Privacy Policy

Last Modified: April 28, 2022

Your privacy is important to us so we have created this privacy policy (this “Privacy Policy”) to explain what Personal Data we collect and why we collect it. This Privacy Policy is solely about Savvy Citizen which includes our website www.savvycitizenapp.com, and our mobile application Savvy Citizen (each, and collectively, “Savvy Citizen”).

You acknowledge that this Privacy Policy is part of the Savvy Citizen Terms of Use, and by accessing or using Savvy Citizen, you agree to be bound by both this Privacy Policy and the Terms of Use. If you do not agree to abide by both this Privacy Policy and the Terms of Use, please do not use Savvy Citizen.

Who Controls and Owns Savvy Citizen?

Management Science Associates, Inc. (“MSA”) controls and owns Savvy Citizen.

For more information, contact .

If you live in the European Economic Area, United Kingdom, Switzerland or the state of California, MSA controls your personal data and provides you with Savvy Citizen and related services. If you are seeking to exercise any of your statutory rights relating to Savvy Citizen, please contact our Data Protection Officer at . You may also contact MSA at:

Management Science Associates, Inc.
Attn: Savvy Citizen
6565 Penn Avenue
Pittsburgh, PA 15206

If located in the European Economic Area, United Kingdom or Switzerland, you may contact the following:

Management Science Associates, Inc.
Attn: Savvy Citizen
MSA Focus International Ltd Neptune Court, Vanguard Way
Ocean Park, Cardiff, United Kingdom CF245PJ

What Types of Personal Data Does Savvy Citizen Collect?

When a User or government entity accesses or uses Savvy Citizen, among the types of Personal Data collected are:

• All data manually entered into Savvy Citizen
• All data that has been authorized to use (read and/or write)
• All data collected to establish an account such as:
  • Your name
  • Address
  • Community where you reside
  • Email address
  • Cell phone number
  • Mobile carrier
  • Savvy Citizen username and password
  • IP addresses
  • Browser type
  • Phone type
  • Internet service provider (ISP)
  • Cookie
  • Usage Data

Other Personal Data collected may be described in other sections of this Privacy Policy or on Savvy Citizen itself.

Information We Receive From Your Use of Savvy Citizen. Your device collects data to estimate a variety of metrics. The data collected varies depending upon which device you use. When your device syncs with our application or software, data recorded on your device is transferred from your device to our servers.

Usage Data. When you access or use our services, we receive certain usage data. This includes information about your interaction with Savvy Citizen, for example, when you view or search content, create or log into your account, or otherwise open or interact with Savvy Citizen. We also collect data about the devices and computers you use to access Savvy Citizen, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, and cookie information.

Special Categories of Personal Data. To the extent that information we collect is a special category of Personal Data subject to the European Union's General Data Protection Regulation (“GDPR”) or the California Consumer Privacy Act of 2018 (“CCPA”), we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data. You can use your account settings and tools to withdraw your consent at any time, including by stopping use of a feature, or deleting your data or your account.

The Personal Data may be freely provided by the User, or collected automatically when using Savvy Citizen.

Any use of Cookies - or of other tracking tools - by Savvy Citizen, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for Savvy Citizen to provide its services.

Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our site. For government entities that sign-up for Savvy Citizen this includes payment information including credit card number, CVV number, expiration date and postal code. Please be aware that you are providing your personal information to these third parties and not to MSA.

The User assumes responsibility for the Personal Data of third parties published or shared through Savvy Citizen and declares to have the right to communicate or broadcast them, relieving MSA of all responsibility.

How We Use Information

MSA uses the information it collects from you for the following purposes:

Provide and Maintain Savvy Citizen. Using the information MSA collects, it is able to deliver and operate Savvy Citizen and honor its Terms of Use with you.

Improve, Personalize and Develop Savvy Citizen. MSA uses the information it collects to improve and personalize Savvy Citizen and to develop additional features. For example, MSA uses the information to troubleshoot and protect against errors, perform data analysis and testing, conduct research and surveys, and develop new features and services.

Communicate With You. MSA uses your information when needed to send you service notifications and respond to you. MSA also uses your information to promote new features and/or products it thinks you would be interested in. You can control marketing communications and most service notifications by using your notification preferences in account settings or via the “unsubscribe” link in an email.

Promote Safety and Security. MSA uses the information it collects to promote the safety and security of Savvy Citizen, its users, and other parties. For example, it may use information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce its terms and policies.

Why Is Personal Data Collected?

The Personal Data concerning the User is collected to allow Savvy Citizen to provide its services, as well as for the following purposes:

• Contacting the User;
• Analytics within the Savvy Citizen app;
• Displaying content from external platforms; and
• Providing Personal Data to third parties whom you have authorized MSA to release such data.

MSA uses cookies and similar technologies for the purposes described above.

