FinSiteful Mobile App Privacy Policy

Last Modified: January 5, 2023

Introduction

We at FinSiteful, Inc. as well as our affiliates (collectively, “we”, “us” or “our”) 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 from or about you in connection with our FinSiteful application for your mobile device (our “Application”), and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to any information we collect in connection with our Application, including any information you provide in the course of using our Application and any information collected when you interact with us by phone or e-mail messaging.  This Policy does not apply to any other information we collect by any other means.

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, you can choose not to use our Application.  By accessing or using our Application, you agree to this Policy.  This Policy may change from time to time.  When we make changes to this Policy, we will post the updated Policy on our Application and update the Policy’s “last modified” date.  We will also provide notice of any material changes as explained in the section below titled “Changes to Our Privacy Policy.”  Your continued use of our Application after we make changes is deemed to be acceptance of those changes. 

Our Role as a Service Provider to Higher Ed Institutions

The Application is intended to be used as a financial literacy and management tool by students on the campuses of institutions of higher education in the United States.  Colleges, universities or other institutions of higher education may elect to use the Application and related “dashboard” software that we license to them (the “Dashboard Software”) on their campus under contract with us (each such institution, a “Higher Ed Institution”) and, for clarity, “you” are an individual student of a Higher Ed Institution.  We are merely a service provider to the Higher Ed Institution permitting them to use the Application and our Dashboard Software on their campus.  We collect information through your use of the Application and process that information on the Higher Ed Institution’s behalf and under the Higher Ed Institution’s control and direction, pursuant to our contract with the Higher Ed Institution.  As between you and us, we commit to you that we will collect and process your information in accordance with this Policy, as part of the services we provide to the Higher Ed Institution.  However, as between you and the Higher Ed Institution, with respect to information about you that you may share with the Higher Ed Institution or that the Higher Ed Institution otherwise obtains through your use of the Application, each Higher Ed Institution independently has the right to determine the purposes for which it will process such information and the means the Higher Ed Institution will use to process such information.  We do not control (and are not responsible for) the applicable Higher Ed Institution’s policies and practices relating to the collection, use, maintenance, protection or disclosure of your information, including information about you that the Higher Ed Institution obtains through your use of the Application.  We only control (and are only responsible for) our own actions and the actions of our own service providers, as described in this Policy.  We encourage you to review the responsible Higher Ed Institution’s privacy policy or consult with an administrator of the Higher Ed Institution for more information about how the Higher Ed Institution may collect, use, maintain, protect and disclose your information. 

Information Collected About You and How it is Collected

Personal Information We Collect – Generally

We may collect several types of information from and about users of our Application, including information by which users may be personally identified or information about a user that is maintained in personally-identifiable form (collectively “Personal Information”).  Specifically, we (or our third party service providers acting on our behalf) may collect the following information from you:

• Personal identifiers and contact information, such as your full name, date of birth, postal address, e-mail address, telephone number (including mobile telephone number) and the IP Address or Mobile Device ID of the computer or device used to access and use our Application.
• Information you provide in connection with registering to use our Application or creating your user profile, such as a username, contact name, password (for account access purposes), a picture of yourself, the name of the Higher Ed Institution you attend, the student ID or other personal identifier assigned to you by your Higher Ed Institution, your employment status, your gender, your major or area of study and your expected graduation year.
• The balances and transaction histories of the financial accounts you choose to link to our Application.  Please see the section below titled “Linking Your Financial Accounts with the FinSiteful App” for more information.
• The Technical Information described in the section below titled “Traffic, Usage and Device Information.”
• Information you chose to provide in connection with our services for automating the completion of the Free Application for Federal Student Aid^® (“FAFSA”) form, as described below in the section titled “FAFSA Information.”
• Any other information (including Personal Information) you choose to provide in any forms or messages submitted by you to us or to others through our Application, including any Personal Information you share or authorize us to share with your Higher Ed Institution through the In-App Chat Feature (described below in the section titled “How We Use Your Information”). 

How We Collect Information

With the exception of your Technical Information and Internet activity (which we or our third party service providers collect automatically as you navigate through or interact with our Application, as described below in the section titled “Traffic, Usage and Device Information”) we collect Personal Information from you when you provide it or submit it to us or our third party service providers (or direct another party, such as a Financial Account Link Provider, to do so) in connection with your use of our Application, such as by registering for an account on our Application, creating a user profile, requesting information from us (such as signing up to receive our e-mail notifications or other marketing and promotional information about us or our services), linking your financial accounts with the Application, entering into a sweepstakes, contest, giveaway or other promotion related to our services, responding to a voluntary survey you have agreed to complete, contacting us for customer service inquiries or reporting a problem with our Application or otherwise contacting us through the contact methods provided on our Application.

