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Privacy Policy

 

Changed App Mobile App Privacy Policy

Last modified: June 1, 2022

Introduction  

Changed Inc. (“Changed” or “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

  • The types of information we may collect or that you (“you” or “End User”) may provide when you purchase, download, install, register with, access, or use the Changed App (the “App”).
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in the App and in email, text, and other electronic communications sent through or in connection with the App.

This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through the App.
  • You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Changed uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant Changed and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal/).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App. By checking the checkbox indicating that you have read this privacy policy and have agreed to it, and by downloading, registering with, or using the App, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Changed has relationships with certain service providers in order to provide its services to you. Changed has contracted with Synapse Financial Technologies, Inc. a technology service provider that owns or otherwise has relationships with certain banks and financial institutions and service providers (each of the foregoing being a “Partner Financial Institution”). Synapse Financial Technologies, Inc., is not a bank. Among other services, Synapse assists Changed with “Know Your Customer” requirements and other obligations. For purposes of satisfying “Know Your Customer” requirements, Changed asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, gender, videos, and photographs that may contain images of your face, including your driver’s license or government-issued identification number or card. Changed will also collect information pertaining to your account transactions. Your personal information will be shared with Synapse and will be subject to the Synapse Privacy Policy. Synapse will share your information as necessary with its Partner Financial Institutions and other service providers in connection with providing their services. The privacy policies of Synapse, its affiliates’ and its Partner Financial Institutions can be found here.

As specified in the Changed Terms Agreement, the App is intended for use exclusively in the United States of America. The App is NOT intended for use in jurisdictions subject to the General Data Protection Regulation (GDPR).

 

Children Under the Age of 13 or 16

The App is not intended for children under thirteen (13) or sixteen (16) years of age, and we do not knowingly collect Personal Information from children under 16. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@Changedapps.com.

California residents under sixteen (16) years of age may have additional rights regarding the collection and sale of their Personal Information. Please See Your State Privacy Rights for more information.

 

Information We Collect and How We Collect It  

We collect information from and about users of our App:

  • Directly from you when you provide it to us.
  • Automatically when you use the App.
  • Other Personal Information collected may be described in other sections of this Privacy Policy or by dedicated explanation text contextually with the information collection.

 

 Information You Provide to Us.

 When you download, register with, or use the App, we may ask you to provide information:

  • By which you may be personally identified, such as first name, last name, postal address, city, ZIP or postal code, country, date of birth, email address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“Personal Information”).
  • That is about you but individually does not identify you, such as usage information.

This information may include:

  • Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, creating an account, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you report a problem with the App.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Your responses to surveys that we may ask you to complete for research purposes.
  • Details of payments and transactions you carry out through the App. You may be required to provide information about your financial accounts before using the App or the services of our third-party service providers.
  • Other information related to your personal finances, including regarding your bank account and loan service provider.

Failure to provide certain Personal Information may make it impossible for Changed and/or the App to provide its services. Users are responsible for any Personal Information of third parties obtained, published, or shared through the App and confirm that they have the third party’s consent to provide the information to Changed.

 

 Automatic Information Collection and Tracking.

 When you download, access, and use the App, it may use technology to automatically collect:

  • Usage Details. When you access and use the App, we may automatically collect certain details related to your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
  • Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
  • Location Information. The App does not collect real-time information about the location of your device.

If you do not want us to collect this information, do not download the App or register for an account through the App. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

    Information Collection and Tracking Technologies. The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
  • Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

Any use of cookies, or of other tracking tools, by the App or by the owners of third-party services used by the App, unless stated otherwise, serves to identify users and remember their preferences for the sole purpose of providing the service.

  

How We Use Your Information  

We use information that we collect about you or that you provide to us, including any Personal Information, for:

  • Providing you with the App and its contents, and any other information, products, or services that you request from us.
  • Access to third-party services’ accounts.
  • Fulfilling any other purpose for which you provide it.
  • Analytics, including enabling us to monitor the use of the App.
  • User database management.
  • Remarketing and behavioral targeting.
  • Interaction with external social networks and platforms.
  • Hosting and backend infrastructure.
  • Registration and authentication.
  • Managing contacts and sending messages.
  • Displaying content from external platforms.
  • Heat mapping and session recording.
  • Interaction with data collection platforms and other third parties.
  • Managing landing and invitation pages.
  • Handling payments.
  • Giving you notices about your account/subscription, including expiration and renewal notices, and otherwise contact you.
  • Carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us.
  • Notifying you when App updates are available, and of changes to any products or services we offer or provide through it.
  • Each purpose outlined in the Detailed Third-Party Usage section of the document.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our App according to your individual interests.
  • Recognize you when you use the App.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

To allow other App users with separate accounts to make payments on your behalf, we need to share some of your personal information with the App users who want to make such payments. Your name, phone number, photo, or other personal information you give Changed permission to share may be provided to users who wish to make payments towards your loans. We may share this information when you invite another user to contribute to your loan repayment, when another user seeks out your user profile, or when a payment is made on your behalf.