For Personal Data subject to the GDPR and the CCPA, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and other tools; when the processing is necessary to perform a contract with you, like the Terms of Use; and our legitimate business interests, such as in improving, personalizing, and developing the services, marketing new features or products that may be of interest, and promoting safety and security as described above. For more information, please see the “Legal Bases” section below.

How and Where Will Personal Data Be Processed?

Method of Processing

MSA processes the Data of Users in a proper manner and takes appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to MSA, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by MSA. The updated list of these parties may be requested from MSA at any time.

Place

The Data is processed at MSA's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact MSA.

Conservation Time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this policy, and the User can always request MSA for their suspension or removal. In the event that you terminate your Savvy Citizen account MSA will continue to adhere to the policies and practices described in this policy.

With Whom Will We Share Your Information?

We may disclose aggregated information about our Users, and information that does not identify any individual, without restriction.

We do not sell your Personal Data that you provide freely or that we collect in connection to your use of Savvy Citizen.

We may disclose Personal Data that you provide freely or that we collect automatically:

• To our subsidiaries and affiliates to provide support to you in connection with Savvy Citizen.
• To contractors, service providers, websites linked to Savvy Citizen, and other third parties we use to support Savvy Citizen and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it. For example, if you opt-in to text-based notifications we will use your mobile number to send those notifications to you.
• To third parties whom you have authorized MSA to release your Personal Data.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your Personal Data:

• To the extent that it is required to do so by law, in legal proceedings or in the stages leading to possible legal action arising from improper use of Savvy Citizen or the related services or to establish, exercise or defend its legal rights.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe in good faith that disclosure is necessary or appropriate to protect the rights, property, or safety of MSA, our customers or others, or to investigate fraud.

Data Retention

MSA keeps your account information, including, but not limited to, your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of Savvy Citizen, we delete the data after it is no longer needed for the feature. We keep other information, like your activity data, until you use your account settings or tools to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the services. We also keep information about you and your use of the services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the “How We Use Information” section of this Privacy Policy.

The Rights of Users

MSA provides account settings and tools to access and control your Personal Data, as described below, regardless of where you live. If you live in the European Union, European Economic Area, United Kingdom, Switzerland (“the Designated Countries”) or the state of California, you have a number of legal rights with respect to your information, which your account settings and tools allow you to exercise, as outlined below.

Right to Opt-Out of the Sale of Personal Data. Under the CCPA and the GDPR, you have the right to opt-out of the sale of your Personal Data by a business. MSA does not sell your Personal Data that you provide freely or that we collect in connection to your use of Savvy Citizen.

Accessing and Exporting Data. By logging into your account, you can access much of your Personal Data. To receive the entirety of your Personal Data collected by Savvy Citizen in a commonly used file format, please contact MSA's Data Protection Officer at . Before your Personal Data that has been collected by Savvy Citizen is produced, you will be asked to verify your request and your identity. A request for the production of your Personal Data may be made by your authorized agent if your authorized agent provides your written permission to MSA.

Editing and Deleting Data. Your account settings let you change, correct and delete your Personal Data. For example, you may edit or delete the profile data you inputted in Savvy Citizen through your account settings. You may request the entirety of your Personal Data be deleted by submitting a request to MSA. Before your Personal Data is deleted, you will be asked to verify your request and your identity. A request to delete your Personal Data may be made by your authorized agent if your authorized agent provides your written permission to MSA. If you choose to delete your account, please note that while most of your information will be deleted within thirty (30) days, it may take up to ninety (90) days to delete the entirety of your information. We may also preserve data for legal reasons to prevent harm. Please note that deleting and/or removing Savvy Citizen from your device(s) does not delete, or request a delete, of your account and Personal Data.

Objecting to Data Use. We give you account settings and tools to control our data use. For example, through your account settings, you can limit how your information is visible to other users of Savvy Citizen; using your notification settings, you can limit the notifications you receive from MSA; and under your application settings, you can revoke access of third-party applications that you previously connected to your Savvy Citizen account.

If you live in a Designated Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests, including as described in the “How We Use Information” section of this Privacy Policy. You have a general right to object to the use of your information for direct marketing purposes. Please see your notification settings to control our marketing communications to you.

Restricting or Limiting Data Use. In addition to the various controls that we offer, if you reside in a Designated Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can always delete your account at any time.

If you need further assistance regarding your rights, please contact our Data Protection Officer at , and we will consider your request in accordance with applicable laws. If you reside in a Designated Country, you also have a right to lodge a complaint with your local data protection authority.

Users have the right, at any time, to know whether their Personal Data has been stored and can consult MSA to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any Data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to MSA at the contact information set out above.

Savvy Citizen does not support “do not track” requests.

To understand if any of the third party services it uses honor the “do not track” requests, please read their privacy policies.

