We created the App for use by parents and legal guardians ("Parents" or a "Parent"), grandparents ("Grandparents" or a "Grandparent") and their children or grandchildren ("Children" or a "Child") to use to learn about finances in a fun and safe way. This Policy refers to Parents, Grandparents, and Children collectively as "Users" or "you". If you are a Parent reviewing and accepting these terms on behalf of a Child, "you" refers both to you and your child, and you acknowledge that you accept this Policy on behalf of both yourself and your child.
- What Information Does the Company Collect?
The Company occasionally collects Personal Information from Users. "Personal Information" means information that can be used to identify an individual.
- Consent and Modification.
By using the App, you consent to the terms of the Policy and to our processing of Personal Information in the manner and for the purposes set forth in the Policy. If you do not agree with the Policy, please do not use the App.
The Company reserves the right, at its sole discretion, to change the Policy at any time, which change will be effective 10 days following posting of the revision to the Policy on the App. Your continued use of the App 10 days following such posting means you accept those changes.
If the Company makes any change in how we use your Personal Information, the Company will notify you by email (at the e-mail address specified in your account), or by means of a notice on the App prior to the change becoming effective.
- Information We Collect.
The Company collects information in the following ways:
- Information Users Provide Directly. The Company collects information directly provided by Users as part of using the App ("User Content"). This information may include details provided as part of setting up an account or user profile, such as: the User's first and last name, date of birth, social security number, residential address, phone number, email address and/or other screen name or user name that functions as online contact information, gender, school name, and photograph. This information may also include details relating to the User's interactions with the App, such as, but not limited to, information about the User's App calendar, tasks, chores, rewards, account balance, goals, wish list, budgets, allowances, discount codes provided by the Company for use within the App, and shopping and spending activities, as well as the User's family connections, as designated within the App.
- Information Associated with a Bank Account. When a Parent, Grandparent, or Child links a bank account (the "Bank Account") to the App, the Company collects personal details associated with the Bank Account, which may include the account holder's name; a list of accounts held by the account holder at that particular financial institution and their balances; the account holder's primary address and any additional addresses on file with the financial institution; the account holder's email address or addresses; the account holder's phone number or phone numbers; the routing and account numbers for the Bank Account; and the name and address of the financial institution. The Company may also verify a Parent or Grandparent's Bank Account balance when the Parent or Grandparent first links the Bank Account to the App and within seven days of each Automated Clearing House (ACH) debit. The Company may verify the balance of a Child's bank account as often as the Child logs in to the App. For information on why the Company collects this information, please see Section Three, Use of Information, below.
- Information Associated with a Parent or Grandparent Debit or Credit Card. When a Parent or Grandparent links a debit or credit card (the "Parent or Grandparent Debit or Credit Card") to the App, the Company collects personal details associated with the Parent or Grandparent Debit or Credit Card, which may include: the card type, the full legal name of the card holder, the address of the cardholder, the full card number, the expiration date, and the CVV code.
- Information Provided by a Parent on Behalf of a Child. The Company collects information directly provided by Parents on behalf of Children as part of using the App, such as information used to set up accounts or user profiles for Children. This information may include a Child's: first and last name, date of birth, residential address, phone number, email address and/or other screen name or user name that functions as online contact information, gender, school name, and photograph.
- Log Files. The App or third-party analytics services, such as Adjust, may automatically record certain log file information, such as IP address, location, mobile carrier, device, and interaction with links in the App. The App may periodically use a device's geolocation functionality to determine location at the level of street address or other specific, real-world geographic location for the purpose of verifying User security and identity.
- Device Identifiers. The App or third party-analytics services, such as Adjust, may access, collect, monitor, store on your device, and/or remotely store one or more device identifiers, which are small data files which uniquely identify it.
- Metadata. Metadata is technical information associated with User Content, such as how or when User Content was collected. The App or third party-analytics services, such as Adjust, may collect metadata on User Content.
- Use of Information
The Company may use information from Users to operate and improve the App and its other products, and to deliver the App. These uses may include, but are not limited to, fulfilling the Company's identity verification requirements; enabling you to open an Allowance Account or Virtual Debit Card Account (a "Bank Account"), enabling you to fund a Bank Account and utilize such Bank Account in connection with our App; enabling you to utilize the App's shopping function; enabling us to provide Parents and Grandparents with statements that reflect how the funds that they designate for use by a Child are spent; enabling Children to view their own account balances; enabling you to utilize the App's additional features, such as the App's calendar, allowance, chore, reward, budget, and shopping functions; providing you with more effective customer service; making the App easier to use by eliminating the need for you to enter the same information repeatedly; performing research and analysis aimed at improving the App; automatically updating the App; diagnosing or fixing problems with the App; and displaying content and advertising customized to your interests and preferences.
The Company also uses information from Users to communicate with Users. The Company may send certain mandatory service communications, such as welcome letters, information on technical service issues, and security announcements.
The Company does not use Users’ Personal Information for building user profiles for commercial purposes not related to the provision of the App. The Company may use Anonymous Info (as defined below) as described in this Policy.
