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Privacy Policy

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Last Updated: February 24, 2024

 

This Privacy Policy describes how Micronotes, Inc. (“Micronotes,” “we” or “us”) collects, uses and shares the information that is collected through any services, materials, publications and communications provided to You in conjunction with the Website (collectively, the “Program”). Portions of the Program may be available to You through the mobile app, website or other internet properties (collectively, “Apps”) provided by an Integration Partner (defined below). This Privacy Policy also describes the choices available to You regarding our use of Your personal information and how You can access, update and request deletion of such information. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Service.
Please read this Privacy Policy carefully to understand our policies and practices regarding Your information and how we will treat it. By accessing and using the Program, You agree to the terms and conditions of this Privacy Policy. If You do not agree to the terms and conditions of this Privacy Policy, please do not access or use the Program, nor provide any information to us.

We may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, we will post a revised version of this Privacy Policy on the Website. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” date at the top of this Privacy Policy. Your continued access to or use of the Program (directly or through an App) after any changes to this Privacy Policy have been posted shall constitute Your agreement and consent to such changes. Please return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

 

Collection and Use of Personal Information

 

Personal Information We Collect

We may collect certain information that identifies You or can be used to identify You (“Personal Information”) through Your use of the Program. If You interact with us through the services, such as an online banking or other financial services, of an Integration Partner, we may receive Personal Information about You from both You and Your Integration Partner. If You inquire about or respond to credit offers made by an Integration Partner with which You may or may not have a preexisting relationship, we may receive certain Personal Information about You from both You and the Integration Partner making such credit offers. “Integration Partner” includes any third party who makes available to You the services available on the Website and/or the Program or otherwise invites You access or use the Program to view credit offers and/or information contained on Your credit report. Integration Partners include credit unions, banks, mortgage lenders, credit card issuers, other financial institutions, and other parties. Additionally, if You inquire about, apply for, or respond to credit offers You receive from an Integration Partner, we may receive certain Personal Information about You from both You and the Integration Partner making such credit offers to You.

Personal Information may include, but is not limited to, the following categories of information:

  • Name
  • Email address
  • Postal address
  • Telephone number
  • Date of birth
  • Social security number
  • Information provided by You to authenticate Your identity
  • Username and password to access the Program
  • Credit information, such as Your credit score(s), number of open and closed credit accounts, outstanding amounts owed, payment history and other information contained in Your credit report

We collect Personal Information from the following sources: (a) directly from You through Your use of and interactions with the Program; (b) from Integration Partners with which You have a preexisting relationship; (c) from Integration Partners making credit offers to You with which You may or may not have a preexisting relationship; (d) from Integration Partners who have invited You access or use the Program to view credit offers and/or information contained on Your credit report with which You may or may not have a preexisting relationship; and (e) after You enroll with us, from one or more credit reporting agencies.

In addition, as You navigate through and interact with the Program, we may use automatic data collection technologies to collect certain information about Your equipment, browsing actions and patterns, including:

  • Information about Your usage of the Program, including the dates on which You retrieved information contained on Your credit report, as well as traffic logs indicating pages and content You have accessed, traffic data, logs, and other communication data and the resources that You access and use on the Program.
  • Information relating to the device You use to access and use the Program (such as the browser type, location of device, device ID, operating system, mobile network information).

For further information, see Cookies and Other Tracking Technologies below.

Use of Personal Information

We may use Your Personal Information to:

  • Authenticate Your identity and prevent fraud.
  • Fulfill Your requests, respond to Your inquiries, provide the features You enroll for on the Website and the Program, and/or complete transactions You have requested.
  • Retrieve Your credit report on an ongoing basis.
  • Send You requested product or service information or inform You of products or services that we believe You may be interested in.
  • Provide and transmit information on applications You initiate in response to credit offers made to You by an Integration Partner.
  • Display content based on Your interests.
  • For our internal business purposes, such as data analysis, audits, developing new products or services, enhancing and improving the Program, identifying usage trends and determining the effectiveness of features, offers and promotional campaigns.
  • As we believe to be required, necessary or appropriate: (a) to comply with legal process; (b) to respond to lawful requests by public authorities (which includes public authorities outside Your country of residence), including to meet national security or law enforcement requirements; (c) to enforce our terms of service; (d) to protect our operations, business and systems; (e) to protect our rights, privacy, safety or property, and/or that of other users of the Program, including You; (f) in the case of a dispute, to allow us to pursue available remedies or limit the damages that we may sustain; and (g) in any manner permitted under applicable law, including the laws outside Your country of residence.

 

Information Sharing

 

We share Your Personal Information with third parties only in the ways that are described in this Privacy Policy. We do not sell Your Personal Information to any third parties.

