided in Section 20 below, and we will respond as soon as reasonably possible.

By using the Services, you acknowledge that you accept and agree to this Privacy Policy. If you do not accept this Privacy Policy, you (or your child) may not use the Services.

4. What is Stash101?

Stash101 is a wholly owned affiliate of Stash Financial, Inc. Stash101 provides an education software platform that teaches essential finance skills to students. Students create a profile that they can log in to, set up a profile picture (the student’s teacher or parent will be prompted to approve the photo taken by the student before it can be shared with other students), and resume. Students then manage virtual (not using real money) checking, savings, and credit accounts. Students may pay bills, purchase assets, and learn the advantages of saving. Teachers/parents can use Stash101 to help incentivize behaviors they want to see in the classroom like completing work and showing the school’s norms through deposit and withdrawals, called “Action Items”. Teachers/parents can also teach essential financial literacy skills through the use of Stash101 and its functions. Students have access to see, but not alter in any way, other students’ profile pictures, resumes, and personal account information.

Students can see other students in their class, a news log of virtual deposits and withdrawals made each day, a leaderboard to see the virtual net worth and ranking of students, their virtual bills and virtual assets, the teacher/parent approved profile pictures and student created resumes of a teacher’s class.

When students set up a Stash101 account, they input the unique code they have been given by their teacher/parent to connect with a classroom, their first and last name and then create a unique username and password. We do not ask students to enter any other personal information when setting up an account. If a student’s school or teacher wants to use any of the data created by a student such as their resume or transaction history, the school will be responsible for obtaining any necessary parental consent under COPPA.

School administration or other decision-makers in the school may choose to purchase a school account in Stash101. This allows the administration access to teacher and student accounts to add, edit, or delete student accounts transactions (deposits and withdrawals).

5. What Information does Stash101 Collect from students?

Stash101 collects the minimal amount of information from students necessary to create accounts for use of our Services: we ask students to provide a unique username, their first and last name, a password, and the unique code they have been given by their teacher/parent to connect with a classroom. We also collect some information automatically through some tools or software as part of the Services. We will not use or ask for parents’ or students’ email addresses, except to the extent otherwise provided below, and have no intention of spamming anyone. We do not ask students to enter any other personal information when setting up an account. See below for more information regarding the information we collect:

  1. Information users provide to us. There are currently four categories of users on our Services: schools, students, parents, and teachers. We described the information collected from the students above. For other users (schools, teachers, and parents), we collect and store the following types of information from each type of user:
    • Account Sign-up and Profile Information: To create a Stash101 account as a school, you will be asked to provide some basic information such as your first name, last name, school, location (city and state), username, and password. Schools may view teachers in that school’s account; however, no teacher or student profile is made available or visible to the public through the functionality of our Service. If you create a Stash101 account as a student, you will be asked to enter the code you have been given by your teacher or parent (students are unable to sign up for the Services without this), along with their first and last name, unique username, and password. Teachers may also give a letter of consent to use Stash101 located here. We do not ask students to enter any other personal information to create their student accounts. If you are a teacher, you will be asked to provide a first name, last name, school name, email address, location (city and state), username, password, and how you heard about Stash101.
    • School Information and Collaboration Features:If you are a teacher, as part of the profile information you provide, you may choose to associate your account with a school account or may enter a new school name, location (city and state), and how you heard about Stash101. By connecting you with your school, the Services may enable and provide additional collaboration features for teachers and school leaders within the same school, such as depositing and withdrawing different action items (incentivized behaviors) for students in different classes such as specials teachers.
    • Class Information: As a teacher, you can enter the class grade and the full names of the students in your class. If teachers need help with their account, they can contact the staff at Stash101 to access their account and help with training, which allows the staff to see some class information like a students’ full name, grade, net worth (not using real money), and virtual bank account amounts (not using real money). However, none of the Stash101 staff is permitted to share any of the information outside of Stash101 that they see when aiding a teacher in using the software.
    • Deposits and Withdrawals: As a teacher or school, you can customize a list of incentivized behaviors in the form of deposits or withdrawals that you want to encourage or recognize in student actions. These transactions can be seen and edited by the teacher or the banker job- a student in the class with access to editing and assigning bills to students in their individual class.
    • Parent Information: parents may only sign-up for Stash101’s waitlist to receive updates and/or information regarding the launch of our “at-home” Services. Parents may sign-up for the waitlist and receive such information and updates by visiting https://www.stash.com/stash101 and providing your email address.
    • Contact Information: When you choose to provide us with your personal information through the Services in some other manner (e.g., when you send us an email asking a question), we will store your contact information. This applies only to teachers or schools managing an account with us as we do not collect any contact information from students and we do not currently contact parents in this respect.
  2. Information Stash101 automatically collects. Like most web-based services, we may automatically receive and log information on our server logs from your browser or your device when you use the Services. For example, this could include the frequency and duration of your visits to Stash101 on Google Analytics. If we combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy. The technologies and information we automatically collect include:
    • Cookies and other similar technologies: Cookies are tiny pieces of data that are attached to your browser – to track certain preferences about your online behavior. We may use various technologies to collect and store information when you visit our Services, including through cookies and Google Analytics. Like many services, Stash101 uses these technologies to tailor the Services for you and improve your user experience. See our Cookie Policy for more information regarding cookies and other similar technologies.
    • Device information: We collect device-specific information such as your operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how the Services are performing and improve Stash101 for you on your particular device.
    • Log information: Like most online services, when you use our Services, we automatically collect and store certain information in our server logs. Examples include things like: (i) details of how you used our service, such as your activity on the Services, and the frequency and duration of your visits to the Stash101 Platform; (ii) SMS routing information; (iii) IP address; and (iv) device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request, and referral URL. This information helps us make decisions about what we should work on next or improve upon on Stash101.
    • Location information: When you use our Services, we may collect and process information about your geographic location, for example, through GPS, Bluetooth, or Wi-Fi signals on Google Analytics. We collect both coarse (i.e., city-level) location data and precise location data. If we collect precise geolocation information (“precise” meaning sufficient to identify street name and name of city or town) from you (such as when a teacher is searching for a school), we ask for your explicit opt-in permission. We do not collect precise geolocation data from students. We will not store or track your device location on an ongoing basis or without your permission. We do not share precise geolocation data with third parties other than our service providers as necessary to provide the Services.

