CHARLIE FINANCE CO.

PRIVACY AND SECURITY POLICY

Last Updated: January 17, 2018

Please note: This is our Privacy and Security Policy. To see our Terms of Use, please see www.hicharlie.co/terms.

We at Charlie Finance Co. (“Charlie Finance”, “Charlie”, “we”, “us”, or “our”) created this privacy and security policy (“Policy”) to explain how we collect, use, protect, and disclose information and data when you use our online services (“Services”) which are made available to you through our website located at www.hicharlie.co (the “Website”) and/or through the Charlie messaging application accessible by Facebook Messenger and any US or Canada-based cellular subscriber via SMS and MMS (the “Bot”). The Website and the Bot are collectively referred to herein as the “Platform”.

This policy also explains your choices for managing information preferences, including opting out of certain uses of your information.

The terms of this Privacy Policy are incorporated by reference in the Terms of Use that you accept when you register to use our Services (the “Terms of Use”). By accepting the Terms of Use, you accept the terms of this Policy. Capitalized terms not defined in this Policy shall have the meaning set forth in our Terms of Use. We reserve the right, at our discretion, to change this Policy at any time, with or without notice. If we make any material changes to this Policy we will notify you by SMS text message (sent to the cell phone number specified in your account), via Facebook Messenger, or by means of a notice on the Platform prior to the change becoming effective. Continuing to use the Services after such notification by Charlie or posting of changes on the Platform will indicate your acceptance of the amended terms, regardless of if you opened or viewed any notice, text message, or postings. If you do not agree with any of the amended terms, you must avoid any further use of the Services. We encourage you to periodically review this Policy for the latest information on our privacy practices.

Note that, as explicitly indicated in our Terms of Use, you must be 18 years or older in order to use our Services.

1. What Information Do We Collect and/or Receive?

In the course of operating the Platform, Charlie Finance will collect (and/or receive) the following types of information.

“Personal Information” means data that allows someone to identify or contact you, including, for example, your name, gender, date of birth, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. "Aggregated Non-Personal Information" means data that is not associated with or linked to your Personal Information; Aggregated Non-Personal Information does not, by itself, permit the identification of individual persons. We collect Personal Information and Aggregated Non-Personal Information, as described below.

You authorize us to collect and/or receive such information.

1.1 Personal Information. When you register to use the Services, we will ask you to provide Personal Information such as your cell phone number. Based on the Services you choose, you may be asked to provide additional personal details to complete your registration. For example, you may be asked to provide:

  • Additional contact information, such as your name or nickname, address, e-mail
  • Sensitive identifying information such as your date of birth or driver’s license number

To take full advantage of our Services, you may be asked to provide information about your financial accounts, including access credentials, your financial institution’s name, names of your credit and/or debit cards and financial accounts that you elect to connect on the Platform.

We do not collect Personal Information from Visitors who are viewing publicly available content on the Platform, unless they provide such information voluntarily, such as by registering for an account, contacting us through the Contact Us section of the Platform, or through the course of their interaction with our Bot.

1.2 Billing Information. Depending on the products and services we provide and the products and services you use, you may be required to provide certain billing information which may include a debit card number, credit card number, expiration date, billing address, and other payment related information. Such information is collectively called the “Billing Information”. Any Billing Information you share with us will never be stored by Charlie Finance. Instead, it will be passed along to our payment processor Stripe (“Third Party Payment Processor”) for storage and payment processing.

1.3 Activity Information. In addition to the Personal Information and the Billing Information, we may collect or receive additional information based on your activity on our Platform, including but not limited to the following:

  • The frequency and scope of your use of the Services
  • Specific actions that you took or transactions that you made, along with the date and time of those actions or transactions
  • The Internet Protocol (IP) address, or mobile device ID, and the name of the domain that serves you to access the Services
  • Your operating system type, browser type, browser language, and the geographic location of the computer system or mobile device that you are using to access the Services
  • The website you visited before browsing to our Website
  • Pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Website

1.4 Cookies and Web Beacons. We may use “cookies” with our services. Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Our cookies may contain a variety of information, such as the content of search queries, the Services’ pages you have accessed, session durations and IP addresses or mobile device ID. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. If you wish to block the cookies, then please use the help button in your browser, or use the “settings” function in your mobile device, and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Services’ or certain features and functions thereof.