Additionally, administrators at Higher Ed Institution may choose to share certain information about you with us in connection with their subscription to the Application and Dashboard Software or they may submit certain information about you to us in the course of responding to requests and communications initiated by you via the In-App Chat Feature.  We encourage you to review the responsible Higher Ed Institution’s privacy policy or consult with an administrator of the Higher Ed Institution for more information about its choices as to the information it shares with us. 

Traffic, Usage and Device Information

As you navigate through and interact with our Application, we may automatically collect certain traffic data, usage information and information about your mobile device, such as your mobile device’s operating system, language preferences, country and location, your wireless carrier, configuration data, clickstream analytics and other technical information about how and when you use our Application.  The technologies we use for this automatic data collection may include cookies that are stored on your mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code.  We collect this information to manage our content and improve users’ use of our Application; count and review the number of users of our Application and their usage patterns; to track key performance indicators such as pages accessed, frequency of access and other statistical information related to our Application (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who accesses our Application via iOS or Android; to recognize if user is a return user of our Application; to store information about a user’s visits; and to remember a user’s preferences.  Third parties may also collect Technical Information and other information on our behalf as further described in the section below titled “Tracking and ‘Do Not Track’.”

Linking Your Financial Accounts with the FinSiteful App

You may have the option to link certain of your financial accounts to our Application for such purposes as tracking and evaluating your financial activity.  You are not required to use the financial account linking feature as a condition of using the Application or in order to benefit from other Application features that are unrelated to and not dependent on the financial account linking feature.  If you choose to use this feature, a third party entity that you have selected such as Plaid Inc. (“Plaid”), MX Technologies, Inc. (“MX Technologies”) or another provider (the “Financial Account Link Provider”) will connect your financial accounts to our Application pursuant to a separate legal relationship you establish with such Financial Account Link Provider and subject to such Financial Account Link Provider’s separate terms, conditions, policies and practices.  When you use a Financial Account Link Provider to connect your financial accounts to our Application, we do not collect or store any of your financial account information other than the balances and transaction histories of the one or more financial accounts you choose to link to our Application (which such information is provided to us on a real-time basis by the Financial Account Link Provider, at your direction, as part of the service you have requested from the Financial Account Link Provider).  We do not control (and are not responsible for) Plaid, MX Technologies or any other Financial Account Link Provider’s policies and practices relating to the collection, use, maintenance, protection or disclosure of your information, including information about you that Plaid, MX Technologies or any other Financial Account Link Provider obtains when you use their services to link certain of your information to our Application.  We only control (and are only responsible for) our own actions and the actions of our own service providers with respect to the information provided to us by the Financial Account Link Provider, as described in this Policy.  We encourage you to carefully review the applicable Financial Account Link Provider’s terms and conditions and privacy policies for more information about how the Financial Account Link Provider may collect, use, maintain, protect and disclose your information.  

How We Use Your Information

Generally

We (or our third party service providers acting on our behalf) may use the information we collect about you or that you provide to us, including Personal Information, to: 

• Create, maintain, customize, and secure your account and profile with us.
• Provide our Application and its contents and services to you.
• Provide you with support and respond to your inquiries and support requests relating to our Application, including to investigate and address your concerns and to monitor and improve our responses.
• Update and maintain e-mail or mailing lists (such as our e-mail lists to receive newsletters or alerts by e-mail).
• Carry out the advertising, promotional and marketing purposes as described in the section below titled “Use of Personal Information for Marketing Purposes.”
• Help maintain the safety, security, and integrity of our Application, databases and other technology assets and our business.
• Perform research and development activities, which may include, for example, conducting data analyses in order to develop new products and services or to improve existing products and services, and performing quality control activities.
• Notify you about changes to our Application.
• Register you for sweepstakes, contests, giveaways or other promotions.
• Develop and administer voluntary user surveys. 
• With respect to automatically-collected traffic, usage and device information, fulfill the purposes described in the section above titled “Traffic, Usage and Device Information.”
• With respect to information collected pursuant to the FAFSA Form Automation Service, fulfill the purposes described in the section below titled “FAFSA Information.”
• With respect to aggregated and de-identified information, fulfill the purposes described in the section below titled “Use and Disclosure of Aggregated or De-Identified Data.”
• With your permission, and as further described in the section below titled “In-App Chat with Your Higher Ed Institution,” connect you with your Higher Ed Institution so that you may share certain financial concerns or otherwise communicate directly with an administrator at your Higher Ed Institution.
• Contact you by SMS text messaging, as described in the section below titled “Text Message Program.”
• Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations.
• Enforce any contracts between you and us, or for the establishment, exercise or defense of legal claims.
• 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 is among the assets transferred.
• Fulfill any other purpose for which you provide the information.
• Serve any other purpose that we describe when you provide the information and for any other purpose with your consent. 

