Effective June 2022
1. Information we collect
(a) Information You Give to Us. When you access the Site and/or the Services, we may ask you to voluntarily provide us with certain information that personally identifies (or could be used to personally identify) you (“Personal Data”). Personal Data may include, without limitation, some of the following categories of information: (1) contact and profile data (such as your name, address, zip code, e-mail address, profile picture, and phone number); (2) your billing information; (3) questions, comments, and other information you provide on our private or public internet-based community sites and user forums, and (4) other information that you voluntarily choose to provide to us, including without limitation, unique identifiers such as passwords, and personal information that you send to us. You may still access and use some of the Services if you choose not to provide us with any Personal Data, but the features of the Services that require your Personal Data will not be accessible to you. We may also collect additional information, which may be Personal Data, as otherwise described to you at the point of collection or pursuant to your consent, and share this information with our business partners in order to provide the Services to you and as otherwise set forth herein.
(b) Information Gathered from Your Use of the Services. We automatically collect certain data when you use the Site and/or the Services, such as (1) IP address; (2) domain server; (3) type of device(s) used to access the Services; (4) web browser(s) used to access the Services; (5) referring webpage or other sources through which you accessed the Services; (6) geolocation information; (7) beta use information; (8) session information generated and stored on your computer systems; and (9) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). When you use the Services, we also collect data from your bank accounts and your usage thereof, including, without limitation, the description, amount, date, and category of the transaction (collectively, “Bank Data”), provided. Depending on applicable law, some Traffic Data may be Personal Data and some Bank Data may contain Personal Data.
2. How we collect information
We collect information, including Personal Data and Traffic Data, when you register on the Site, use and interact with the Services, fill out a form, use live chat, surf the Site, enter information on our Site, or provide us with feedback on our Services, as well as through Cookies, Web Beacons, website analytics services and other tracking technology (collectively, “Tracking Tools”) as described below. We collect Bank Data when you use the Services. We also may collect information about you from third-party sources.
3. Tracking tools
(b) Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect anonymous information about your use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send you. The information collected by Web Beacons allows us to monitor how many people are using the Services or opening our emails, and for what purpose.
(c) Website Analytics: We may use third-party website analytics services in connection with the Services, including, for example, recording mouse clicks, mouse movements, scrolling activity and text that you type into the Site. These website analytics services generally do not collect Personal Data unless you voluntarily provide it and generally do not track your browsing habits across websites which do not use their services. We use the information collected from these services to help make the Services easier to use and as otherwise set forth herein.
4. Information Provided By Or On Behalf Of Children
The Services are not intended for use by children under sixteen (16) years of age, and children under age 16 are prohibited from using the Services. We do not knowingly collect any information from children under 16. By accessing, using and/or submitting information to or through the Services, you represent that you are at least 16 years of age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, please contact us immediately. If we learn that we have received or inadvertently gathered any information from a child under the age of 16, we will use reasonable efforts to delete that information from our records as soon as reasonably practicable.
5. Use of data
6. Disclosure of data
We may disclose and/or transfer certain information that we collect from you (which may include Personal Data, Traffic Data, and/or Bank Data) as follows:
(c) Compliance with Law. We may disclose such information if we determine in good faith that such disclosure is needed to: (1) comply with applicable law, regulation, court order or other legal processes; (2) protect our rights, property or safety or that of another party; (3) enforce other agreements with you; or (4) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
7. Public information
Any information that you post in chat rooms or message boards on the Site or reveal in a review of the Services to us or on the Site or on any other website is public information and may be shared or used by us for any reason in our sole discretion.
8. Storage and security of information
9. Controlling your personal data
If you are a registered user of the Services, you may modify certain portions of your Personal Data directly within your account settings where possible, or by contacting us to make the required changes. If you close your account or the agreement by which you purchase the Services expires or otherwise terminates, we will delete your account and all Bank Data in your account without undue delay and will purge your profile data from our user database. Please note, however, that we reserve the right to retain information from closed accounts, including to comply with the law, prevent fraud, resolve disputes; enforce any agreement between you and us, and take other actions permitted by law. You must promptly notify us if you become aware that any of your account data is lost, stolen or used without permission.
10. Your sharing options
If you do not want to receive special offers, marketing communications, advertisements, newsletters or other promotional communications (“Marketing Communications“) from us, you may opt out by clicking the “Unsubscribe” link at the bottom of all marketing emails. Please note that once we receive your request, it may take up to ten (10) business days for such an opt-out to become effective. Also note that if you opt-out of our Marketing Communications, we may still email or communicate with you from time to time if we need to provide you with information or request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons. The Services will provide automatic analysis reporting emails which are fundamental to the delivery of the Services. This may be discontinued solely through discontinuation of your use of the Services.
11. Business Transitions
12. Links to other websites
14. California Residents Subject
Residents Subject to certain limitations under California Civil Code § 1798.83, California residents may ask us to provide them with (i) a list of certain categories of personal information that we may have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as provided below (see Contact Us). We do not receive any personal information from You (“Customer Personal Information”) as consideration for the Products or other items provided to You. We shall not have, derive or exercise any rights or benefits regarding Customer Personal Information. We will not sell Customer Personal Information, and shall not collect, retain, share or use Customer Personal Information except as necessary for the sole purpose of providing the Products. We agree to refrain from taking any action that would cause any transfers of Customer Personal Information, either to or from us, to qualify as a sale of personal information under the California Consumer Privacy Act of 2018 (AB 375), as amended (the “CCPA”). The terms “personal information”, and “sale” shall have the same meaning as in the CCPA.
15. Transfers of personal data
16. Contact us
Additional Information For European Union Users
Legal basis for processing. We only use your personal data as permitted by law. We are required to inform you of the legal basis of our processing of your personal data, which are described in the “Use of Data” section above. If you have questions about the legal basis of how we process your Personal Data, contact us using the contact information provided above.
Retention. We will only retain your Personal Data for as long as necessary to fulfill the purposes we have collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We keep basic information about our users for the duration of the agreement. In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Your Rights. European data protection laws give you certain rights regarding your Personal Data. You may ask us to take the following actions in relation to the Personal Data that we hold:
* Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
* Access. Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
* Correct. Update or correct inaccuracies in your Personal Data.
* Delete. Delete your Personal Data.
* Transfer. Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
* Restrict. Restrict the processing of your Personal Data.
* Object. Object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.
You can submit these requests by email to the address or email provided above in the contact us section or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Data or respond to your requests regarding your Personal Data, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
We engage certain third parties (“Subprocessors”) in order to assist us in connection with the Services, some of whom may have access to your Personal Data in conjunction with such processing. Please contact us for a list of our current Subprocessors.
Cross-Border Data Transfer
Whenever we transfer your Personal Data out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer, where required by EU data protection legislation, will be based on the Standard Contractual Clauses approved by the European Commission which impose data protection obligations on the parties to the transfer.
Please contact us for a copy of our Data Processing Addendum or if you want further information on the specific mechanisms used by us when transferring your personal information outside of the EEA.