In addition, we may make use of web beacons on the Services for user security purposes and in order to improve product service and evaluation. A web beacon is an object that is inserted in an e-mail or web page and is usually invisible to the user. The beacon allows checking that a user has viewed the page or e-mail, allowing us to track user services and website traffic more effectively.

We do not collect Personal Information via cookies or web beacons. If you have provided us with Personal Information separately, however, we may associate that information with the information that is collected automatically via cookies and web beacons and use such information to improve the Services. Automatic data collection may be performed on our behalf by our services providers who may provide us with reports about the data collected by such service providers.

1.5 Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Platform. This includes third party analytics services, including but not limited to Mixpanel, Amplitude and Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Platform, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Platform and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Platform and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at support@hicharlie.co.

1.6 Information from Third Parties. We may also collect information about you from third parties, including Facebook. We may collect information about you from affiliated or nonaffiliated companies for purposes of business analysis or to present targeted marketing offers to you. We may work with third parties to display our advertising on their websites or mobile apps and manage our advertising on other websites or mobile apps. These third parties may use tracking technologies such as cookies to gather information about your activities on their websites and mobile apps and other websites and mobile apps in order to provide you advertising based upon your browsing activities, usage and interests.

2. How Do We Use the Information?

Your privacy is our priority. We will use your Personal Information for the following purposes:

  • to provide you with the Services and enable you to use the Services;
  • to send you communications and notifications through text on your mobile and through the Facebook Messenger application;
  • to improve and customize your experience on the Platform;
  • to retrieve your User Accounts statements and information regarding your transactions in order to provide you with the Services.
  • to provide you with support, handle complaints and collect fees (if applicable) and to conduct administrative activities necessary to maintain and provide our Services;
  • to send you Services-related updates, notices and announcements;
  • to provide you with information related to the Services;
  • to conduct surveys and questionnaires;
  • to enforce our Terms of Use;
  • to contact you regarding service and administration related issues as and when we believe it to be necessary;
  • to comply with any applicable law and assist law enforcement agencies under any applicable law, when we have good faith to believe that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards;
  • to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
  • to take any action in any case of dispute, or legal proceeding of any kind between you and Charlie Finance, or between you and any other third parties or users with respect to, or in relation with the Services;
  • for any other purposes disclosed at the time the Information is collected or to which you consent; and
  • as otherwise specifically described in this Policy.

3. How Do We Use Non-Personal Aggregated Information?

We may use Aggregated Non-Personal Information to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, for further internal, commercial and statistical purposes.

4. How Do We Share the Information With Others?

We will ALWAYS take your express consent, before we sell, rent or lease your Personal Information to third parties, other than to the following entities identified below.

4.1 Key Third Party Providers. We may offer certain features or services within the Service that are facilitated by Third Party Providers such as Facebook. We will share your information with such Third Party Providers as required to operate our Services, to facilitate your use of them, and to help us conduct our business and marketing activities.

4.2 Plaid. Specifically, we work with a company called Plaid (www.plaid.com) to gather data for you about your accounts at other financial institutions from those financial institutions and from Plaid. By using the Services, you grant Plaid and any other Third Party Provider the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to the terms of Plaid’s privacy policy, available at www.plaid.com/legal, or that of any other Third Party Provider.

4.3 Billshark. We also work with a company called Billshark (www.billshark.com) to help negotiate bills and subscriptions on your behalf. By using the Services and opting in to the Billshark feature, you grant Billshark the right, power, and authority to act on your behalf to access and transmit your personal and financial information and to otherwise use information you provide to Billshark through the Platform according to the terms of Billshark’s privacy policy, available at www.billshark.com/privacy.

4.4 Government Authorities. We may disclose your Personal Information to government authorities, and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas, or in connection with an audit of Charlie Finance or its affiliates. We also may disclose your Personal Information to government authorities, and to other third parties when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of the Platform, or anyone else that could be harmed by such activities.

