Effective Date: 06/15/2017
01. Information We Collect
02. How We Use Your Information
03. How We Disclose Your Information
04. Cookies and Other Tracking Mechanisms
05. Third-Party Analytics
06. Do Not Track Disclosure
07. Third-Party Links
09. Your Choices
10. Your California Privacy Rights
12. Contact Us
Information We Collect
We collect information about you directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources.
Information We Collect Directly from You. We collect information about you directly from you. For example, if you create an account with us, we will collect your name, phone number, email address, bank account information, debt account information, prepaid card information, or other payment-related information. We may also collect other information, such as driver’s license number, passport information, and other governmental identification information. We will also collect any other information that you provide to us through our Services. For example, we will collect your email address if you sign up for our newsletter through our Site.
Information We Collect About You from Third Parties. We may also collect information about you from third parties. For example, if a family member or friend creates an account to help you pay off your debt, we will collect your debt account information from that family member or friend. In addition, if you log into our Services through a social networking accounts, such as Facebook or Google, we obtain your name and username and any other publicly available profile information. [Note: Please review for accuracy. Please also note that the Facebook Platform Policy says that you should only collect the information that you need: https://developers.facebook.com/policy/#login.]
Information We Collect Automatically Through Our Services. We automatically collect information about you through your use of our Services, including, without limitation, your IP address, location, browser type, device type, operating system and version, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, and the links you click and your other activities within the Services. In addition, we will collect information about spending and paying habits, such as the frequency of your payments and the amounts that you spend. [Note: Please review the language I added regarding collecting information about spending/paying habits for accuracy.] Please see our Cookies and Other Tracking Mechanisms section below for more information about how we automatically collect information about your use of our Services. We may combine information we collect automatically through our Services with information we collect directly from or from third parties.
How We Use Your Information
We may use your information, including personal information, for the following purposes:
Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features, products, or services; to perform technical operations, such as updating software; to authenticate users; to facilitate payments; and for other customer service and support purposes.
Marketing and Communications. To communicate with you about your account and use of our Services, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Our communications with you may include communications via email. [Note: As we discussed, in order to send text messages, you will need consent. When you roll out your text messaging feature, please consult us to ensure that it is implemented appropriately, and I would want to add language here and in the Your Choices section below. So that you have a sense of the consent that would be needed, here is sample consent language, which will have to be tailored:[tick box for user to check] By providing your mobile phone number above and clicking Create Account, you consent to receiving text messages from us relating to our services. You may withdraw your consent at any time by texting “STOP” to any text message we send you. You understand that receiving text messages from us is not a condition of your use of our services but that you may lose certain functionality if you withdraw your consent. You further understand that message and data rates may apply and that you are responsible for any fees charged by your mobile carrier regarding communications between us and you.] Please see our section regarding Your Choices for more information about how to change your communications preferences.
Research and Analytics. To analyze how you interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
How We Disclose Your Information
We may disclose your information, including personal information, as described to you at the time of collection or disclosure or as follows:
Service Providers. We may disclose your information to our vendors, service providers, agents, consultants, or others who perform functions on our behalf. For example, we may disclose your information to third-party service providers to process payments on our behalf.
Other Unaffiliated Third Parties. We may disclose your information to third parties, including so that those third parties may send marketing information to you.
Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes. For example, we may share aggregate information with retailers so they can understand the spending habits of their customers.
Cookies and Other Tracking Mechanisms
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Services who disable cookies will be able to browse certain areas of the Services, but some features may not function (e.g., you may not be able to stay logged into your account).
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do Not Track Disclosure
Our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You may, however, disable certain tracking as discussed in the Cookies and Other Tracking Mechanisms section above (e.g., by disabling cookies).
We have taken steps to help protect the personal information we collect. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Accessing, Modifying, or Deleting Your Personal Information. You may access, modify, or delete the personal information that you have provided to us by logging into your account settings or emailing us at email@example.com [Note to update this with the email address that you created.] with what you would like updated. Please note that we may retain certain information about you as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information but we believe that you have violated our Terms of Service[link] we may retain information about you in order to attempt to resolve the issue before deleting it.
Opting out of Marketing Emails. We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Your California Privacy Rights
If you are a California resident then under Cal. Civ. Code § 1798.83 you may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the contact information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. [Note: This is the language I mentioned over the phone that I would have to add because you want to leave open the opportunity to share personal information with third parties for those third parties’ own marketing purposes (e.g., giving Macy’s my email address so that Macy’s can market to me directly.]
Our Services are not targeted to children under thirteen (13) years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.