6. How does Stash101 use the Information it Collects?

Stash101 does not sell or rent any of your, your child’s, or your student’s personal information to any third party for any purpose, including for advertising or marketing purposes. Third party targeted advertising from third parties is not permitted on Stash101. We only use the information you provide us to:

7. Photos and Videos (User Content)

When students create an account, they are able to upload a picture of themselves. This photo is sent to be approved by the teacher/parent prior to others being able to see it. If we discover that we have collected information from a student in a manner that is inconsistent with COPPA, we will take appropriate steps to either delete the information or immediately seek the parent’s consent for that collection. We do not disclose any personal information about students to third parties, except to service providers when necessary to provide the Services, as required by law or to protect the security of the Services or other users. Information collected from students (including personal information and information collected automatically) is never disclosed for third party advertising or for any third-party targeted advertising, and student’s personal information is never sold or rented to anyone, including to marketers, advertisers, banks, or other financial institutions. If a teacher chooses to set up their students’ accounts, he, she or they can choose to provide full names for students (e.g., first name and last name) when setting up their class; they can also opt to only provide non-identifying information (e.g., provide the required information under alias).

8. What student’s information is visible to others?

The student’s profile, picture, and resume are never made available or visible to the public through Stash101. Teachers/parents may share profiles with other teachers/parents and administrators in the building, but without a media release and/or written permission from a legal guardian, students’ information is not available to use for any reason outside of the school. In addition, students can see each other’s profile pictures, resume, classroom jobs, net worth (not using real money), net currency (not using real money), and transactions (not using real money) through the news log and class ranking. This is similar to how a teacher might display classroom jobs, behavior charts, and progress toward a specific goal around the classroom. The only other time student information or teacher information is visible to others is when the teacher contacts Stash101 to assist in setting up, managing, navigating, editing, or deleting their account(s). Stash101 staff will also periodically access teacher accounts to see if they are using the account and send follow up emails with how to better use the software but they will not change, alter, or delete any information unless asked to do so by the teacher.

9. Will Stash101 share any information it collects?

Stash101 will not share or disclose any information about teachers, schools, parents and students unless under the below circumstances. And even if we share information under these circumstances, it will be in line with this Privacy Policy and COPPA.