4.5 Additional Service Providers. We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information.

4.6 Change of Control. If we transfer our business relating to the Services, or any part thereof, to an affiliated company or a third party, including, but not limited to, by merger, sale of equity interests, sale of all or substantially all assets or other change of control transaction involving such business, then we may transfer your Personal Information as part of the transferred assets to the acquirer of such business and you hereby give your prior consent thereto.

4.7 Third Party Payment Processor. If you are a Premium User, or if you are using a good or service through Charlie that requires payment of fees, we will share your credit card and other payment related information with Stripe, our Third Party Payment Processor as necessary to process your payment. Storage by Stripe of your credit card and other payment relating information is subject to the privacy policies and practices of Stripe at https://stripe.com/us/privacy and is not subject to the terms of this Policy. By providing your credit card and other payment related information, you acknowledge and agree to use of such information by our Third Party Payment Processor for purposes of processing your payment to us.

4.8 Sharing of Aggregated Non-Personal Information. To the extent permitted by law, we may sell, license, distribute and disclose Aggregated Non-Personal Information to third parties.

5. Accessing and Updating Your Personal Information

You may update the information that is stored in your user account by accessing your account through the Platform. If you find that the information in your account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from registering with the Services and impair our ability to provide you with the Service through the Platform. If you are unable to update your information via your user account, you may submit an access request to us by sending an email to support@hicharlie.co. Your email should include adequate details of your request. You should be aware, however, that it is not always possible to update the information stored in your user account. If we are unable to provide you the necessary access to update your information we will let you know by SMS text message (sent to the cell phone number specified in your account) or via Facebook Messenger.

6. Data Retention

When your account is terminated, we will use commercially reasonable efforts to delete your Personal Information and discontinue any connection with your financial institution regarding your account. Naturally, once disconnected, you will no longer have access to your account or the Service. However, due to periodical backups and safety mechanisms meant for your information protection and for our administrative purposes, certain Personal Information from your account may remain in our systems. If you have a query about any such Personal Information that we may be storing, please email us at support@hicharlie.co. Your email should include adequate details of your query.

7. Links to Other Sites

The Platform and the Services may contain links to Third Party Sites. We do not endorse such Third Party Sites and we are not responsible for the privacy practices of such Third Party Sites. Please refer to the privacy policies of such Third Party Sites for more information on how the operators of those sites collect and use your Personal Information.

8. Social Media Features and Widgets

Our Website may include social media features and widgets for social networking sites (collectively, “SNSs”), including but not limited to the Facebook Like button and Facebook Messenger. As part of the Services, our Bot uses Facebook Messenger to communicate with you. These features may collect information, including but not limited to, your IP address, the page you are visiting on our Website, and may set a cookie to enable the feature to function properly. All such social media features and widgets are either hosted by a third party or hosted directly on our Platform. Your interactions with these social media features and widgets are governed by the privacy policy of the company providing it, for example, your interactions with Facebook Messenger are governed by Facebook’s then current privacy policies and terms at www.facebook.com/full_data_use_policy. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

9. Testimonials

We may display personal testimonials of satisfied customers on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your full or partial name. If you wish to update or delete your testimonial, you can contact us at support@hicharlie.co.

10. Information Security

We use commercially reasonable efforts to safeguard your Information from any unlawful interceptions or access, or other kinds of abuse and misuse. We implement a variety of systems, applications and procedures to do this. Among such security methods is the storing of your Information on ISO27001 certified cloud services, firewalls, encryption codes, authentication procedures and multi layer passwords. Furthermore, we implement employee supervision and prevent unnecessary access to data.

Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Personal Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail, SMS, or MMS sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail, SMS, or MMS.

The security of your information may be compromised if you lose possession or control of your mobile device or mobile phone number. You are solely responsible for maintaining the security of your mobile device from unauthorized access.

11. Children’s Privacy

We do not knowingly collect Personal Information from children under the age of 18 through the Platform. If you are under 18, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Policy by instructing their children never to provide Personal Information through the Platform without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

12. Contacting Us

You may send us requests, responses, questions and complaints with respect to our Policy and privacy practices by emailing us at support@hicharlie.co.