Welcome to the Privacy Policy for The Sandbox Companies, Inc. (“Sandbox”, “we”, “us”, or “our”). In this Privacy Policy, we describe what Personal Data (as defined below) we collect, how we use and share that information, and your choices concerning our information practices. Sandbox is a financial institution pursuant to the Gramm-Leach Bliley Act (the “GLBA”) and complies with all GLBA information security and data privacy requirements.
This Privacy Policy outlines how and when Sandbox collects, protects, shares, and uses information that can identify you individually (“Personal Data”), such as your name, email, or telephone number. Personal Data does not include information that is anonymous, aggregated, or can no longer be used to identify you as an individual.
This Privacy Policy applies to users of our website, https://www.sandboxwealth.com, (the “Site”, and such users, “Site Visitors”), our mobile application (the “App”), and our related technologies, products and services (collectively with the Site and the App, the “Services”). Our Services are designed to create the best place to manage and improve your financial life by enabling you to access personal financial management and advisory services, enabling you to open and access banking products provided by our banking partners, and enabling you to open and access lending products provided by our lending partners. When you apply for or obtain a financial product or service from Sandbox, Sandbox’s Federal Privacy Notices (Section 10 below) applies to the Personal Data you provide to us related to that financial product or service.
This Privacy Policy is incorporated into and forms part of our Terms of Service. Before using the Services or submitting any Personal Data to us, please review this Privacy Policy carefully and contact us if you have any questions. By using the Services, you are agreeing to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Services.
This Privacy Policy covers the privacy practices of Sandbox only. This Policy does not apply to the practices of third-party websites, services, or applications that you may access through the Services, including the products and services offered by Sandbox’s banking and lending partners. These third-party services are governed by each such third party’s privacy policy. Sandbox is not responsible for the privacy policies and practices of websites other than that of Sandbox, and Sandbox is not responsible for the failure of unaffiliated third parties to honor their privacy obligations.
We may collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) in the following circumstances:
We collect Personal Data from you when you voluntarily provide this information to us, such as when you register for access to our Services, contact us with inquiries, link your accounts, respond to offers from us or third parties, obtain or use products or services from us or third parties, or when you authorize our Services to collect this information about you from your financial institution, credit bureaus or others. Personal Data that you voluntarily provide depends on your use of the Services but may include your name, address, email address, phone number, tax identification number (such as U.S. social security number) or other government-issued ID number, date of birth, annual income, and other information about your finances and employment. It may also include biometric identification data, such as facial recognition scans; records and copies of your correspondence with us, if you contact us; and details of transactions and search queries you may carry out through the Services.
Please note that if you are located outside of the United States, by providing this information to us, you acknowledge and agree that this Personal Data may be transferred from your current location to the offices and servers of Sandbox and the authorized third parties referred to in this Privacy Policy, located in the United States.
When you choose to use the Services to link or view activity on financial or finance related accounts operated by a third party (e.g., your bank or credit card company), we collect Personal Data from that third party and others (each, a “Third Party Partner”) to enable us to provide the Services or certain features thereof.
When you choose to use the Services to access banking products from our banking partners or lending products from our lending partners, pursuant to our Terms of Service, you also expressly authorize Sandbox to access your Personal Data held by those partners, on your behalf as your agent pursuant to Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and you expressly authorize those partners to disclose your information to us. When that occurs, we collect Personal Data from those partners to enable us to provide the Services or certain features thereof.
When you interact with our Services, we receive and store certain information about your visit, use, or interactions. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store this information itself or it may be included in databases owned and maintained by our agents or service providers. Our Services may use this information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, and the domain names of our visitors' Internet service providers.
In particular, the following information is created and automatically logged in our systems:
Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, and how you interacted with the Services.
Cookies Information: Please see the “Cookies and Similar Technologies” section below to learn more about how we use cookies.
Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
Usage Information: We collect information about how you use the Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
Location Information: We may collect and use your location information (for example, by using your IP address to determine your approximate geographic location) through the Services in order to help us authenticate activity related to your account. We may also use your location information in an aggregate way as Aggregate Data (defined below). We do not share your location information with other users of our Services.
In operating the Services, we may use “cookies” and other similar technologies. A cookie is a piece of information that the computer hosting our Services gives to your browser when you access our Services. Cookies help provide additional functionality to our Services and help us to analyze usage more accurately. For instance, our website may set a cookie on your browser that allows you to access our Services without needing to remember and then enter a password more than once during a visit to our website. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of additional features of our Services. We may use third-party analytics service providers such as Google Analytics, Microsoft Clarity, Twilio Segment, and Mixpanel to assist us in analyzing your data, and we will provide them with your cookie information to do so.Advertising networks may also use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.Similarly, we use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.We may also allow third party service providers, including Facebook, to use cookies, pixels, or similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services and use that information to send targeted advertisements. These third-party service providers help us analyze how our users use our Services and can enhance your experience when you use our Services. We currently do not respond to “Do Not Track” (“DNT”) signals and operate as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
In general, Sandbox uses Personal Data we collect through the Services to:
Provide products and services you request;
Improve our offerings to you, including to develop new products and services;
Communicate with you or provide notices in connection with such products and services;
Process and respond to customer inquiries and provide support;
Detect security incidents and prevent fraud and illegal activities;
Fulfill our legal requirements and enforce our agreements;
Improve the content, functionality, and usability of the Services;
Communicate with you, either directly or through our service providers, including for marketing and promotional purposes;
Improve our marketing and promotional activities; and
For our other legitimate business purposes permitted by law.