  1. Other Users You Share and Communicate with on Stash101: No teacher, administrator, parent, or student profiles are made available to the general public through our Services. Please keep in mind that information (including personal information or student's personal information) or content that you voluntarily disclose to others, including to other Stash101 users you interact with through the Services (such as messages you might send other users or other teachers and administration you collaborate with), can be viewed, copied, stored, and used by the people you share it with. We cannot control the actions of people with whom you choose to share information.
  2. Stash101 Staff/Employees: If teachers need help with their accounts, they can contact the staff at Stash101 to access their accounts and help with training, editing, deleting, or adding information to the accounts. When the Stash101 staff accesses the teacher’s account, they can see the class information like students’ full names, grades, net worth (not using real money), virtual bank account amounts (not using real money), etc. However, none of the Stash101 staff is permitted to share any of the information outside of helping the teacher in using the software to its fullest extent.
  3. Third-party integrations on our Services: When, as a teacher or administrator, you use third-party apps, websites, or other services that use, or are integrated with our Services, they may receive information about what you post or share. For example, when you invite others via Facebook or Twitter, these services receive the information that you share through this functionality and information that you are sharing from Stash101. Information collected by these apps, websites, or integrated services is subject to their own terms of use and other policies.
  4. Third Party Service Providers: Third-party targeted advertising is not permitted on the Stash101 Platform. We do work with vendors, service providers, and other partners to help us provide the Services by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions. For example, sending emails on our behalf, database management services, database hosting, data analytics, providing customer support software, and security. These service providers do not have the right to use any personal information we share with them beyond what is necessary to assist us. Additionally, these service providers must adhere to confidentiality and security obligations in a way that is consistent with this Privacy Policy.
  5. Testimonials: We may post testimonials on the Stash101 Platform which may contain personal information such as the full name, photo, and/or a video of the individual in the testimonial. We obtain the individual’s consent in advance to ensure we have permission to post this content. To request removal of your personal information from our testimonials, please contact us using the contact information provided in Section 20 below.
  6. Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information publicly, including with users, partners, or the press in order to, for example, demonstrate how Stash101 is used, spot industry trends, or to provide marketing materials for Stash101. Any aggregated information shared this way will not contain any personal information.
  7. Legal Requirements: We may disclose personal information if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of Stash101, our employees, our community, or other users, or to prevent violations of our Terms of Use or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests or summonses.
  8. Sharing with Affiliates: Stash101 is a wholly-owned subsidiary of Stash Financial, Inc. We may share your personal information with our parent companies, affiliates, subsidiaries, joint ventures, or other companies that we control, are controlled by, or are under common control with, including, Stash Financial, Inc., Stash Investments LLC (our registered investment adviser), Stash Capital LLC (our registered broker dealer), Stash Cash Management LLC (our banking services affiliate), and Stash Insurance Services LLC (our insurance services affiliate), and any other affiliated Stash entities we may create or form in the future, in a way that is consistent with this Privacy Policy.
  9. Change of control: To comply with our obligations in the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event. If your personal information is part of the transferred assets, you will be notified via email and/or a prominent notice on the Stash101 Platform of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
  10. With your consent: Other than the cases above, we will not disclose your personal information for any purpose unless you consent to it. Additionally, as discussed above, we will never sell or rent your personal information to advertisers or other third parties.

10. How does Stash101 Protect and Secure your Information?

Your Stash101 account is protected by a password. You can help us protect against unauthorized access to your account by keeping your password secret and confidential at all times. The security of your personal information is important to us. We work hard to protect our community, and we maintain administrative, technical, and physical safeguards designed to protect against unauthorized use, disclosure, or access to personal information. We make every effort to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems; however, no practices are 100% immune from attack, and we cannot guarantee the security of information at all times. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you electronically in accordance with any applicable laws so that you can take appropriate protective steps. For example, we may post a notice on the Stash101 Platform or elsewhere on the Services. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

11. Can I opt-out of providing information?

You can always decline to share personal information with us, or even block all cookies. However, if you choose to do so, it is important to remember that many of Stash101’s features may not be accessible or function properly.

12. How can I access and manage my personal information?

Stash101 aims to provide you with easy access to any personal information we have collected about you. If that information is incorrect, we give you easy ways to update it, or to delete it, unless we have to keep that information for legitimate business (e.g., we need at least an email address for your account) or legal purposes. Upon request, Stash101 will provide you with information about whether we hold any of your personal information, and if you are a user of Stash101, you may request access to all your personal information we have on file by contacting us using the contact information provided in Section 20 below. In some cases, we will not be able to guarantee complete access due to legal restrictions. For example, you will not be allowed to access files that contain information about other users or information that is confidential to us. We may not be able to fulfill requests that are unreasonably repetitive, require disproportionate technical effort, or would be extremely impractical.