We will not disclose your loan repayment status, transaction activity, account balances, or other sensitive financial information to anyone, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.

If you are an App user making payments on behalf of another App user some of your Personal Information may be disclosed to other users. This information may include your name, phone number, photo, or other personal information you allow us to share. While your transaction activity and financial information will not be shared, the amount you contribute to another user’s loan repayment, whether through rounding up transactions or one-time payments, will be shared with that user.

 

Third-Party Information Collection  

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies.
  • Third-party services’ accounts.
  • Your mobile device manufacturer.
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the App. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Changed Inc. has relationships with certain service providers in order to provide its services to you. Changed Inc. has contracted with Synapse Financial Technologies, Inc. (“Synapse”), a backend technology service provider that owns or otherwise has relationships with Synapse Brokerage LLC, an SEC-registered broker-dealer and member of FINRA and SIPCand certain banks and financial institutions and service providers (each of the foregoing being a “Partner Financial Institution”). Among other services, Synapse conducts “Know Your Customer” requirements and other requirements. For purposes of satisfying “Know Your Customer” requirements,  Changed Inc. asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, videos, and photographs that may contain images of your face, including your driver’s license or government-issued identification number or card.  Changed Inc. will also collect information pertaining to your account transactions. Your personal information will be shared with Synapse and will be subject to the Synapse Privacy Policy. Synapse will share your information as necessary with its Partner Financial Institutions and other service providers in connection with providing their services. The privacy policies of Synapse, its affiliates and its Partner Financial Institutions can be found here.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

Please be advised that some of our third-party partners may conduct all or part of their business in jurisdictions subject to General Data Protection Regulation (GDPR). Changed makes no warranties that third parties are compliant with the GDPR.

 

Facebook permissions asked by the App

The App may ask for some Facebook permissions allowing it to perform actions with your Facebook account and to retrieve information, including Personal Information, from it. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The following Facebook permissions are asked:

  • Basic information: By default, this includes certain information of yours such as ID, name, picture, gender, and locale. If you have made more of your information “public,” more information will be available.
  • About Me: Provides access to the 'About Me' section of your profile.
  • Access Friend Lists: Provides access to any friend lists the User created.
  • Birthday: Provides access to your birthday.
  • Education History: Provides access to your education history. 

 

Detailed Third-Party Usage and Information Processing

If desired, you may request additional information regarding third-party use of your Personal Information at support@Changedapps.com.

 

Additional information about Information collection and processing

    Legal action. The User’s Personal Information may be used for legal purposes by Changed, in court or in the stages leading to possible legal action arising from improper use of the App or the related services. The User declares to be aware that Changed may be required to reveal Personal Information upon request of public authorities.

    Additional information about User's Personal Information. In addition to the information contained in this Privacy Policy, the App may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Information upon request.

    System logs and maintenance. For operation and maintenance purposes, the App and any third-party services may collect files that record interaction with the App (System logs) or use for this purpose other Personal Information (such as IP Address).

    Information not contained in this policy. More details concerning the collection or processing of Personal Information may be requested from Changed at any time. Please see the contact information at the end of this document.

    The rights of Users. Users have the right, at any time, to know whether their Personal Information has been stored and can consult Changed to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, canceled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to support@Changedapps.com..

    The App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

 

Disclosure of Your Information  

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose Personal Information that we collect, or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Changed’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Changed about our App users is among the assets transferred.
  • To third parties to market their products or services to you. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the App terms, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Changed, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information  

We strive to provide you with choices regarding the Personal Information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
  • Promotion and Advertising. If you do not want us (1) to use your email address or contact information to promote our own or third parties’ products or services, (2) to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, or (3) to share your Personal Information with unaffiliated or non-agent third parties for advertising and marketing purposes, please delete your account and remove the App from your device.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

Residents in certain states, such as California, may have additional Personal Information rights and choices. Please see Your State Privacy Rights for more information.

 

Accessing and Correcting Your Personal Information  

You can review and change your Personal Information by logging into the App and visiting your account profile page.