FAFSA Information

In connection with your use of our Application, you may choose to use a service we offer for automating the completion of your FAFSA Form (the “FAFSA Form Automation Service”).   Pursuant to the FAFSA Form Automation Service, we may collect certain additional information, including Personal Information, which we use to populate the information requested on the FAFSA Form on your behalf.  This information includes identifiers such as your social security number and driver’s license number, and information about you and your parents’ citizenship status, marital, familial and dependency status, educational backgrounds, tax filings, income and employment history, financial resources, military service and use of government support services.  At your election, you may then download or otherwise export the FAFSA Form to your computer or mobile device, to allow you to share it externally with third parties (such as the Federal Student Aid office of the U.S. Department of Education or with your Higher Ed Institution) directly, or you may (via the Application) submit it directly to your Higher Ed Institution.  If you choose the latter option, then we will deliver a copy of the FAFSA Form, including all Personal Information included therein, to your Higher Ed Institution consistent with your direction and instructions.   Please refer to the U.S. Department of Education’s Federal Student Aid website at https://studentaid.gov/ for more information on the FAFSA Form and the information it collects. 

In-App Chat with Your Higher Ed Institution

You may direct us to initiate communications between you and your Higher Ed Institution through a messaging platform hosted on our Application (the “In-App Chat Feature”).  We will only initiate such communications if you “opt in” by indicating that you would like to be connected with or receive communications from an administrator at your Higher Ed Institution.  If you opt in to the In-App Chat Feature, you direct us to disclose to your Higher Ed Institution (and you consent to our disclosure of) the information, including Personal Information, you provide through the In-App Chat Feature.  You should review your Higher Ed Institution’s privacy policy or consult an administrator at your Higher Ed Institution for more information on their use, disclosure and processing of this information.

Use and Disclosure of Aggregated or De-Identified Data

We may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user.  We may use and disclose to third parties, such as your Higher Ed Institution, any such de-identified or aggregated data (including traffic and usage data that does not identify you personally) for any lawful purpose.

Use of Personal Information for Marketing Purposes 

We may use your information (including Personal Information) for advertising, promotional and other marketing purposes in various ways.  This includes:

• Providing you with informational and promotional content and materials regarding the Application and our own products and services, such as advertising and promotional information about our products and services or information about special offers or promotions related to our products and services.

• Providing you with informational and promotional content and materials regarding the products and services of our partnering Higher Ed Institutions.

• Sharing your e-mail address with our partnering Higher Ed Institutions so that they may contact you directly regarding their products and services.

If you do not wish to have your Personal Information used by us to contact you with promotional content or messages, you may send us an e-mail stating your request to info@finsiteful.com or you can opt-out by simply clicking on the “Unsubscribe” or “Updating your e-mail preferences,” link in the most recent e-mail you received from us and follow the prompts that appear.  This opt-out does not apply to notifications about changes to our Application or this Policy.

Third-Party Sites and Services

Our Application may include links to blogs, social media and third-party websites.  These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any Personal Information.  If you follow a link on our Application to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy. 

Text Message Program

When you register for the Application and include your mobile telephone number at registration, or when you initiate text message communications with us by texting us at a number we have provided to you, you will be given an option to participate in our SMS text message program (the “Text Message Program”).  We provide the Text Message Program to send you informational communications related to your use of the Application, such as informing you of support that is available to you through your Higher Ed Institution.  By subscribing to the Text Message Program, you voluntarily authorize and direct us to send text messages using an automated system to the mobile telephone number you have provided.  You are not required to use or subscribe to the Text Message Program as a condition of using the Application or in order to benefit from other Application features that are unrelated to the Text Message Program.  Standard message and data rates may apply.  Once enrolled in the Text Message Program, you may opt out of the Text Message Program (i.e., stop text messages) at any time.  With respect to any text message, you may reply STOP, at which time we will reply by text to give you the option to stop receiving informational communications through the Text Message Program.  You may also opt out by contacting us at info@finsiteful.com.  If you contact us by e-mail please include “Text Message Opt Out” or similar language in the subject line of your e-mail, to assist us in our efforts to ensure prompt and proper processing of your e-mail request.  Regardless of the method you use to opt out, please allow us a few days to process your opt out request.

Tracking and “Do Not Track”

Tracking involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions.  Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit.

We do not currently collect Personal Information about your online activities over time and across third-party sites for tracking purposes.  We do not currently allow third parties to collect Personal Information through or using our Application that could be used by them to analyze and store information about your online activities over time and across third-party sites for tracking purposes.  Therefore, our Application does not respond to any “do not track” signals sent by your mobile device, and if your mobile device sends a “do not track” signal to our Application, our Application will not treat you differently from users who do not send such signals.

