PRIVACY POLICY
Effective as of April 5, 2022
INTRODUCTION
Thank you for visiting My Milestones by Commerceᵀᴹ (“My Milestones”), an interactive financial education platform to help you improve your financial well-being.
My Milestones by Commerceᵀᴹ is operated by iGrad LLC. (“iGrad”). All services and products are the sole responsibility of iGrad. The information on this website is intended for general knowledge and does not constitute financial advice. We encourage you to review iGrad’s privacy policy available at https://commercebank.enrich.org/privacy for further information on how iGrad processes your information.
Commerce Bank, its parents and subsidiaries and affiliates, and any agent, independent contractor or assignee (collectively, “Commerce,” “we,” “our,” or “us”) receives certain information from iGrad based on your use of My Milestones by Commerce™. Commerce respects the privacy of your information. This My Milestones by Commerce™ Privacy Policy is designed to assist you in understanding what information we collect and how we use, share, and safeguard that information. For more information on how you can update, manage, access, and delete your information that Commerce collects, please visit our Online Privacy Policy available at https://www.commercebank.com/online-privacy-policy.
If you have a consumer financial product or service with Commerce Bank please view our U.S. Consumer Privacy Notice available at https://www.commercebank.com/security-center/privacy-statement to learn more about our privacy practices in connection with customer accounts.
From time to time, we may change this My Milestones by Commerce™ Privacy Policy. If we do, we will post an amended version on this webpage. Please review this My Milestones by Commerce™ Privacy Policy periodically.
1. COLLECTING AND USING INFORMATION
Personally Identifiable Information We Collect from iGrad
We collect Personally Identifiable Information from iGrad about you through your use of My Milestones by Commerce™. “Personally Identifiable Information” is individually identifiable information about an individual that we collect online and that we maintain in an accessible form.
We collect from iGrad certain Personally Identifiable Information that you may input into My Milestones by Commerce™, including date of birth, zip code, and your responses to interactive tools, such as your reported level of financial stress, what your financial goals are, types of debt you have, what type of insurance you have, and what benefits your employer provides. To the extent you input the following information on My Milestones by Commerce™, we will never receive salary, expenses, savings, credit score, or your Social Security number. We also collect from iGrad certain Personally Identifiable Information about your use and engagement with My Milestones by Commerce™ modules and tools, such as your passing score on a quiz and which modules or courses you start and complete.
How We Use Your Personally Identifiable Information
We use the Personally Identifiable Information we collect from iGrad to:
- Evaluate engagement with and the value of My Milestones by Commerce™ ;
- Confirm whether you are a current Commerce customer;
- Contact you regarding our products and services that we feel may be of interest to you;
- Based on an aggregated data level, identify programs and services that Commerce may provide to the employees of its business customers (i.e., employers);
- Maintain and improve our products and services;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business; and
- Comply with applicable law.
How We Share Your Personally Identifiable Information
We may share the information that we collect about you from iGrad in the following ways:
- With service providers who perform data-related services on our behalf (e.g., email, hosting, analysis, etc.);
- To service providers to prepare, deploy and analyze advertising content;
- To your employer, but only in an aggregated and deidentified format such as when we provide employers with aggregated reports showing which topics are of the highest interest to their employees*;
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
- To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
- To any other person or entity where you consent to the disclosure.
*Only select Commerce employees with administrative authorization to the iGrad platform will have access to individual users’ Personally Identifiable Information. All other reporting to Commerce and any reporting to Commerce business clients (i.e., employers) will be on an aggregated and deidentified basis.
2. SECURITY
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
3. HOW TO CONTACT US
To contact us for questions or concerns about our privacy policies or practices please email mymilestones@commercebank.com or contact us by mail at:
My Milestones by CommerceTM
Privacy Policy
8000 Forsyth, 4th Floor
Clayton, MO 63105