In addition, Sandbox uses Personal Data to verify your identity in order to expedite your ability to obtain banking and lending products from our third-party partners. You expressly authorize Sandbox to use your identity verification information for its own purposes, as well as the purposes of its banking and lending partners from whom you have requested products and services.
In an ongoing effort to better understand and serve our users, we may also conduct research on our Customer demographics, interests, and behavior based on Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate or other non-identifiable basis (“Aggregate Data”), and we may share this Aggregate Data with our contractors, agents, and business partners. We may also disclose Aggregate Data in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes. In addition, we may share Aggregate Data with third party providers to permit them to make offers that are more relevant to you. We may collect and share Aggregate Data through the Services, through cookies, and through other means described in this Privacy Policy.
We may share your Personal Data in the following circumstances:
We may share your Personal Data where you have consented or otherwise given us permission to share your data. For example, if you want us to expedite your identity verification with a banking partner in order to open a deposit account, we will need to share your Personal Data with that banking partner. When you use the Services to request a banking or lending product from one of our partners, you expressly authorize Sandbox to share your identity verification information with that partner.
We will not share your name, address, email address, phone number, or tax identification number (such as U.S. social security number) with third party product providers for marketing purposes without your express consent. Note that when you decide to pursue an offer from a third-party product or service provider, you may be asked to provide additional information directly to that provider, including your Personal Data. Using our Services does not require you to provide any additional information directly to such providers, unless you wish to.
We may share your Personal Data with the financial institutions with whom you choose to link your account, third-party banking and lending partners, and other service providers that we use in delivering the Services. Examples include providers that provide us with technology services such as hosting, identity verification, support, payment, and email service. We provide these providers with only the Personal Data they need to perform their specific function, or to evaluate new potential vendors, and take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
We may share your information if required by applicable law or legal process, or if we believe it is in accordance with applicable law or legal process. This can include protecting the rights, property, and safety of Sandbox, our users, and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate or asset sale, merger, reorganization, dissolution, or similar event, your Personal Data may be part of the transferred assets.
We may provide your Personal Data to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements, such as lenders and loan brokers that can present financing offers relevant to you. These third-party financial institutions have agreed that they will not use or disclose your Personal Data except to effectuate the joint marketing agreement and as otherwise permitted by federal financial privacy laws. If you directly provide your Personal Data to these third parties, they may use or share it in accordance with their privacy policies.Sandbox does not share your Personal Data with or sell your Personal Data to any third parties for their marketing purposes.
No method of transmission over the Internet or electronic storage is 100% secure; however, we care about the security of your information and take reasonable measures designed to protect your personal information from unauthorized access and use by maintaining physical, electronic, and procedural safeguards in compliance with applicable law. These measures include computer safeguards and secured files and buildings.
You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from us at all times. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information may not be accessed, disclosed, altered, or destroyed. By using the Services, you agree to assume all risk in connection with the information sent to us or collected by us when you access, visit, and/or use the Services. This includes, without limitation, any personally identifiable information that you provided to Sandbox. Sandbox is not responsible for any loss of such information or the consequences thereof.
In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.
The Services are not intended for children or minors under the age of 18. We do not knowingly collect personal information from, or market to, children under the age of 18. If we become aware that a child under the age of 18 has provided us with personal information, we will take steps to comply with applicable legal requirements to remove such information.
Our business and Services may change from time to time. As a result, at times it may be necessary to make changes to this Privacy Policy. If we make changes, we will notify you by revising the “Last Updated” date at the top of this page. If we make material changes, we will do so in accordance with applicable legal requirements, and we will post a notice on our website and mobile applications alerting our users to the material changes prior to such changes becoming effective. Your continued use of our Services after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy.
If you have any questions or concerns about this Policy, you can contact us at:
The Sandbox Companies Inc.
info@sandboxwealth.com
228 Park Avenue South, Suite 35600
New York, NY 10003
Last revised: August 15, 2023
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
Social Security number and income
Account balances and account transactions
Checking account information and assets
All financial companies need to share consumers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers' personal information; the reasons Sandbox chooses to share; and whether you can limit this sharing.
Does Sandbox Share | Can You Limit This Sharing | |
|---|---|---|
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
For our marketing purposes — to offer our products and services to you | Yes | No |
For joint marketing with other financial companies | Yes | No |
For our affiliates’ everyday business purposes — information about your transactions and experiences | No | No |
For our affiliates’ everyday business purposes — information about your creditworthiness | No | We Don't Share |
For our affiliates to market to you | No | We Don't Share |
For our nonaffiliates to market to you | No | We Don't Share |
Email us at info@sandboxwealth.com.
The Sandbox Companies, Inc.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We collect your personal information, for example, when you:
Open an account
Seek advice about your investments
Seek financial or tax advice
Tell us about your investment or retirement portfolio
Give us your contact information
We also collect your personal information from other companies.
Federal law gives you the right to limit only
sharing for affiliates' everyday business purposes—information about your creditworthiness
affiliates from using your information to market to you
sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See "Other important information" section below.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
Sandbox has no affiliates.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Sandbox does not share with nonaffiliates so they can market their products to you.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Our joint marketing partners include banks, lenders and other financial companies.
You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.
In accordance with California law, we will not share information we collect about you with companies outside of our corporate family, except as permitted by law, including, for example, with your consent or to service your account. We will limit sharing among our companies to the extent required by California law.
In accordance with Vermont law, we will not share information we collect about you with companies outside of our corporate family, except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness within our corporate family except with your authorization or consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.
