DEBTSY, INC.

PRIVACY POLICY

Last Updated: November 1, 2017

 

This privacy policy (“Policy”) describes how Debtsy, Inc. (“Debtsy,” “we,” “our,” or “us”) collect, use and share nonpublic personal information of consumer users of this website, https://www.debtsy.com, including any debtsy.com sub-domains and any other website that links to this Policy (collectively, the “Sites”).  By accessing or using our Sites, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your nonpublic personal information as described in this Policy and our Terms of Service.

 

WHAT WE COLLECT

 

We get information, including nonpublic personal information about you in a range of ways. “Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you.

 

Information You Give Us. We collect your‎ name, postal address, email address, phone number, fax number, username, password, demographic information (such as your gender and occupation), financial information, credit information, and information about your account balance, payment history, overdraft history, social security number, credit history and income as well as other information you directly give us on our Site, including information about your transactions with us, our affiliates or others. Debtsy does not share financial information with any third party social networking services.

 

Information We Get From Others. We may get information, including nonpublic personal information about you from other sources (including, information we receive from credit bureaus such as information about your account balance, payment history, overdraft history, credit history and income) and combine that with information we collect through our Site. We may add this to information we get from this Site. [For example, we may obtain information when you login through a third party social network or authentication service, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information.   Similarly, when you interact with us through a social media site or third party service, such as when you like, follow or share Debtsy content on Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. The data we receive from these third party sites is dependent upon that third party’s policies and your privacy settings on that third party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Sites.]

 

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.

 

Cookies and Other Tracking Technology. We, and our third party partners, may automatically collect or log certain types of usage information about you using a variety of tracking technologies, including "cookies," web beacons, Flash objects, embedded scripts, location-identifying information, file information and similar technology. Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Sites. This type of information is collected when you visit our Sites, read our emails, or otherwise engage with us, and is used to make the Sites more useful to you and to tailor the experience with us to meet your special interests and needs. For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Sites, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Sites, whether you open emails or click the links contained in emails, whether you access the Sites from multiple devices, and other actions you take on the Sites. When you access our Sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.  We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time. 

 

We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

 

USE OF INFORMATION

 

We use the information we collect from you, including your nonpublic personal information as follows:

·       To operate, maintain, and improve our Sites, products, and services, including to monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website.

·       To communicate directly with you, including to send you email messages, respond to comments and questions and provide customer service.

·       To send you email messages relating to our Sites, including information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

·       To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

·       To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, enforce our Terms of Service, and perform other duties required by law.

·       To provide and deliver products and services you request.

·       To remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites.

·       To provide custom, personalized content and information, including targeted content and advertising.

 

SHARING OF PERSONAL INFORMATION

 

We may share nonpublic personal information as follows:

 

·       With other users of the Sites, as necessary to provide our services to you.

·       We may share nonpublic personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.

·       We may share nonpublic personal information with other users of our Sites with whom you interact with on the Sites. You control what information you share.

·       We may share nonpublic personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

·       We may share nonpublic personal information with other companies and brands owned or controlled by Debtsy, Inc., and other companies owned by or under common ownership as Debtsy, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns.  These companies will use your personal information in the same way as we can under this Policy.

·       We may share nonpublic personal information for legal, protection, and safety purposes.

o   We may share information to comply with laws.

o   We may share information to respond to lawful requests and legal processes.

o   We may share information to protect the rights and property of Debtsy, Inc., our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.

o   We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

·       We may share nonpublic information with those who need it to do work for us, including with third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services.

 

We may also share aggregated and/or anonymized data with others for their own uses.

 

Gramm-Leach-Bliley Act Opt-Out Provision

 

Under the Gramm-Leach-Bliley Act you have the right to limit our sharing of your non-public personal information as follows: (a) for our affiliates’ everyday business purposes – information about your creditworthiness; (b) for our affiliates to market to you; and (c) for non-affiliates to market to you.

 

If you prefer that we not share your nonpublic personal information as set forth in the immediately preceding sentence, please follow the instructions regarding the opt-out procedure below. If you choose not to opt-out, we reserve the right to share this information.

 

You may exercise your right to opt-out by providing written notice to legal@debtsy.comm that clearly states you choose to opt-out of Debtsy sharing your nonpublic personal information with affiliated third parties for or nonaffiliated third parties, in accordance with GLBA. Your opt-out preference will become effective within two (2) business days of receipt. This opt-out preference will remain active until you cancel this option.

Please note that this notice is not a binding contract and replaces any previous notices that you may have received from us. In the event that the terms of our privacy disclosures change, we will disseminate a revised privacy notice for your review, and provide an additional opportunity for you to exercise your opt-out preference.

 

ADDITIONAL INFORMATION CHOICES AND CHANGES

 

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices)

 

You may send requests about personal information by contacting legal@debtsy.com.

 

You can typically remove and reject cookies from our Sites with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Sites works for you. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

 

If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at legal@debtsy.com.  We may not be able to modify or delete your information in all circumstances. 

 

THIRD PARTY TRACKING AND ONLINE ADVERTISING

 

We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our website over time so that they may play or display ads on our Sites, on other devices you may use, and on other websites, apps or services, including on Facebook.  Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site and other information. We may also share a common account identifier (such as an email address or user ID) to help us identify you across devices. We and our third party partners use this information to make the advertisements you see online more relevant to your interests.   As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings.   Some of these opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookie, you may need to perform the opt-out task again. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices  and downloading the mobile AppChoices app.    

 

HOW WE STORE AND PROTECT YOUR INFORMATION

 

Your information collected through our website may be stored and processed in the United States or any other country in which Debtsy or its affiliates or service providers maintain facilities.  If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which the Debtsy or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Policy. 

 

We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website.  However, no security system is impenetrable and we cannot guarantee the security of our systems 100%.  In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

 

CHILDREN’S PRIVACY

 

Debtsy does not knowingly collect or solicit any information from anyone under the age of 13 on this Sites.  In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible.  If you believe that we might have any information from a child under 13, please contact us at legal@debtsy.com. 

 

LINKS TO OTHER WEB SITES AND SERVICES

 

The Sites may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.  We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

 

CONTACT INFORMATION. We welcome your comments or questions about this privacy policy. You may also contact us via email or at our address:

 

Email

legal@debtsy.com

 

Address

Debtsy, Inc.

234 Fifth Avenue

NY, NY 10001

 

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy. If we make any changes, we will change the Last Updated date above.