Contents
Information We Collect
02
Sensitive Personal Information
03
How We Use Personal Information
04
How We Disclose Personal Information
05
Financial Privacy
06
Data Security
07
Data Retention
08
Your Privacy Rights
09
California Privacy Rights
10
How to Exercise Your Privacy Rights
11
Marketing Communications
12
Third-Party Websites
13
Children’s Privacy
14
Changes to This Privacy Policy
15
Contact Us
Version 4.2
Supersedes all prior versions.
LEGAL
Last updated: August 31, 2026
BeSmartee, Inc. (“BeSmartee,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information entrusted to us.
This Privacy Policy explains how BeSmartee collects, uses, discloses, and protects personal information when you visit www.besmartee.com or other BeSmartee webpages that link to this Privacy Policy (collectively, the “Website”), communicate with us, or otherwise interact with BeSmartee.
BeSmartee also provides technology and software services to financial institutions. When we process personal information on behalf of a financial institution or other customer in connection with those services, that institution generally determines how and why the information is processed, and BeSmartee processes the information in accordance with our contractual obligations and applicable law.
01
The personal information we collect depends on how you interact with BeSmartee.
We may collect information you voluntarily provide when you:
This information may include:
Information Collected Automatically
When you visit the Website, we and certain service providers may automatically collect information about your device and use of the Website, including:
We may collect this information through cookies, pixels, tags, analytics tools, and similar technologies. For additional information, see our Cookie Policy below.
BeSmartee provides software and technology services to financial institutions and other businesses. In providing those services, BeSmartee may process personal, financial, or other information provided by or on behalf of our customers and their consumers.
Depending on the services being provided, this information may include:
When BeSmartee processes this information on behalf of a customer, our processing is governed by our agreement with that customer and applicable law. Questions regarding information submitted directly to a financial institution should generally be directed to that institution.
02
Certain information processed through BeSmartee’s services may qualify as sensitive personal information or otherwise receive heightened protection under applicable law.
Depending on the applicable service, this may include information such as Social Security numbers, financial account information, credit information, government-issued identification information, or other sensitive financial information.
BeSmartee processes sensitive personal information only as reasonably necessary to provide services, comply with contractual and legal obligations, maintain security, prevent fraud, or for other purposes permitted by applicable law.
03
We may use personal information to:
04
BeSmartee does not disclose nonpublic personal information except as permitted or required by applicable law and contractual obligations.
We may disclose personal information to:
We may provide information to vendors and service providers that perform services on our behalf, such as website hosting, cloud infrastructure, analytics, marketing technology, communications, security, customer support, and professional services.
These providers are permitted to process information only as necessary to perform services for BeSmartee and subject to applicable contractual and legal requirements.
When BeSmartee processes information in connection with services provided to a financial institution or other customer, information may be made available to that customer and its authorized users as necessary to provide the contracted services.
We may disclose information to attorneys, accountants, auditors, consultants, insurers, and other professional advisers where reasonably necessary.
We may disclose information when reasonably necessary to:
Personal information may be disclosed or transferred in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or other corporate transaction, subject to applicable law.
05
BeSmartee provides technology to financial institutions and recognizes the sensitive nature of financial information processed through our services.
Where applicable, BeSmartee handles nonpublic personal information in accordance with contractual requirements and applicable financial privacy laws and regulations, which may include requirements under the Gramm-Leach-Bliley Act (“GLBA”).
BeSmartee does not disclose nonpublic personal information to nonaffiliated third parties except as permitted or required by applicable law or as necessary to provide contracted services.
Nothing in this Privacy Policy is intended to replace privacy notices that a financial institution may be required to provide directly to its customers.
06
BeSmartee maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction.
Access to sensitive information is restricted based on business need and appropriate authorization.
No method of transmitting or storing information is completely secure, however, and we cannot guarantee absolute security.
For additional information regarding BeSmartee’s security practices, please visit our Security page.
07
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide our services, comply with contractual and legal obligations, resolve disputes, maintain security, and enforce our agreements.
Retention periods may vary depending on the nature of the information, the context in which it was collected, applicable customer agreements, and legal or regulatory requirements.
08
Depending on where you reside and applicable law, you may have certain rights regarding your personal information.
These rights may include the right to:
These rights are not absolute and may be subject to exceptions under applicable law.
If BeSmartee processes your information solely on behalf of a financial institution or other customer, we may direct your request to that organization or assist it in responding to your request as required by our agreement and applicable law.
09
California residents may have additional rights under the California Consumer Privacy Act, as amended (“CCPA”), where the law applies.
These may include rights to know, access, delete, or correct certain personal information and rights relating to the sale or sharing of personal information and certain uses of sensitive personal information.
BeSmartee will not discriminate against you for exercising privacy rights provided by applicable law.
Where required, BeSmartee will recognize qualifying opt-out preference signals, such as Global Privacy Control, in accordance with applicable law.
10
To submit a privacy request or ask a question regarding your personal information, contact us at:
Email: info@besmartee.com
Mail:
BeSmartee, Inc.
Attn: Privacy / Compliance
31371 Rancho Viejo Rd #204
San Juan Capistrano, CA 92675
We may need to verify your identity before processing certain requests.
Authorized agents may submit requests on behalf of individuals where permitted by applicable law and subject to appropriate verification.
11
You may opt out of marketing emails from BeSmartee at any time by using the unsubscribe link contained in the communication or by contacting us at marketing@besmartee.com.
Even if you opt out of marketing communications, we may continue to send transactional, administrative, security, or service-related communications where appropriate.
12
Our Website may contain links to websites or services operated by third parties.
BeSmartee is not responsible for the privacy, security, or data practices of third-party websites or services. We encourage you to review their privacy policies before providing personal information.
13
The Website is intended for business and professional audiences and is not directed to children under 13.
We do not knowingly collect personal information directly from children under 13 through the Website. If we become aware that we have collected such information in circumstances not permitted by law, we will take appropriate steps to delete it.
14
We may update this Privacy Policy periodically to reflect changes to our practices, technology, legal requirements, or other factors.
When we update this Privacy Policy, we will revise the “Last Updated” date at the top of the page.
We encourage you to review this Privacy Policy periodically.
15
If you have questions or concerns about this Privacy Policy or BeSmartee’s privacy practices, contact:
BeSmartee, Inc.
Attn: Privacy / Compliance
31371 Rancho Viejo Rd #204
San Juan Capistrano, CA 92675
Email: info@besmartee.com
© 2026 BeSmartee, Inc. All rights reserved.
Terms of Service