This chart details the categories of Personal Information that we collect and have collected over the past 12 months:
When you provide such information directly to us.
When you use the Services and such information is collected automatically.
From the public social media posts, databases, or other sources.
Third Party Accounts Authorized by You
If you provide your credentials to any third party account (such as a social network account, linked retailers and financial institution (linked bank) via Plaid Inc.) to us or otherwise sign in to the Services through such third-party site or service, some content and/or information in or from those accounts may be transmitted to us.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purpose set forth in section 7027(m) of the CCPA regulations and we do not collect or process senstiive personal information with the purpose of inferring any characteristics about California residents.
We disclose your Personal Information to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Information. For more information, please refer to the state-specific sections below.
NOTE: Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes.
We may disclose any Personal Information that we collect to third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Information” section above.
All of your Personal Information that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
We may create aggregated, de-identified or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management setting by clicking the Cookie icon in the bottom right-hand corner of this screen. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Information) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We seek to protect your Personal Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Information and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Information about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Information. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Information, and the sensitivity of the Personal Information. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
We do not knowingly collect or solicit Personal Information about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Information to us, please contact us at firstname.lastname@example.org.
If you are a California resident, you have the rights set forth in this section. Except as otherwise specified below, please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Information to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Information disclosed to each category of third party recipient. If we have sold or shared your Personal Information over the past 12 months, we will identify the categories of Personal Information sold to or shared with each category of third party recipient.
You have the right to request that we delete the inaccurate Personal Information that we have collected about your. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Information to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Information involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
You have the right to request that we correct any inaccurate Personal Information we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Information, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
In this section, we use the terms ‘sell’ and 'share' as they are defined in the CCPA. We sell your Personal Information, subject to your right to opt-out of these sales.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” or "share" of information and California residents have certain rights when a business "sells" or "shares" Personal Information with third party, including for purposes of cross-contextual behavioral advertising. You can opt out of these sales and the sharing of Personal Information by following the instructions in this section.
We may sell or share your Personal Information, including for the purposes of cross-contextual behavioral advertising, to and with the following categories of third parties:
Over the past 12 months, we may have sold or shared the following categories of your Personal Information to and with the categories of third parties listed above:
We have sold or shared the foregoing categories of Personal Information for the following business or commercial purposes:
You have the right to opt-out of the sale of your Personal Information. You can opt-out using the following methods:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale or sharing of your Personal Information for at least 12 months.
To our knowledge, we do not sell or share the Personal Information of minors under 18 years of age.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may compensate you for the collection or sale or sharing of your Personal Information to participate in our Points Program (described below), which will give you access to various Klover offerings. As a result, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you. More information regarding our financial incentive program can be found in the paragraph below.
As part of our Services, we offer financial incentives which can be accessed by participating in our Points Program. By participating in our Points Program, we will offer Points as payment to you as compensation, for the collection of your Personal Information and/or the sale or sharing of your Personal Information. These Points will provide you access to various financial incentives, including cash advances. The value of your Personal Information to us is related to the value of the financial incentives or other benefits that you obtain or that are provided as part of our Points Program, less the expense related to offering those products, services, and benefits to Points Program participants. By signing up to use our Services, you agree to participate in our Points Program. Additional information about our Points Program, including on ways you can revoke your participation, can be found at here.
If you are a Virginia resident, you have the rights set forth under the VCDPA. Please see the "Exercising Your Rights" section below for instructions regarding how to exercise these rights. Please note that we may process Personal Information of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
You have the right to request confirmation. of whether or not we are processing your Personal Information and to access your Personal Information.
You have the right to correct inaccuracies in your Personal Information, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Information.
You have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.
You have the right to delete your Personal Information.
Once you have submitted an opt-out request, we will not ask you to reauthorized the processing of your Personal Information for targeted advertising purposes for at least 12 months.
If we refuse to take action on a request withint a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oaag.va.us/consumer-protection/index.php/file-a-complaint.
You may appeal a decision by us using the following methods:
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
If you are a California resident, you may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at email@example.com.
Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about "Do Not Track," you can visit www.allaboutdnt.com.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.