February 2nd, 2023
3. INFORMATION WE COLLECT AND HOW WE USE IT.
Our purposes in collecting, storing and using the personal data We collect from you are to provide and improve Our Services, to administer your use of the Service, to notify you about new features, and to enable you to enjoy and easily navigate Our Services.
A. Information You Provide to Us.
- Account Information. When you sign up for an Account with Our Services, you will need to provide us, Our third party payment processor, or Our third party payment provider, with Personal Information. This may include your name, email, mailing address, phone number, date of birth, Social Security Number, wet-ink signature, and other related information.
- Information Necessary for Our Services. When you use Our Services, We will need to collect and store Personal Information to assist you in fighting charges from your Financial Institution Accounts. Some examples include, but are not limited to, your Financial Institution Accounts’ login information such as your username and passwords, verification codes, and security questions and answers needed to access your Financial Institution Accounts, and other related information. We may collect when necessary transaction information from your Financial Institution Accounts.
- Transactional Information. We and Our third-party service providers may Process your financial and payment card information in order to facilitate a transaction that you request.
- Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about Our Services, request customer or technical support, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
- Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information We collect may be associated with accounts and other devices.
B. Information You Provide to Us
We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access Our Services through a third-party application, such as an App Store, a third-party login service, or a Social Networking Site (“SNS”), We may collect information about you from that third-party application that you have made available via your privacy settings. Information We collect through these services may include your name, your user identification number, your user name, email, and your contacts stored in that service. This supplemental information allows Us to verify information that you have provided to Us and to enhance Our ability to provide you with the Services.
4. information we collect and how we use it.
A. To Provide Products, Services, or Information Requested.
- Identify money-saving opportunities;
- Recommend financial products or other promotional opportunities;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of Our Services; and
- Answer requests for customer or technical support.
B. Administrative Purposes.
- Measure interest and engagement in Our Site and Services;
- Improve Our products and Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate with you about your account, activities on Our Site and Services and policy changes;
- Process your financial information and other payment methods for products or Services purchased;
- Prevent potentially prohibited or illegal activities; and
- Enforce Our Terms.
C. Marketing Our Products and Services
You may contact Us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
D. De-identified and Aggregated Information Use.
E. Other Uses.
Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows Us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of such Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to Our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of Our functions;
- Performance Related. We may use Technologies to assess the performance of Our Services, including as part of Our analytic practices to help Us understand how Our visitors use the Services;
- Functionality Related. We may use Technologies that allow Us to offer you enhanced functionality when accessing or using Our Services. This may include identifying you when you sign into Our Services, keeping track of your specified preferences or past pages viewed;
- Advertising or Targeting Related. We may use first party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on Our Services or on third-party sites.
G. Marketing Our Products and Services
To track opt-outs, Our session replay service providers use an opt-out cookie placed on your device. Please note that if you get a new device, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the opt-out cookie. Third Party Websites/Applications and Software Development Kits. The Services may contain links to other websites/applications and other websites/applications may reference or link to Our Site or other Services. These other domains and websites are not controlled by us. We encourage Our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of Our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about Our use of APIs and SDKs, please contact Us as set forth below.
5. How We May disclose your information.
A. We Use Service Providers.
We may share any Personal Information We receive about you with Our third-party service providers, including Plaid (as provided in our Terms of Service). The types of service providers to whom We entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing services; (iv) customer service activities; and (v) the provision of the Services.
B. Payment Processing.
C. Business Partners.
D. Disclosures to Protect Us or Others.
E. Merger, Sale, or Other Asset Transfers.
6. INTERNATIONAL DATA TRANSFERS.
7. Your Choices.
B. Email Communications
We may send you push notifications or contact you through the Services with notices or alerts that may be of interest to you. You may opt out of receiving push notifications from Our mobile application by contacting us directly.
D. "Do Not Track"
8. ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION.
We will process such requests in accordance with applicable laws. To protect your privacy, Cushion will take steps to verify your identity before fulfilling your request.
9. Data Retention.
10. Security of Your Information.
By using the Services or providing Personal Information to us, you agree that We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If We learn of a security system’s breach, We may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
Cushion uses Plaid to securely connect to your bank and fetch your bank transactions as well. 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 Amazon AWS Privacy and Very Good Security.
11. Children's Information.
12. California's Privacy Rights.
Upon consent to access your email inbox through the Auto-Import service, Cushion may read messages and metadata for bills and Buy Now Pay Later (BNPL) purchases. Relevant information from the emails will be displayed in the app to enhance the monitoring and analytics of bills and BNPL purchases. Cushion will not sell or provide these emails to a 3rd party. Cushion scans bill-related and BNPL emails based on the sender’s email domain, keywords, or other identifiers and securely stores relevant information in our database. The data stored includes, but is not limited to, the sender’s email address, time sent, subject, text, and images. Data for emails unrelated to bills or BNPL purchases will not be stored.
Bills include, but are not limited to, subscriptions, utilities, insurance, rent, phone, internet, cable, loans, debt, and recurring payments. Buy Now Pay Later (BNPL) includes any purchase paid over a period of time, which a merchant can offer to their customer directly, or through a provider specializing in BNPL or pay-over-time financing.
14. Terms of Service.