We may share Your Personal Information with third parties that are our agents or that provide services to us to help us with our business activities and in providing the Program to You, such as authentication of the identity of users, preventing fraud, website hosting, data analysis, email delivery services, text delivery services, retrieving credit reports, credit application processing, and customer service. These third parties are authorized to use Your Personal Information only to enable them to provide services to us or act as our agents in performing the activities we are permitted to conduct under the Terms of Service and this Privacy Policy. We require that these third parties are bound by contractual obligations to keep Your Personal Information confidential and use it only for the purposes for which we disclose it to them.

We may share Your Personal Information with an Integration Partner, including when You apply for credit offers made by an Integration Partner through the Website or the Program, or when You request that an Integration Partner or other third party follow up with You about Your income, debt and spending, or to otherwise contact You regarding credit offers and other promotions for which You may be eligible. Also, if You inquire about, apply for, or respond to credit offers You receive from an Integration Partner, we may share Your Personal Information with such Integration Partner and its third party providers that allow You to apply for such credit offers. Additionally, we may share Your Personal Information with Integration Partners who have invited You access or use the Website and/or Program to view credit offers and/or information contained on Your credit report. Lastly, if You seek customer service assistance from an Integration Partner for Your account with us, such Integration Partner may be provided with access to Your account, including all information contained in Your account. The Personal Information that we may share with an Integration Partner include: (a) Your contact information (which includes Your name, email address and postal address); (b) whether You appear to qualify for credit offers made available by such Integration Partner; (c) based on Your credit report, whether You appear to meet certain credit thresholds or criteria; (d) Your credit score(s) and any credit application information You submit; and (e) information about Your usage of the Website and/or the Program, including the content You access.

You may opt out of receiving offers from an Integration Partner based on Your Personal Information provided by us to such Integration Partner by contacting us at our contact information at the end of this Privacy Policy. Please allow up to 60 days for us to implement Your opt out request for offers from such Integration Partner. For purposes of clarity, if You also wish to opt out of receiving emails and other communications from an Integration Partner (which are not based on Your Personal Information provided by us to such Integration Partner), You must do so in compliance with the applicable terms, conditions and privacy policy of such Integration Partner. You may not opt out of viewing certain offers that appear on Your screen when You are logged into an App offered by an Integration Partner, whether or not based on Your Personal Information provided to us from such Integration Partner. If the Program is no longer being offered or made available through an Integration Partner, such Integration Partner may notify You of such fact, even if You have opted out of receiving marketing emails and communications.

Please understand that this Privacy Policy governs only Micronotes’ collection, use and disclosure of Your Personal Information. The collection, use and disclosure of Your Personal Information by an Integration Partner or any other third party that You authorize to receive Your Personal Information is governed by that Integration Partner’s or other third party’s privacy policy.

We may also disclose Your Personal Information:

  • As required by law, such as to comply with a subpoena or similar legal process.
  • To respond to lawful requests by public authorities (which may include public authorities outside Your country of residence).
  • To protect our rights, privacy, safety or property, and those of users of the Program, including You.
  • To an affiliate or other third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings) (each, a “Transaction”). If we are involved in a Transaction and a third party receives Your Personal Information as a result, You will be notified via email and/or a prominent notice on the Website of any change in ownership or uses of Your Personal Information, as well as any choices You may have regarding Your Personal Information.
  • To any other third party with Your prior consent to do so.

 Non-Personal Information

We may use and share freely any information that we collect from or about You that is not Personal Information, subject to applicable law. Any information about You that has been aggregated or anonymized, such that it cannot be used to identify any individual, is not considered Personal Information. When we combine information about You that is not Personal Information with Your Personal Information, we treat it as Personal Information for as long as it is combined with Your Personal Information.

 

Data Security

 

We have implemented industry standard physical, administrative, and technical safeguards to preserve the integrity and security of Your Personal Information. Such safeguards include using secure socket layers (SSL) and encryption both during transmission of Your Personal Information (such as Your address, date of birth, and social security number) and after we receive Your Personal Information. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the absolute security of any information You transmit to us or which is transmitted by us, You authorize us to obtain on Your behalf, or You receive from us, and we cannot guarantee that Your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, administrative and/or technical safeguards. Additionally, we will not be responsible or liable to You for third party circumvention of our security measures. If You have reason to believe that Your interaction with us is no longer secure (for example, if You believe that the security of any account You might have with us has been compromised), You must immediately notify us of the problem by contacting us at our contact information at the end of this Privacy Policy.

In our agreements with Integration Partners, we commit to maintaining an information security program, and notifying the Integration Partners of any security breaches, consistent with the applicable obligations of the Integration Partners under the Gramm-Leach-Bliley Act.

