PadSplit Privacy Policy

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect personal information that you provide to us such as name, address, contact information, passwords, security data, payment information, social media login data and data necessary to verify your identity and perform identity screening. We collect personal information that you voluntarily provide to us when registering to use the Sites, Apps and Services, expressing an interest in obtaining information about us or our Services, when participating in activities on or through the Sites, Apps or Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, Apps and/or Services you choose to use. The personal information we collect can include the following:

Name and Contact Data. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy policy link(s) here: https://stripe.com.

Social Media Login Data.We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below.

Background and Identity Verification Data. If you choose to use certain of the Services managed by us, you are required to provide information that will be used to conduct background checks and identity verification, which information may include your social security number (SSN) and/or ITIN, banking information and other Personally Identifiable Information (PII). You will be prompted to electronically sign a consent form before providing any information for this purpose. By continuing with PadSplit or affiliated services you expressly consent to the usage of your SSN, ITIN, banking information, and other PII by PadSplit and its partner vendors.

All personal information that you provide us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information - such as IP address and/or browser and device characteristics - is collected automatically when you visit our Sites and/or Apps.

We automatically collect information when you visit, use or navigate our Sites and/or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about and when you use our Sites and/or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites and Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information collected through our Apps

In short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our Apps.

If you use our Apps, we may also collect the following information:

• Geo-location information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may automatically collect device or information (such as your mobile device, model, and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Information collected from other sources

In short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL, and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links). Upon your request, we will inform you about the source of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within one month.

2. HOW DO WE USE YOUR INFORMATION?

In short: We process your information for purposes based on legitimate business interests, management of certain Services provided to you by companies for whom we act as a manager, compliance with legal obligations, and/or your consent.

We use personal information collected via our Sites, Apps or Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests and the legitimate business interests of companies for whom we act as a manager, in order to provide the Services to you, with your consent, and/or compliance with our legal obligations and the legal obligations of companies for whom we act as a manager. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for our performance of the Services. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS” for further information.
• To send you marketing and promotional communications.We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
• To send administrative information to you. We may use your personal information to send you product, service and new feature information about changes to our terms, conditions, or policies, as well as information concerning the Services and Your Facilities.
• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Sites, Apps and/or Services.
• To protect our Services and Your Facility. We may use your information as part of our efforts to keep our Sites, Apps, Services and Your Facility safe and secure (for example, for fraud monitoring or prevention).
• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.
• To deliver services to the user. We may use your information to provide you with the Services.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues that you might have with the use of our Services and/or Your Facility.
• For other Business Purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, Apps and/or Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

We will not use identifiable personal information other than as provided in this privacy policy without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In short: We only share information with your consent, to comply with laws, to provide you with the Services, to protect your rights or to fulfill business obligations

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we, or a company for whom we are acting as a manager, have entered into a contract with you, we may process your personal information to fulfill the terms of that contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Service Providers.We may share your data with third party vendors, service providers, contractors, or agents who perform services for us or Your Company or on our behalf or on behalf of Your Company and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites and/or Apps, which will enable them to collect data about how you interact with the Sites and/or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business or Your Company’s business to another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites and/or Apps. These companies may use information about your visits to our Sites and/or Apps and other websites and/or applications that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites and/or Apps) or otherwise interact with public areas of the Sites and/or Apps, such as personal information may be viewed by all users and may be publicly distributed outside the Sites and/or Apps in perpetuity. If you interact with other users of the Sites, Apps and/or Services and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, Apps and/or Services, and view your profile.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and other tracking technologies (like web beacons and pixels) to access or store information.

5. DO WE USE GOOGLE MAPS?

In short: Yes, we use Google Maps for the purpose of providing better service.

Our Sites and Apps use Google Maps APIs. You may find the Google Maps API’s Terms of Use here. To better understand Google’s Privacy Policy, please refer to this link.

We use the Google Maps API anywhere we display a map or provide the capability to search for an address (collectively, our “Maps API Implementation”). By using our Maps API Implementation, you agree to be bound by Google’s Terms of Use. You agree to allow us to obtain or cache your location. You may revoke your consent at any time

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Sites and/or Apps offer you the ability to register and login using third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that otherwise made clear to you on the Sites, Apps and/or Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 90 days past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, Apps and/or Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites, Apps and/or Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@padsplit.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your information processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

If you would at any time like to review or change the information in your account to terminate your account, you can:

• Contact us using the contact information provided.
• Access your account settings

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites and/or Apps. To opt-out of interest-based advertising by advertisers on our Sites and/or Apps visit http://www.aboutads.info/choices

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list - however, we will still need to send you service-related emails that are necessary for the administration of your account. To otherwise opt-out, you may:

• Contact us using the contact information provided.
• Access your account settings

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites and/or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites and/or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites and/or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

12. DO WE USE THIRD PARTY SERVICE PROVIDERS THAT WILL HAVE ACCESS TO YOUR INFORMATION?

In short: Yes, we use certain third-party service providers who will have access to your information.

We use Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant PadSplit and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy. A copy of Plaid’s end user privacy policy can be found at: https://plaid.com/legal/#end-user-privacy-policy.

13. DO WE MAKE UPDATES TO THIS POLICY?

In short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by any updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have any questions or comments about this policy, you may contact our Data Protection Officer (DPO), Jon O’Bryan, by email at support@padsplit.com, or by post to:

PadSplit, PBC
Jon O’Bryan
691 West Whitehall Street SW
Atlanta, GA 30310
United States

15. HOW CAN YOU REQUEST DELETION OF YOUR DATA

Users may request deletion of their data at any time by contacting PadSplit at support@padsplit.com.