Right to Non-Discrimination. If you choose to exercise your rights as a user of Savvy Citizen as outlined above, we will not discriminate against you or otherwise treat you differently than other users.

Information Security

MSA works hard and takes precautions to keep your data safe. We utilize a combination of technical, administrative, and physical controls to maintain the security of your data. This includes the measures to encrypt much of the data submitted to and collected by Savvy Citizen. However, no method of transmitting or storing data is completely secure. If you have a security-related concern, please contact MSA’s Data Protection Officer at .

In the case of breach of Personal Data, MSA shall without undue delay notify affected Users by describing the nature of the breach, providing contact information of its Data Protection Officer, and advising of the likely consequences of the breach.

In support of MSA’s efforts to keep your data safe, we recommend Users employ their devices’ password features and ensure that the settings on such devices allow Users to encrypt data.

Legal Bases

MSA is committed to providing our members with meaningful information and choices about the information they share through Savvy Citizen and the services. The GDPR requires organizations to have legal bases to collect, use, share, and otherwise process information about users residing in the European Union. If you habitually reside in the European Union, there are particular rights available to you. While some of these rights apply generally, certain rights only apply depending on the legal bases we rely on to process data. We have explained these legal bases and your rights below.

To provide Savvy Citizen and the Services. As described in the Terms of Use, Savvy Citizen cannot be provided, and the Terms of Use cannot be performed, without MSA processing your Personal Data. Since we process data you provide to us which is necessary to perform our contract with you, you have the right to port or transfer that data if you habitually reside in the European Union.

With your consent. We ask for your permission to process your Personal Data for certain purposes and you have the right to withdraw your consent at any time. When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time via your account settings. You also have the right to port or transfer the data.

Legal obligation or for the establishment, exercise or defense of legal claims. We process data where we have a legal obligation to do so, for example, where we're responding to valid and binding legal process from law enforcement agencies for certain data. In addition, processing may be needed for us to establish, exercise or defend civil or criminal claims in connection with actual or potential litigation including to protect Savvy Citizen and related services, our property or other legal rights, including those of our members or partners.

To protect vital interests. We process data where it is necessary to protect an interest which is essential to someone's life or protect any person from serious bodily injury. This includes processing information to combat harmful conduct both on and off of our Services.

Carrying out a task in the public interest. Where set forth by the law of the European Union or a member state thereof, we may process users' data to perform processing in the public interest. This may include protecting against harm and undertaking research for social good. You have the right to object to, and seek restriction of, our processing of your Personal Data when we process data using this legal basis.

In furtherance of legitimate interests. We process your information for our legitimate interests, and those of third parties, while applying appropriate safeguards that protect your privacy, rights and interests. We do this to:

• Market Savvy Citizen and other commercial products or services. For example, our partners may pay us to promote their products, services, events, gear or devices on Savvy Citizen. This is one of the ways we are able to provide the Services on a sustainable basis. We provide controls and safeguards for our members, including the ability to object.
• Maintain our business by conducting research and continuously improving the services so as to offer innovative and customized offerings to our members and partners.
• Convert it into aggregated form (by removing certain information, such as your name, and combining the resulting information with similar information from other members) for use by us and our partners. Our partners may use this information to improve infrastructure or for other commercial purposes, including developing useful insights.
• Keep the services safe and secure by using information to prevent or detect violations of our Terms of Use, fraud or abuse, and other harmful or illegal conduct. We may also share information with third parties, including law enforcement agencies for this purpose.
• Promote the services, including email and in-product marketing campaigns to inform members about our services.
• Encourage users to find new ways to interact, including activities, followers, clubs, or events. We rely on our legitimate interest in retaining members when ensuring that we offer new opportunities of interest to our users.

You have the right to object to, and seek restriction of, our processing of your Personal Data based on legitimate interests. Please contact MSA's Data Protection Officer at if you object to us using your information.

Changes to this Privacy Policy

MSA reserves the right to make changes to this privacy policy at any time by giving notice to Savvy Citizen Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using Savvy Citizen and can request MSA to erase the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data MSA has about Users.

Information about this Privacy Policy

MSA is responsible for this privacy policy.

Additional Information

Information Not Contained in this Policy

More details concerning the collection or processing of Personal Data may be requested from MSA at any time at its contact information.

Definitions

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number when a User accesses or uses Savvy Citizen.

Usage Data

When you access and use Savvy Citizen, we may automatically collect certain details of your access to and use of the app or website, including traffic data, logs and other communication data. We may collect information about your mobile device or computer and internet connection, including the device's unique device identifier, IP address, operating system, browser type and phone type.

User

The individual using Savvy Citizen, which must coincide with or be authorized by the data subject, to whom the Personal Data refers.

Cookie

Small piece of data stored in the User's device.