Last Updated: August 6, 2019
In providing the Service, we collect and obtain information about individual consumers (“End Users”) to, among other things, provide a personal finance information management tool that allows you to track and organize your finances, including through the aggregation of your financial account information (“Account Data”) from financial institutions and other third-party data sources you select and with whom you have a contractual relationship (“Third-Party Data Sources”).
1. Information We Collect. Copilot collects information from and about End Users in a variety of ways. This information includes:
A. Information You Provide. We collect information you provide when you use the Service or otherwise communicate with us, including your banking and financial account information for Third-Party Data Sources. If you register an account with us, we will collect the information you provide, such as your name, email address, login credentials for Third-Party Data Sources, budget names and amounts, bills, and monthly subscriptions. We will also collect your Account Data from Third-Party Data Sources on your behalf and any other information you submit through your use of the Service. We may also collect information through your communications with our customer-support team.
B. Provider-Submitted Information. Our third-party service providers may provide us information about End Users or assist us in obtaining the Account Data (including a list of the End User’s financial transactions) from Third-Party Data Sources. We use and disclose this information only in accordance with our provision of the Service to the End User.
C. Device and Usage Information. Like most online services, we automatically receive standard technical information when you interact with the Service, including browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), browser types, and the date and time of your interactions. We also receive information about your interactions with our Service, such as which website pages you visited and how much time was spent on the page, and which user invited you via an identification code.
We may collect this information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable us to personalize your experience on the Service, maintain a persistent session, passively collect demographic information, and monitor advertisements and other activities. The Service may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).
2. How We Use Your Information. We use information in a variety of ways to provide the Service and to operate our business, including the following:
A. Service-Related Usage. We use the information we collect about and from you for a number of purposes, including providing and supporting the Service, analyzing how you use the Service, and better tailoring features. We also use the login credentials you provide for the Third-Party Data Sources to retrieve, analyze, and present to you your Account Data.
B. Communications. We use your information to communicate with you for Service-related purposes. For example, we may send email to the email address you provide to us for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes.
C. Improve the Service. We use the information that we collect: (1) to understand and analyze usage trends and preferences; (2) to monitor and analyze the effectiveness of the Service; and (3) to improve the Service and develop new products, services, features, and functionality.
D. Marketing. As permitted by applicable law, we may use information we collect about and from you for marketing purposes, such as providing you with promotional materials that may be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we’ll obtain your prior opt-in consent to send you electronic marketing communications.
3. How We Share Your Information. We do not share your information with (1) other companies for joint marketing purposes; or (2) any third parties so they can market to you. We may share, transfer, or disclose your information if you consent to us doing so, as well as in the following circumstances:
A. Service Providers. We share information with third parties who provide services to us, such as customer service, interfacing with Third-Party Data Sources, analytics, website management, information technology, and other similar service providers.
B. Comply with Legal Requirements. We may disclose your information as we believe to be necessary or appropriate to: (1) comply with applicable law and legal processes; (2) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (3) enforce our Terms of Service; (4) protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (5) allow us to pursue available remedies or limit the damages that we may sustain.
C. Corporate Transactions. We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
D. Aggregate, De-Identified Information. We may use your data to create aggregate or statistical information that does not directly identify a specific person, and we may share that information. For example, we may share anonymous and aggregated reports and information on user demographics and traffic patterns with third parties.
5. Children’s Privacy. We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of the Service is directed to children under the age of 18. If you learn that your child has provided us with personal information without your consent, you may alert us at the contact information listed below. If we learn that we have collected any personal information from children under 18, we will promptly take steps to delete such information and terminate the child’s account.
You can opt-out of receiving further promotional emails from us by following the unsubscribe instructions provided in the promotional email you receive or by emailing us directly at firstname.lastname@example.org with "OPT-OUT," "UNSUBSCRIBE," "STOP," or "REMOVE" in the subject line.
8. California Residents.
California law requires us to disclose how we respond to web browser Do Not Track signals. Because there currently isn’t an industry or legal standard for responding to Do Not Track signals, we do not respond to them at this time.
California law provides California residents with specific rights regarding their personal information. If you are a California resident, this section describes your rights and explains how to exercise those rights.
A. Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information we collected about you (also called a data portability request).
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
· sales, identifying the personal information categories that each category of recipient purchased; and
· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
B. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
· Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
· Debug products to identify and repair errors that impair existing intended functionality.
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
· Comply with a legal obligation.
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
C. Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
· Calling us at 504-475-1474.
· Visiting https://www.copilot.money/ccpa.html
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
D. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your California privacy rights. Unless permitted by California law, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Copilot Money, Inc.
45 Tudor City Place, Apt 1118
New York, NY 10017