 

Your State Privacy Rights

 

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. In particular, California law grants additional privacy rights to California residents. In particular, the California Privacy Rights Act of 2020 (“CPRA”), amending California Consumer Privacy Act of 2018, requires businesses to disclose, for the past 12 months: (a) the categories of personal information collected, (b) the sources of the collected personal information, (c) the purposes for which the collected personal information is used, (d) the categories of personal information disclosed for a business purpose, and (e) the categories of any personal information sold or shared. We provide these disclosures in the following table, subject to the further disclosures elsewhere in this Privacy Policy. In addition, the CPRA provides specific rights to limit use of personal information defined as “sensitive.”

Please note that Micronotes does not “sell” or “share” any of Your Personal Information as those terms are defined in the CPRA. With respect to any of Your Personal Information defined under the CPRA as “sensitive” (e.g., social security number and financial account information), Micronotes only uses such information as necessary to provide the Program.

 

California residents also have the rights described below.

Right to access/know Your Personal Information. You may request from us a list of (a) the Personal Information that we have collected about You, and (b) the categories of third parties to whom we have disclosed Your Personal Information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete Your Personal Information. You may request, at any time, that we delete Your Personal Information and direct our service providers to delete Your Personal Information from their records. We are not required to delete any information that is necessary to provide the products or services You have requested, to detect security incidents, or to comply with a legal obligation, among other limited exceptions.

Right to limit use of Your Personal Information that is sensitive. You may request, at any time, that we limit our use of sensitive Personal Information to that use that is necessary to provide the Website and Program to You.

You may contact us to exercise these rights at privacy@Micronotes.com. To ensure the privacy and protection of individuals, we are required to verify Your identity (or that of Your authorized agent) or otherwise authenticate Your request(s), which we will do in accordance with the CPRA regulations. Please note that, under the CPRA, we are not required to grant a request to access/know or a request to delete with respect to Personal Information obtained from You in Your role as an employee, owner, director, officer or contractor of a company and within the context of Micronotes providing its services to such company.

Under the CPRA, You have a right to be free from discrimination as a result of exercising any of the CPRA rights afforded to California residents. If You choose to exercise such rights, we will not deny You the ability to use the Program (or suggest that we might do so), charge You or the Integration Partner a different rate for the Program (or suggest that we might do so) or change the quality of the Website or the Program pertaining to You. The only exceptions are when You have an account with us and: (a) You wish to delete any or all of Your Personal Information or (b) You wish for Micronotes not to share Your Personal Information with third parties, in either which case You may do so only by closing Your account with us, at which point You will no longer have the ability to access the member-only features of the Program. If You do not have an account with us and (i) You wish to delete any or all of Your Personal Information or (ii) You wish for Micronotes not to share Your Personal Information with third parties, please contact us at our contact information at the end of this Privacy Policy with Your request. 

Accessing, Correcting, Updating and Deleting Your Personal Information

Upon request, Micronotes will provide You with information about whether we hold any of Your Personal Information.

To access, correct or update Your Personal Information or to ensure it is accurate, contact us at our contact information at the end of this Privacy Policy. In order to comply with any of Your requests pertaining to Your Personal Information, we will first need to authenticate Your identity and thereafter we will try to comply with Your request as soon as and to the extent reasonably practicable. We will respond to Your request within a reasonable timeframe. Please note that we cannot remove Your Personal Information from the database of third parties who previously received such information.

Retention Period

We will retain Your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy as well as may be necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, all in accordance with applicable law.

Links to Other Websites or Internet Properties

The Program may include links to other websites or other internet properties whose privacy practices may differ from those of Micronotes. If You submit Personal Information to any of those websites, Your Personal Information is governed by their privacy policies. We encourage You to carefully read the privacy policy of any website You visit.

 Testimonials

We display personal testimonials of customers on the Website in addition to other endorsements. With Your consent, we may post Your testimonial along with Your name. If You wish to update or delete Your testimonial, You can contact us at info@Micronotes.com.

Children’s Privacy

Protecting the privacy of children is especially important to us. The Program are not directed to individuals under the age of 13, and we do not knowingly collect Personal Information from anyone under the age of 13. If You are under the age of 13, do not use the Program or provide any Personal Information to us. If we become aware that we have collected Personal Information from anyone under the age of 13, we will delete that information. If You believe we might have any information from or about a child under the age of 13, please contact us at privacy@Micronotes.com

Jurisdictional Issues

We do not represent or warrant that the Program, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Program do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.

 

Contact Information

 

If You have any questions or comments about this Privacy Policy or our privacy practices, You can contact us as follows:

By email at: privacy@Micronotes.com

By mail at:
Micronotes, Inc.
Attn: Privacy
50 Milk Street, 16th floor
Boston, MA 02109