Last Updated January 20, 2023
MetLife Consumer Services, Inc. ("MetLife") recognizes the importance of protecting all personal information.
BY INSTALLING, USING, REGISTERING OR OTHERWISE ACCESSING THE PROGRAM OR THE APP, YOU AGREE TO THIS POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT INSTALL, USE, REGISTER OR OTHERWISE ACCESS THE PROGRAM OR APP. MetLife reserves the right to modify This Policy from time to time, so please review it regularly. If we make any material change in how we collect your personal information online, or how we use or share it, we will notify you.
What information does This Policy cover?
This Policy only applies to personal information collected in connection with participation in the Program, including downloading, registering, or using the App, and does not apply to personal information collected by MetLife through any other means. The Program and App are only available to United States residents.
This Policy describes the types of personal information we may collect, how we collect and use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.
How do we collect your personal information?
Situations when you make personal information available to MetLife include but are not limited to: (i) registration in the Program; (ii) asking to receive information about our products or services; (iii) participating in any MetLife promotion or survey; (iv) authorizing the App to link to third parties; (v) requesting technical support; and (vi) otherwise using the App where personal information is requested or required.
We may also get information about you from third parties where authorized by you or permitted by applicable law. For example, we may receive personal information from:
- Your service providers. If you choose to sync a third-party account or service with the Program or the App, we will receive information from that account or service according to your settings with that account or service.
- Identity verification providers. We may utilize service providers who help us verify your identity or to ensure the accuracy of your information.
- Third parties we may work with, if you instruct, or authorize them to provide your information back to us.
What types of personal information do we collect about Program participants?
The types of personal information may vary depending on the activity you are engaged in. The personal information MetLife may collect and process includes, but is not limited to:
- Contact information and identifiers, such as your name, telephone number, address, digital signature, last four digits of your social security number, employee ID, e-mail address, phone number, photo or other image, birthdate, gender, marital status and number of dependents;
- Information about your preferences, such as survey responses, money mood and challenges taken while using the App;
- Behavioral information, to understand how you use the App and make improvements as appropriate;
- Biometrics, should you choose to use this method of authentication; please note that MetLife does not directly request biometric data, but you may choose to use this method of authentication to login to the App, in which case, we may receive anonymized data in the form of a token.
- Financial information you provide to us or authorize us to obtain, which may include income and commercial information such as records of purchases (including time and location), loan and debt information (including type and payment amount), credit score information, and the last four digits of your credit or debit card;
- Professional or employment-related information, education-related information; and
- Location data. Your location information may be collected with your permission through use of geolocation services. Should you choose not to permit access to your location information, some App features may not be available to you.
We do not knowingly collect personal information from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with their personal information, that parent or guardian should contact us at firstname.lastname@example.org. We will delete any personal information regarding a child under the age of 13 within a reasonable time. MetLife takes children's privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times.
How is your personal information used?
We will collect personal information to the extent reasonably necessary to provide the Program to you, to fulﬁll your requests and our legitimate business objectives, and where necessary to comply with legal requirements.
For example, we may use your personal information to:
- Deliver the services you request;
- Authenticate your identity;
- Process your registration of the App;
- Analyze your survey responses and feedback;
- Analyze use of the App and participation in the Program;
- Analyze your behavior, interests, and characteristics in order to recommend or suggest products and services that may be offered by Upwise, MetLife, or third parties;
- Personalize and enhance the Program, communications, and App experience;
- Provide technical support;
- Send service communications related to your enrollment in the Program; and
- Send marketing communications related to our products to you. Note that you can opt-out from marketing communications at any time.
We may disclose your personal information to our service providers so that we or they can perform requested services and provide certain features in accordance with the Program. We will only disclose personal information to our service providers that they need in order to perform a service or provide a feature of the Program that you have opted into.
Anonymous, aggregate information, comprising financial account balances, other financial account data, or other available data that is collected through your use of the Program, may be used by us and our service providers to conduct certain analytical research, performance tracking and benchmarking, create new Program content, and/or improve MetLife products. Our service providers may publish summary or aggregate results relating to metrics comprised of research data, from time to time, and distribute or license such anonymous, aggregated research data for any purpose, including but not limited to, helping to improve products and services and assisting in troubleshooting and technical support.
How is your personal information shared?
We may share your personal information to our afﬁliates and others for any purpose allowed by law.
We may share your personal information with:
- MetLife affiliates for the purposes outlined above;
- Our service providers so that we or they can perform requested services and provide certain features in accordance with the Program;
- Your employer
- Third parties with whom you may connect using our App; and
- Regulatory authorities or other parties as required by law.
We will not share your personal information, survey responses or feedback with your employer without your permission. We may share aggregate, unidentifiable information regarding App usage and Program participation with your employer.
Your personal information will not be sold to third parties.
If you register or log in to your Upwise account through a third-party social networking or other integrated authentication service (what we call an “Integrated Service”), such as Apple, Facebook or Google, we may also collect personal information that is already associated with your Integrated Service account as authorized by that service. You may also have the option of sharing additional personal information with Upwise through an Integrated Service.
MetLife and our service providers will retain your personal information for as long as you participate in the Program or use the App, in accordance with our records retention schedule or as required by law. Should MetLife cease operating as a going concern or we otherwise cease to make the Program and/or App available to users, your personal information will be retained as required by law and remain subject to the protections set forth in this Policy.
Purchase or Sale of Businesses
From time to time, we may sell one or more of our businesses and the information we have collected may be transferred as a part of the purchase or sale. If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personal information in accordance with applicable law. The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings.
Third Party Terms and Conditions
Please note that your access to and use of the App may be subject to certain third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, and third parties whose services you access through the App. You recognize and agree that MetLife is not liable for any such third-party terms and conditions and their use of your personal information. MetLife may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that while using such products or services, you are using products or services developed and administered by people or companies not afﬁliated with or controlled by MetLife. MetLife is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that MetLife is linking to those products or services does not constitute our sponsorship of or afﬁliation with those people or companies.
What choices do you have about the collection, use, and sharing of your personal information?
We won’t share your personal information with third parties for their own marketing purposes without your consent. If you sign up to receive newsletters or other e-mail messages from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message. For California residents, you may click here to learn about additional rights regarding your personal information: https://www.metlife.com/about-us/privacy-policy/california-residents/.
What kinds of security measures do we take to safeguard your personal information?
MetLife follows generally accepted industry standards and maintains reasonable and appropriate safeguards to ensure the security, integrity, and conﬁdentiality of the information in MetLife's possession. Only those persons with a need to access your personal information in connection with the fulﬁllment of their tasks in accordance with the purposes of This Policy and for the purposes of performing technical maintenance have access to your personal information in MetLife's possession. Personal information collected by MetLife is stored in secure operating environments that are not available to the public. We have technical, administrative, and physical security measures in place to protect your personal information from unauthorized access and improper use. However, no system can be 100% secure and there is the possibility that despite MetLife's reasonable efforts, there could be unauthorized access to your personal information.
How can you update your personal information?
You can email MetLife Financial Wellness (email@example.com) to submit any changes to your contact or other personal information, as well as opt out from marketing.
How can you ask questions, or send us comments, about This Policy?
If you have questions or wish to send us comments about This Policy, e-mail us at firstname.lastname@example.org. or call or write to us at:
P.O. Box 489
Warwick, RI 02887-9954
How will you know if we amend This Policy?
We may amend This Policy at any time. You should review This Policy regularly for any changes – the date of the most recent update will be made available on our website: https://www.upwise.com/privacy-policy/. If we make any material change in how we collect your personal information online, or how we use or share it, we will notify you.