Disclosure of Your Information

Generally

We may share your Personal Information with third parties in the following circumstances:

• We may disclose Personal Information to any contractors, service providers and other third parties who need to know such information (or such contractors, service providers or other third parties may collect Personal Information directly from you on our behalf while you use our Application) to provide services to us that support our hosting, maintenance, operation and promotion of our Application and our permitted uses of Personal Information under this Policy.  For example, we use a third party cloud-hosted IT infrastructure service provider to securely store and maintain the information you provide to us via the Application; we use a third party in-app “chat” service provider to facilitate communications through the Application; and we use third party service providers to collect and analyze technical data derived from your use of the Application. 

• With your consent, we may disclose certain types of Personal Information (including your name, e-mail address and student ID) to your Higher Ed Institution so that administrators at your Higher Ed Institution may discuss your financial concerns with you.  At your direction, we may also disclose Personal Information to your Higher Ed Institution in connection with your use of the In-App Chat Feature, as described in the section above titled “In-App Chat with Your Higher Ed Institution.”  

• With your consent and at your direction, we may disclose the Personal Information you provide to us through your use of the FAFSA Form Automation Service to the parties with whom you elect to share such information through your use of the FAFSA Form Automation Service, as described in the section above titled “FAFSA Information.”

• We may disclose Personal Information for the purposes described in the section above titled “Use of Personal Information for Marketing Purposes.”

• We may disclose all types of Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, and any due diligence review with respect to any such proposed transaction.

• We may disclose all types of Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit, and to enforce or apply any legal agreement between us and you, including our FinSiteful Mobile Application End User License Agreement (available online at: https://finsiteful.com/end-user-license-agreement/) or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of our customers or others.

• When you elect to register for the services of a Financial Account Link Provider through our Application, you may disclose certain of your Personal Information directly to Financial Account Link Providers through our Application, as described in the section above titled “Linking Your Financial Accounts with the FinSiteful App.”

We may also disclose your Personal Information for any purpose disclosed when the information is provided, and for any other purpose with your consent.

No Sales of Personal Information

We do not sell any types of Personal Information to third parties, including as “sale” is defined in the California Consumer Privacy Act of 2018, and we will not do so in the future without separately obtaining your consent.

Accessing, Correcting and Deleting Your Information

You may send us an e-mail at info@finsiteful.com to request access to any Personal Information that you have provided to us, or to correct or delete that Personal Information.  For security reasons, we may need to request specific information from you to help us confirm your identity before we correct, update or delete any Personal Information you provide us.  We will evaluate such requests on a case-by-case basis.  In certain cases we cannot delete your Personal Information.  For example, we cannot continue to maintain your account on the Application without retaining certain portions of your Personal Information, so a request to delete certain forms of Personal Information may require the deletion of your account and cessation of services to you.  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.

California “Shine The Light” Disclosure

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year.  To make such a request, please send an e-mail to info@finsiteful.com or otherwise contact us using the information set forth below.  Please mention that you are making a “California Shine the Light” inquiry. 

Nevada Residents: Sale Opt-Out Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@finsiteful.com.  Please mention that you are making a “Nevada Sale Opt-Out Right” request.  However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Users Outside of the United States

Our Application is hosted in the United States and is provided from the United States.  The Application is not intended to be used by individuals located outside of the United States at this time.  If you are a resident of any country other than the United States, please note that by providing your Personal Information to us, you are consenting to the transfer of your Personal Information to the United States and other jurisdictions and to our use and disclosure of your Personal Information in accordance with this Policy.

Children Under the Age of 16

Our Application is not intended for children under 16 years of age, and no one under the age of 16 may provide any information to us or others on or using our Application.  We do not knowingly collect Personal Information from children under the age of 16.  If you are under 16 years of age, do not use our Application or provide any information about yourself to us.  If we learn we have collected or received Personal Information from a child under 16 years of age without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under the age of 16, please contact us at info@finsiteful.com.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.  The safety and security of your information also depends on you.  When we have given you (or when you have chosen) a password for access to certain parts of our Application, you are responsible for keeping that password confidential.  We ask you not to share your password with anyone.  Unfortunately, the transmission of information over the Internet is not completely secure.  Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to or using our Application.  Any transmission of Personal Information is at your own risk.  We are not responsible for the circumvention of any privacy settings or security measures contained on our Application. 

Changes to Our Privacy Policy

We post any changes we make to our Policy on this page.  If we make material changes to how we treat Personal Information, we will notify you through a notice on the Application home page.  The date this Policy was last revised is identified at the top of the page.  You are responsible for periodically visiting our Application and this Policy to check for any changes. 

Contact Information

We are FINSITEFUL, INC., a Delaware corporation with headquarters in Swansea, South Carolina.  To ask questions or to submit comments about this Policy and our privacy practices, you may contact us via e-mail at info@finsiteful.com.