Last updated: December 2015
Change Labs Ltd. (the “Company“, “us“, “our” or “we“) provides vicariously through its designated website (the “Website“), web-based services and SMS text messages designated to assist individual users to better manage their day-to-day financial operations and to provide them with financial recommendations, recommendations based on behavioral analysis of user’s transaction history and financial behavior patterns, and comparative information related to management of their spending and financials, through the use of behavioral analysis algorithms (the “Service“; the Service users shall be referred to as the “Users“, “you“ or “your“).
Information That We Collect
Personal Information. During your use of the Website and/or Services, we may collect, save or otherwise keep in our possession certain information that identifies you personally, such as your name, serial account number, physical address, phone number, email address, photo, documents, details and information regarding your financial transactions, transaction history and records or statistics, or any other information that may personally identify you (“Personal Information“). We may collect such information through your use of the Website and/or Services or from information that is entered into our system by any other User uploading, sharing or otherwise making such information available.
Non-Personal Information. We may also collect, save or otherwise keep in our possession information that does not identify you personally, such as your history of use of the Website and/or Services. We refer to information that does not identify you personally as “Non-Personal Information“.
Additional Information. When using the Website and/or Services, we may also collect, save or otherwise keep in our possession certain information that your browser sends to every Internet website you visit, such as your IP address, your browser information (including browser type, capabilities and language), your operating system, the date and time you accessed the Website, certain location-based data, and the website from which you linked to the Website and/or Services.
By using the Website and/or Services you voluntary agree to provide us with any information, and to collect, save or otherwise keep in our possession such information (including Personal Information). If you refuse to provide us such information you may not have access to all functionality of the Website and/or Services.
Please note that while we make reasonable efforts to secure all information and User Accounts, it is impossible to have the information and User Accounts completely secure. As such, we cannot accept any liability for the disclosure of Personal Information as a result of unauthorized access to our system, Website or User Accounts.
With respect to accessing your Bank Account(s), we do not save or gain access to any bank credentials but use Plaid (as defined below) to access account transactions. After the creating an Account, once credentials are secured, they are passed directly to the Bank through Plaid, pursuant to which the Company receives an encrypted token that allows the Company to access the Bank Account and transaction details through Plaid.
Our Use of Information
We use Personal Information for internal purposes only, to improve our Website or Services and to better tailor them to meet your needs.
By analyzing the information we are provided or we collect, save or otherwise keep in our possession, including all Personal Information, we may compile certain statistical information, such as without limitation anonymous information about how Users use the Website and/or Services (the “Statistical Information“). Statistical Information helps us understand trends and User needs so that new products and services can be considered and so existing products and services can be tailored to User desires. Statistical Information is anonymous and will not be linked to any Personal Information for provision to third parties. We may share such Statistical Information with our affiliates, without restriction, on commercial terms that we can determine in our sole discretion.
Legal Disclosures. In the event we are required to disclose Personal Information or Non-Personal Information, or any other related information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws or regulations, we will make such disclosure. It is our policy to cooperate with law enforcement agencies, and we will fully cooperate with any ongoing law enforcement investigation, including to the extent we are required to disclose Personal Information.
Change of Ownership. In the event the ownership of all or a part of our business were to change, your Personal Information and other related information pertinent to the business’ operations would likely be transferred to, or licensed for use by, the new owner.
Third Party Service Providers. In connection with and in addition to the abovementioned, we use third-party service providers to perform certain services on our behalf. We may provide your Personal Information to these third-party service providers. These third-party service providers will be contractually restricted from using Personal Information for any other purpose and required to comply with all applicable laws with respect to your Personal Information. Such third party service providers may be located in jurisdictions that are not your home jurisdiction and, as such, may be subject to statutory or regulatory obligations that are not as protective as the applicable laws or regulations in your home jurisdiction.
Removal of Information
You may request that we delete your account for the Website or Services. If you do so, your Personal Information will be permanently expunged from our servers and further access to your account will not be possible. We will also promptly disconnect any connection we had established to your Account Information (see below) and delete all Personal Information in our possession. However, portions of your Personal Information, in de-identified and aggregate forms, may remain on our system indefinitely. We reserve the right to use this aggregate data to improve our service and for other lawful purposes, as discussed above. Further, please note that we also may need to store your data as required by federal, state or local law, even if you request that we delete it. To request deletion of your account, email firstname.lastname@example.org, requesting a deletion of your account. Merely deleting the app from your device does not constitute a request to delete your account.
Other Websites, Services and Communities
A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. A “persistent” cookie may be used to help save your settings and customizations across visits. Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Website may not function properly when cookies are disabled or removed.
Information Sent by Mobile
We collect certain information that your mobile device sends when you use our Website or Services, such as a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
We may use any contact information you have provided us to provide you with information concerning updates to the Website or Services or such other materials and information related to the Website and/or Services. You expressly agree to the receipt of such communications.
Policy Regarding Children
You must be 18 years old or older to use the Website, Application or Services; we do not knowingly collect information from children under the age of 18. If we become aware that we have collected Personal Information from a child under the age of 18 years old, we will use commercially reasonable efforts to delete such information from our database.
Responding to Do Not Track Signals
Our Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.