Personal Information collected by the App may be stored and processed in the United States or any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities. By using the App, you consent to any such transfer of information outside of your country. The Company may transfer your Personal Information to affiliated companies for the purpose of storing or processing such information on its behalf. Such information may be transferred to other countries for purposes including, but not limited to, transaction processing and fraud prevention. The Company requires that these parties agree to process such information in compliance with the Policy. In particular, if you provide Personal Information, it may be transferred to and processed on computers in the U.S. and other countries.
The Company may disclose your Personal Information or any information submitted via the App if the Company has a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our Users, yourself or the public. The Company may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- Sharing of Information
The Company will not share your Personal Information except as provided for by this Policy. The Company will not sell Personal Information. The Company may share other information as provided by this Policy.
The Company may share information collected by the App with businesses that are legally part of the same group as the Company, or that become part of that group ("Affiliates").
- Third Party Service Providers.
The Company may use contractors to collect, use, analyze and otherwise process information on its behalf. The Company requires such suppliers to handle information in a manner consistent with the Policy.
The Company may occasionally hire other companies to provide limited services on its behalf, such as providing customer support, providing KYC/AML/OFAC customer identification services, hosting websites, processing transactions, providing order fulfillment and/or shipping services, or performing statistical analysis of its services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They will be required to maintain the confidentiality of the information and will be prohibited from using it for any other purpose.
- Anonymous Information.
The Company may use Anonymous Information (as defined below) or disclose it to third party service providers, to provide and improve the App. The Company may also disclose Anonymous Information to third parties for a fee. "Anonymous Information" means information which does not enable identification of an individual User, such as aggregated information about use of the App.
- Review, Deletion and Retention
The Company allows Parents and Children to review Personal Information collected from Children and, upon request, to delete such Personal Information. A Parent or Child seeking to review personal information should contact firstname.lastname@example.org. It is the Company’s policy to verify the identity of a Parent or Child making a request to review or delete Personal Information.
It is the Company's policy to retain Personal Information regarding Parents and Grandparents indefinitely. It is the Company's policy to retain personal information regarding Children for as long as is reasonably necessary to fulfill the purpose for which the information was collected, including any retention period required by law.
Your Choices Regarding Personal Information
You have the choice to request information about our collection, use, and disclosure of Personal Information (a "Request to Know") and to request that we delete personal information that pertains to you (a "Request to Delete"). The Company does not discriminate against users upon the basis of submitting either type of Request. As noted in the "Sharing of Information" section, above, the Company does not sell Personal Information, and so state laws regarding the right to "opt out" of such sales are not directly applicable to Company.
Users may submit two types of Requests to Know: (1) A request for the specific items of Personal Information that we have collected about you in the past twelve months; or (2) a request for the categories of Personal Information that we have collected, used, and disclosed about you in the past twelve months.
When you submit a Request to Know, we may ask you to provide certain items of information in order to verify your identity, such as your name, email address, and phone number. If you submit a Request to Know for the specific items of information that we have collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.
If we are able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why we are not required to provide the requested information. If we are unable to verify your identity, we will respond by explaining why we cannot verify your identity. We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.
If we provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.
Users may submit a Request to Delete by emailing us at email@example.com. When you submit a Request to Delete, we may ask you to provide certain items of information in order to verify your identity, such as your name, email address, and phone number. If we are able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why we are not required to delete your Personal Information. We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the Personal Information. We will specify the manner in which we delete your Personal Information.
If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete. We will confirm receipt of your Request to Delete within 10 days and will respond to your Request to Delete within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.
Please note, however, that certain information may be exempt from Requests to Delete, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.
- Other Information
- Business Transitions.
If the Company is acquired by or merged with a third party entity, or if it is subject to a bankruptcy or any comparable event, the Company reserves the right to transfer or assign Personal Information in connection therewith.
- Security, Confidentiality and Integrity of Personal Information.
The security of your Personal Information is important to us. The Company follows generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to use commercially reasonable means to protect Personal Information, the Company cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact the Company at firstname.lastname@example.org.
Please be aware that certain Personal Information and other information provided by you in connection with your use of the App may be stored on your device (even if that information is not collected by the Company). You are solely responsible for maintaining the security of your device from unauthorized access.
- International Users.
The Company and its servers are located in the United States and are subject to the applicable local and national laws. Those who choose to access the App do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. Users who choose to access or use the App consent to the use and disclosure of information in accordance with this Policy and subject to such laws. The Company may limit the App’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. The Company does not represent or warrant that the App, or any part thereof, is appropriate or available for use in any other jurisdiction.
- Other Websites.
- Children’s Privacy.
The App is marketed towards Parents and Grandparents for use by Parents, Grandparents, and Children together. The Company does not collect Personal Information from Children less than 13 years of age without verifiable parental consent. If the Company learns that Personal Information of persons less than 13 years of age has been collected without verifiable parental consent, the Company will take the appropriate steps to delete this information. To make such a request, or to revoke consent previously granted, please contact the Company at email@example.com.
- California Online Privacy Protection Act.
Pursuant to the California Online Privacy Protection Act, the Company discloses to disclose how it responds to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they use online services.
The Company does not authorize the collection of personally identifiable information from our users for third party use through advertising technologies.
- Contact Information.
If you have questions about this Policy, please contact firstname.lastname@example.org.
- Effective Date.
The effective date of this Policy is November 17, 2020.