PRIVACY POLICY

Effective as of October 11, 2021

Introduction

Splitsy, LLC (“Splitsy,” “we,” “our,” or “us”) respects the privacy of your information.  This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our website and application, (“Sites”), and the services provided through our Sites (collectively, “Services”).

From time to time, we may change this Privacy Policy.  If we do, we will post an amended version on this webpage.  Please review this Privacy Policy periodically. 

This Privacy Policy covers the following topics:

  1. Collecting and Using Information
  2. Cookies and Other Tracking Technologies
  3. Third Party Processors
  4. “Do Not Track” Signals
  5. Choices About Your Personally Identifiable Information
  6. Security
  7. Third Party Links
  8. Children’s Privacy
  9. Notice to Nevada Residents
  10. Notice to California Residents
  11. How to Contact Us

1. Collecting and Using Information

Personally Identifiable Information We Collect Online

We collect Personally Identifiable Information from you through your use of the Sites and Services.  “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form.  We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

  • Account. If you create an account for any of our Services, you will provide us with your first name, last name, email address, and password.
  • Create a Group. If you create a group with other users through your use of the Services, you will provide the first name, last name, email address, and personal phone number of such users.
  • Waitlist. If you submit information to be a part of our waitlist, you will provide us with your first name, last name, phone number, and email.
  • Link to a Biller’s Account. To link to a specific biller’s account, you will provide us with your bank username and password, and your bank account information, including but not limited to the financial institution name, account name, account type, account ownership, account number, and routing number, We use Plaid to enable us to offer this service. Plaid’s privacy policy is available here.
  • Chatbot. If you interact with the chatbot on the Sites, you may need to provide us with your first name, last name, email address, and other relevant information that may identify you personally.
  • Contact Us. When you log-in to your account, send us any feedback, questions, comments, suggestions, or ideas, or interact with us in any way, you may need to provide us with your log-in information (e.g., email address and password), name and/or email address.

Information as You Navigate Our Sites

We automatically collect certain Personally Identifiable Information through your use of the Sites and Services, such as the following:

  • Usage Information. We collect information such as which of the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
  • Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
  • Mobile Device Information. In addition to the Device Information listed above, when you access our Sites via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Sites via a mobile device or tablet, device type, and carrier.
  • Location Information. We collect location information from Site visitors on a city-regional basis.

Third Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party.  For example, if you create a group with other users through your use of the Services, you may provide the first name, last name, email address, and personal phone number of a third party.  If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Sites, and to protect our legal rights.  In addition, we may use the Personally Identifiable Information we collect to:

  • Process your account registration;
  • Email you our blog posts;
  • Link your biller’s account;
  • Send you push notifications related to your user experience;
  • Contact you regarding our products and services that we feel may be of interest to you;
  • Communicate with you about our Sites or Services or to inform you of any changes to our Sites or Services;
  • Provide support;
  • Maintain and improve our Sites and Services;
  • Defend our legal rights and the rights of others;
  • Efficiently maintain our business; and
  • Comply with applicable law.

How We Share Your Personally Identifiable Information

We may share the information that we collect about you in the following ways:

  • With service providers who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.), and any such service providers will be under an obligation to us to maintain the confidentiality of your Personally Identifiable Information;
  • To service providers to prepare, deploy and analyze advertising content;
  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
  • To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these; and
  • To any other person or entity where you consent to the disclosure.

2. Cookies and Other Tracking Technologies

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”).  “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

  • Estimate audience size and usage patterns;
  • Understand and save your preferences for future visits, allowing us to customize the Sites and Services to your individual needs;
  • Advertise new content and services that relate to your interests;
  • Keep track of advertisements and search engine results;
  • Compile aggregate data about Site traffic and Site interactions to resolve issues and offer better Site experiences and tools in the future; and
  • Recognize when you return to the Sites.

We set some Cookies ourselves and others are set by other entities.  We use Cookies set by other entities to provide us with useful information to help us improve our Sites and Services, to conduct advertising, and to analyze the effectiveness of advertising.  For example, we use Cookies from Google, Facebook, and other similar companies.

How You Can Opt-Out of Cookies

Browser Settings

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies.  If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

Platform Controls 

You can opt out of Cookies set by specific entities by following the instructions found at these links:

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website.  For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised.  Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc.  Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage.  The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website.  The technologies used by Google Analytics do not gather information that personally identifies you.  The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies.  To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

Google reCAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Sites from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed.  For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction.  Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements.  Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Use.  More information as to Google reCAPTCHA and how it works is available here.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize our Services and your experience.  Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Services with user feedback.  Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices.  This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website.  Hotjar stores this information on our behalf in a pseudonymized user profile.  Hotjar is contractually forbidden to sell any of the data collected on our behalf.

3. Third Party Processors

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws.  For example, we use cloud data storage, payment processors, and marketing service providers.

4. “Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked.  Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

5. Choices About Your Personally Identifiable Information

Review and Request Changes to Your Personally Identifiable Information

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account.  To review or request changes to any of your Personally Identifiable Information, please contact us at privacy@splitsy.app

Marketing Communications

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails.  You also may submit a request to us at privacy@splitsy.app

6. Security

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access.  However, no security measure or modality of data transmission over the Internet is 100% secure.  Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

7. Third Party Links

The Sites and Services may contain links that will let you leave the Sites and Services and access another website.  Linked websites are not under our control.  This Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on the Sites and Services.  We accept no responsibility or liability for these other websites.

8. Children’s Privacy

The Sites and Services are not intended for children under 13 years of age.  We do not knowingly collect, use, or disclose personal information from children under 13.

9. Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information.  Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons.  We do not currently sell personal information as defined in the Nevada law.  However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes.  Opt-out requests may be sent to privacy@splitsy.app.

10. Notice to California Residents

We do not disclose personal information obtained through our Sites or Services to third-parties for their direct marketing purposes.  Accordingly, we have no obligations under California Civil Code § 1798.83.

11. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email privacy@splitsy.app.