You may also send us an email at support@Changedapps.com to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents in certain states, such as California, may have additional Personal Information rights and choices. Please see Your State Privacy Rights for more information.

 

Your California Privacy Rights  

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. To learn more about California residents’ privacy rights, please see CCPA Privacy Policy for California Residents. California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@Changedapps.com.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their Personal Information.
  • Access and delete certain Personal Information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their PERSONAL INFORMATION, taking into account the information’s nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

TO exercise any of these rights, please send an email to support@Changedapps.com. To appeal a decision regarding a consumer rights request, please send an email to support@Changedapps.com.

Nevada provides its residents with a limited right to opt out of certain Personal Information sales. Residents who wish to exercise this sale opt-out rights may submit a request to the designated address: support@Changedapps.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

 

Data Security  

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and information relating to financial transactions will be encrypted using SSL technology.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We process your Personal Information in a proper manner and will take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of that information. Information processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Changed, in some cases, the information may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, by us as Information Processors. The updated list of these parties may be requested from Changed at any time.

Your Personal Information is processed at our operating offices and in any other places where the parties involved with the processing are located. For further information, please contact Changed at support@Changedapps.com.

Your Personal Information is kept for the time necessary to provide the service requested by you or stated by the purposes outlined in this document. You can always close your account and request that we suspend or remove the data.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our App. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

 

Changes to Our Privacy Policy  

We may update our Privacy Policy from time to time. If we make material changes to how we treat our users’ Personal Information, we will (1) post the new privacy policy on this page with a notice that the Privacy Policy has been updated; (2) notify you by email to the email address specified in your account; (3) notify you by an in-App alert the first time you use the App after we make the change.

The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this Privacy Policy to check for any changes.

 

Additional Definitions and Legal References

“Personal Information” (or “Information”) Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

“Usage Data” Information collected automatically from the App (or third-party services employed in the App), which can include: the IP addresses or domain names of the computers utilized by the Users who use the App, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the App) and the details about the path followed within the App with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

“User” The individual using the App, which must coincide with or be authorized by the Information Subject, to whom the Personal Information refers.

“Information Subject” The legal or natural person to whom the Personal Information refers.

“Information Processor” The natural person, legal person, public administration or any other body, association or organization authorized by Changed to process the Personal Information in compliance with this Privacy Policy.

 

Contact Information  

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Changed Inc.

433 W. Van Buren St. Suite 1100-J

Chicago, IL 60607

(800) 557-9419

support@Changedapps.com

 

Changed Inc. Privacy Policy for California Residents

 

Last modified: June 1, 2022

 

This Privacy Policy for California Residents supplements the information contained in Changed’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

 

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("Personal Information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

 

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO 

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you when you provide it to us.
  • Automatically when you use the App.
  • Other Personal Information collected may be described in other sections of this Privacy Policy or by dedicated explanation text contextually with the information collection.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information.
  • To provide, support, personalize, and develop our App, website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our App, website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our App, website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.

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.

 

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed Personal Information for a business purpose.

We do not sell Personal Information. In the preceding twelve (12) months, Company has not sold Personal Information. For more on your Personal Information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 

Personal Information Category

Category of Third-Party Recipients

Business Purpose Disclosures

Sales

A: Identifiers.

Banking Partner

NONE

B: California Customer Records personal information categories.

Banking Partner

NONE

C: Protected classification characteristics under California or federal law.

NONE

NONE

D: Commercial information.

NONE

NONE

E: Biometric information.

NONE

NONE

F: Internet or other similar network activity.

NONE

NONE

G: Geolocation data.

Banking Partner

NONE

H: Sensory data.

NONE

NONE

I: Professional or employment-related information.

NONE

NONE

J: Non-public education information.

NONE

NONE

K: Inferences drawn from other personal information.

NONE

NONE

 

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing us at support@Changedapps.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. To designate an authorized agent, email us at support@Changedapps.com. You may also make a request to know or delete on behalf of your child emailing us at support@Changedapps.com. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include: verification of your identity or status as a parent or guardian of a child under the age of 16.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it. For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at support@Changedapps.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). We do not sell the Personal Information of consumers.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@Changedapps.com.

Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

If you have any questions or comments about this notice, the ways in which Changed collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Changed Inc.

433 W. Van Buren St. Suite 1100-J

Chicago, IL 60607

(800) 557-9419

support@Changedapps.com

 

If you need to access this Policy in an alternative format due to having a disability, please contact us at support@Changedapps.com.