Helpful Steps^® for Parents

PRIVACY POLICY

BMO HARRIS HELPFUL STEPS FOR PARENTS

BMO Harris Helpful Steps for Parents is an interactive website for you and your children, ages 5‑15, which provides information, activities and tools related to earning, investing, savings and spending money (the “Site”).  The Children’s Online Privacy Protection Act (“COPPA”) requires us to inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age.  This policy describes our practices with respect to information we collect from you, as well as from your child.

Personal information we collect from children

Children are not required to register or provide any personal information to use the Site or any of the activities and tools contained on the Site.  Children are not allowed to register  or post on the Site.  It is our policy not to collect personal information from children under 13.

Personal information we collect from parents

Parents are not required to register to use the Site, however, parents are required to register to provide comments on the Site and, if requested, receive newsletters or marketing materials.  Registration requires the parents to provide their first and last names, an email address, a screen name and password. The parent may, at the parent’s option, provide an address, telephone number, gender, and language preference.  The parent may also choose an age category that will help determine and tailor the topics of the Site.  Once registered, parents are permitted to post comments on the Site.  You are prohibited from including any personal information about your children, yourself or others on the Site.  We do not knowingly collect personal information about children on the Site.

Information we collect from children and parents related to use of the Site

Cookies are files that your Internet browser puts on your computer when you visit a site.  We use cookies to tell us how often you visit our Site, and what pages you go to on our Site.  The cookies do not contain any personal information as defined under COPPA about children under 13. 

We also use a third party service that uses clear gif images to track what pages you visit and in what sequence.  These Clear Gifs do not contain any personal information.  The third party service cannot identify or contact you as a result of this use.

How we use the information we collect

If you choose to receive marketing materials or other communications,  we will use your email address to provide the requested communication to you. We may also use your email address to communicate with you about administrative issues related to the Site.  We reserve the right to use information that does not identify your name, address or phone number for marketing purposes, for instance by displaying recent comments along with your provided screen name on the Site.

We use data collected to optimize the Site’s features and personalize your experience.  We also use aggregated data that does not identify you or your children personally to improve our existing service and develop new features.  You may choose to reject these cookies, but if you do, you may be unable to take advantage of all the activities and tools contained on the Site.  Refer to your browser’s help information on how to disable cookies.

Data retention

We will retain and use your information as needed to provide services for you.  In addition, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  Copies of information you post may remain viewable in the cached and archived pages of the Site, or if other visitors to the Site have copied or stored your information.

Security

We have implemented commercially reasonable safeguards to protect the information including personal information you submit and we collect.  Although we take certain security measures to protect your privacy, please be aware that no security measures are perfect or impenetrable.  You use the Site and post on the Site at your own risk.  The Site is a public site, and all comments you post on the Site may be viewed by anyone who views the Site.

Applicable law

Your use of the Site and all related matters will be governed by and construed in accordance with the laws of the State of Illinois and applicable federal laws, without regard to principles on conflicts of law.

Modifications of the privacy policy

We reserve the right to modify this privacy policy at any time and will notify you by posting any changes in a revised privacy policy on the Site.  Such modifications will become effective on the day noted in the new policy.  We encourage you to frequently review the privacy policy for any modifications.

If we decide to collect and or use personal information from children we will notify parents by email to obtain verifiable parental consent for the collection and usage of the child’s personal information.

Contacting BMO Harris Bank

If you have any questions, comments or concerns about the Site or this privacy policy call us at 1-888-654-0063.

Effective: September, 2011