13. How can I delete my account?

You can delete your account at any time by contacting us using the contact information provided in Section 20 below. If you are a school, teacher, or student, you can delete your account anytime by logging into your account and deleting your profile from the profile options. When you delete your account, we delete your profile information and any other content you provide in your profile (such as your full name, username, password, email address, and profile photo).

14. Parental Choices

If you are the parent or legal guardian of a student who has created a Stash101 account and you do not want your student to have a Stash101 account, please contact us using the contact information provided in Section 20 below.

15. How Long Does Stash101 keep student information?

We only keep a student’s personal information for as long as the student’s account is active – unless we are required by law to retain it, need it to ensure the security of our community or our Services, or to enforce our Terms of Use. More specifically, Stash101 operates a 3-tier student data protection policy to protect all students’ information (3-Tier Student Data Protection Policy):

  1. Minimal information:As mentioned before, Stash101 collects the minimal amount of information from students necessary to create accounts on our Services: we ask students to provide just the unique student code given by their teacher or parent, a username, their first and last name, and a password.
  2. One-year deletion policy for account profiles and transaction history: To protect students, Stash101 sets limits on how long students account profiles and transaction history is retained. Teachers can also delete students individually or the entire class by entering their password.
  3. Deleting inactive accounts: If a student’s account is not in use for twelve months or more (meaning there have been no logins), Stash101 will automatically delete the student account, including all personal information about that student.
Teachers also have the ability to delete their students from their account by logging into their account and then typing in their password to confirm that they would like to delete all of their students. Stash101 strongly encourages teachers to delete all student data at the end of their time with that student to help protect student data.

16. How long does Stash101 keep information about teachers/schools/parents?

We store your personal information for as long as it is necessary to provide the Services to you and others, including those described above. Personal information associated with your account will be kept until your account is deleted. Please note that we may have to retain some information after your account is closed, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent the abuse of our Terms of Use. You can, of course, delete your account at any time, as stated above.

When you sign up to receive our Services, sign up to our waitlist (parents), or receive promotional messages, marketing, advertising, and other information that may be of interest to you about Stash and its various products and services, we will send you periodic emails that we believe will be of interest to you. To opt out of marketing emails, simply click the labeled “unsubscribe” link at the bottom of any such email we send you.

Information connected to parents, schools or teachers that is no longer necessary or relevant to provide our Services may be de-identified with other non-personal data to provide insights which are commercially valuable to Stash101, such as statistics of the use of the Services.

17. Organization Accounts

Companies can sponsor a group of teachers and customize the Stash101 experience. To join an organization, a teacher must request access via the partner organization, and they will be provided with an organization pin to link their account. Once a teacher account is linked to an organization, the organization will gain access to the teacher account for support. A partner organization may see teacher and student account information throughout the support process. Organizations only have access to anonymized and aggregated student data (see section 5 of this Privacy Policy to understand collected information). To have a teacher account unlinked from an organization, contact us using the contact information provided in Section 20 below.

18. Social Media Plugins/Widgets

The Services may now or in the future include social media plugins, such as Facebook, Twitter, Pinterest, or Instagram. These social media plugins may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the plugin to function properly. Social media plugins and widgets are either hosted by third parties or hosted directly on the Stash101 Platform. Your interactions with these social media plugins are governed by the privacy policy of the company providing each social media plugin.

Further, to the extent we offer a widget and you add a widget to the Stash101 Platform through the interactive instructions displayed on your mobile device, you are expressly authorizing Stash101 to display certain of your personal information outside of the Stash101 Platform on your mobile device.

19. How will Stash101 notify me of changes to this Privacy Policy?

We may update this Privacy Policy from time to time. You can see when the last update was by looking at the “Last Updated” date at the top of this page. If we make any significant changes, we will provide prominent notice by posting a notice on the Stash101 Platform. We encourage you to review this Privacy Policy from time to time to stay informed about our collection, use, and disclosure of personal information through the Services. If you do not agree with any changes to the Privacy Policy, you may terminate your account by contacting us using the contact information provided in Section 20 below. By continuing to use the Services after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.

20. Contact Us

If you have questions or concerns regarding this Privacy Policy, or about Stash 101’s information handling practices, or if you have a complaint, please contact us at one of the following:

Mail:

500 7th Avenue, 8th Floor

New York, NY 10018

Email: Stash101support@stash.com

Phone: (720) 583-4116