Privacy Policy

Last revised on June 18, 2024

This Privacy Policy for Morrow Group, Inc. (“Morrow”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Morrow website (www.usemorrow.com), services, tools, features and functionalities (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, both when you sign up directly with us and in the context of our Services being offered through a corporate partner, such as your employer. If we make changes to this Privacy Policy, we will update the last revised date, post the updated version on our website and take any other steps necessary to comply with applicable law. Should you not agree with the revised terms of this Privacy Policy, you should not continue to use the Services.

Please read this Privacy Policy carefully. By using or accessing any of the Services, you agree to the use of your information it describes and to the other terms of this Privacy Policy and our Terms of Service. If you do not agree to this Privacy Policy, please do not access or use the Services.

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1. HOW WE COLLECT AND USE INFORMATION ABOUT YOU

When you access or use our Services, or otherwise engage with us, we may ask you to provide us with the following information about you:

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• Contact information: Name, email address, mailing address, and phone number. We collect this information to create and maintain your account, provide you with the Services, communicate with you about our Services (including to tell you about products or other services that may be of interest to you), respond to your queries, offer promotions and administer surveys.
• Account information: Username and password. We collect this information to create, maintain and secure your account. If you choose to register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately at contact@usemorrow.com.
• Professional or Employment-Related Information: This includes information about your occupation, title, employer information, employment history, and wage information.
• Payment information: Credit/debit card information, billing address and other payment or billing information if you provide it to us. We collect this information to complete transactions and provide you with aspects of the Services that you have requested.
• Information about your use of the Services: Services that you buy, place in your shopping cart, or otherwise express interest in. We collect this information to provide you with the Services, facilitate your engagement with the Services, personalize your experience,  monitor and analyze trends in connection with the Services and conduct internal research and development.
• Retirement related and other information you provide as part of receiving the Services or communicating with us: Information you share with us  as part of receiving the Services, such as your Social Security number, personal and/or business income, credit score, payment account information (e.g., credit card and/or loan balances, payment history, account numbers and other billing information), tax return information, details about your family, assets, savings and investments, your gender, date of birth, marital status, financial and retirement planning goals, household income, number of children and dependents, home ownership status, responses to our surveys and retirement questionnaires, social media handles and any other information that you choose to include in communications with us, for example, when sending us an email or otherwise communicating with us. We retain and use this information to provide the Services, facilitate your engagement with us, offer promotions, administer surveys, personalize your experience, monitor and analyze trends in connection with the Services and conduct internal research and development. In addition, we use this information to communicate with you about our Services (including to tell you about products that may be of interest to you).

Some features of the Services may require you to provide certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

We obtain information about you from other sources:

• If your company has engaged us to provide Services to its employees, we may receive professional and employment information about you, including information about your employer-provided retirement plans, in order for us to communicate with you, conduct initial consultations and otherwise provide Services to you and other employees who choose to engage with us.
• If you choose to participate in our refer-a-friend program or purchase an e-gift card for someone else, as well as collecting information about you, we will collect information about your friend (their name and email address) to invite your friend to shop with us and/or send them their e-gift card.
• Third parties that you choose to share with us, for example when you choose to access the Services through social media (e.g., Facebook or Instagram) or link any social media platforms to your account. In addition, if you interact with us on social media, we will collect information about those interactions.
• Third party service providers who help us process or supplement the information you have provided (e.g., from our payment processor).
• Other sources, such as from publicly available sources.

Any information that we receive about you from outside 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 their policies or practices. See Section 5 below for more information.

In addition, our website, like most websites, uses third party tools, including cookies, pixels and other tracking technologies (“Tracking Technologies”), including Google Analytics, to provide and enhance the performance of our Services, facilitate and enhance user experience, monitor and analyze trends, usage and activities in connection with the Services and conduct internal research and development. For further information about Google Analytics, please click here. The information we collect through Tracking Technologies includes:

• Details of the devices used to access our website, such as unique device identifier, browser type, device type, and operating system information.
• IP address.
• Precise location.
• Date and time stamps, such as the date and time you first accessed the Services.
• Log data.
• Other information regarding your interaction with the Services, such as clickstream data, referral activity, which emails you may have opened and ad impressions.

We may associate this information with your account (if you have a registered account), the device you use to access the Services, or email or social media accounts that you use to engage with Morrow.

In addition to the specific uses of information described above, we may use all of the above information to provide, improve and develop the Services and our product offerings, including as we describe in our Terms of Service, to comply with any applicable legal obligations, to enforce any applicable terms of service, to protect or defend the Services, our rights, the rights of our users, or others, for the purpose of combatting fraud, or to otherwise operate the Morrow business. Further, we may also aggregate and de-identify information so that it is no longer reasonably associated with an identified or identifiable natural person and use or share this data may then be used for any lawful purpose.

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2. HOW WE SHARE INFORMATION ABOUT YOU

We may share information about you with third parties in the following circumstances:

• With vendors and service providers, including cloud storage providers, payment processors, security vendors, data analytics vendors and our e-commerce platform.
• When you request us to share certain information with other third parties, such as through your use of social media widgets or login integrations.
• With our affiliates or otherwise within our corporate group.
• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In connection with an asset sale, merger, bankruptcy, or other business transaction.
• To enforce any applicable terms of service.
• To ensure the safety and security of Morrow and our users.
• With professional advisors, such as auditors, law firms, or accounting firms.

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.

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3. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule.  For example, in the Chrome menu bar, select: More > Settings > Privacy and security > Cookies and other site data > See all cookies and site data, where you can choose to allow or block all or certain cookies, and choose to clear cookies when you quit Chrome. In addition, to opt out of tracking by Google Analytics, click here.

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4. SOCIAL FEATURES

Certain features of the Services permit you to initiate interactions between the Services and third-party services or platforms, such as social media (“Social Features”). Social Features include features that allow you to click and access Morrow’s pages on certain third-party platforms, such as Facebook and Instagram and from there to “like” or “share” our content on those platforms or contribute to playlists. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both Morrow and the third party may have access to information about you and your use of both the Services and the third-party service. For more information on third-party websites and platforms, see Section 5 below.

5. THIRD PARTY WEBSITES AND LINKS

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.

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6. CHILDREN'S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information from children under 13 years of age. If we become aware that we have unknowingly collected information from a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below contact information to request that it be deleted.

7. DATA SECURITY

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you transmit to us you do at your own risk.

8. INTERNATIONAL USERS

The Services are designed for users in the United States only and are not intended for users located outside the United States.

9. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at contact@usemorrow.com.