Privacy policy

Last revised: October 10, 2017

This Privacy Policy (the "Privacy Policy") applies to the cushion.ai website and our related social media sites, including our Facebook Messenger bot (collectively, the "Site") operated by Cushion AI, Inc. ("Us", "We" or "Our") and the services available through the Site (the "Service").

Your access to and use of the Service is conditioned upon your acceptance of this Privacy Policy. By accessing or using the Service you agree to be bound by this Privacy Policy and our related Terms of Service (the “Terms”).

Your access to and use of the Service is subject to all terms of use contained herein and the Terms and all applicable laws and regulations. If you disagree with any part of this Privacy Policy or the Terms, then you do not have permission to access the Service. Capitalized terms used by not defined in this Privacy Policy are used as defined in the Terms.

We will not use or share your information with anyone except as described in this Privacy Policy. We do not knowingly provide the Service to or solicit or collect information from any individuals under the age of 18.

INFORMATION WE COLLECT

A.  User Provided Information

When you establish an Account, We may ask you to provide Us with contact information in order for Us to identify and communicate with you, including your first and last name as well as your email address. We will retain your email address solely for the purpose of communicating with you about the Service. As part of our primary offering, We also ask that you provide your account information, including log in credentials, for each bank/retailer/service provider (each, an "Institution") with which you wish to use the Service. As We expand the Service, we may request other information.

When you are using the Service, We collect information about your Institutions' account transactions and trust relationships and other account information.

B.  Automatically Collected Information

When you visit the Site, We also collect your IP address and standard web log information, such as your browser type, the pages you accessed on the Site, the time and date of your visit, the time spent on those pages and other statistics.

We use cookies to collect information in order to improve the Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

Finally, We may collect additional anonymous information from or about you or your Institutions, including but not limited to an Institution's APR rates, reward information, and similar information.

USE OF INFORMATION COLLECTED BY US

Our primary purpose in collecting information is to provide you with a safe, secure, effective and efficient experience and to improve the Service and Site. We may use your information to: provide the Service; process transactions; troubleshoot problems; prevent prohibited activities; customize and improve the Service; communicate with you; and perform other duties as required by law.

We also may use anonymized, aggregated data that includes your information to evaluate and compare the use and effectiveness of the Service.

SHARING PERSONAL INFORMATION

We do not share your information with third parties for promotional or marketing purposes. However, We may share your information:

• With the Institutions you register with Us in order to provide the Service;

• With Our service providers who assist Us in order to provide the Service and operate the Site (which may only use the information as described in this Privacy Policy);

• As part of, or following, an acquisition or other change of control including a merger or sale of assets involving Us; and

• As required by law or if reasonably necessary to prevent physical or financial harm, or to investigate violations of this Privacy Policy or the Terms.

PERSONAL AND FINANCIAL INFORMATION

We use the vendors identified below to facilitate delivery of the Service and to store personal and financial information and other bank credentials which you provide to Us and which is necessary for you to use, and for us to provide, the Service. These parties are prohibited from using your Personal Information for any other purposes.

PROTECTION & STORAGE

WE use MX Atrium to securely connect to your bank and fetch your bank transactions. We store and process your personal and financial information and electronic copies of all correspondence through Amazon Web Services and VGS. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. The privacy policies and security systems utilized by these parties can be viewed at https://aws.amazon.com/privacy/, https://www.mx.com/privacy-policy, and https://www.verygoodsecurity.com/.

CHANGES

We reserve the right to update or change this Privacy Policy at any time by posting a new policy on this page. We will notify you of any changes to Our Privacy Policy by changing the “Last Revised” date above. Any such changes will automatically apply to all uses of the Application on or after such effective date (until such time as this Privacy Policy is subsequently revised).Your continued use of the Service after We post any modifications to this Privacy Policy will constitute your agreement to such modified Privacy Policy.

INTERNATIONAL OPERATIONS: A NOTE TO USERS OUTSIDE OF THE U.S. AND THE EU

For international users, please note that it may be necessary to transfer your information internationally and, in particular, your information may be transferred to and processed in the United States. For residents of the European Union: the data protection and other laws of other countries outside of the European Union may not be as comprehensive as those of the European Union. Please be assured that we take steps to ensure that your privacy is protected as described in this policy. By using the Services, you agree to have your information transferred to and used in the United States as set forth in this policy.

YOUR CALIFORNIA PRIVACY RIGHTS

California Do Not Track Notice:
Because there are not yet common, industry accepted “do not track” standards and systems, Our Application does not respond to Do Not Track signals.

California Disclosure Information:
Although We do not collect or retain, and therefore will not disclose to any third parties for their marketing purposes, any personally identifiable information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personally identifiable information, such as name, address, date of birth, social security number, email address, and any other types of personally identifiable information that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under “Contact Us”. If We receive your request at a different email or mailing address, We will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

We comply with state and federal rules of the United States regarding the collection, use and retention of personally identifiable information and data. The recipients of users' personally identifiable data, and more generally these disclosures, may be located in the United States or other jurisdictions that might not provide a level of protection equivalent to the laws in your jurisdiction. If you submit personally identifiable data to us, you consent to the transfer of such personally identifiable data outside your jurisdiction.

HOW TO CONTACT US

If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practices for Our Application, please contact Us at: [email protected].

Cushion AI, Inc.