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).

Terms not otherwise defined herein shall have the same meaning ascribed to them in our Terms of Service available at Terms of Use (the “Terms of Service“).

Your privacy is important to us. We highly value and respect the privacy of the personal information we obtain from you by using our Website, Application and Services and we have created this privacy policy (the “Privacy Policy“) to inform you about how we collect, use and share your information, and our privacy practices in general. Unless otherwise stated below, we do not share your Personal Information (as defined below) with any third parties. This Privacy Policy together with the Terms of Service constitutes the entire agreement between you and the Company and should be read jointly.

By accessing and using the Website and/or Services via the User Account, you agree to be bound by this Privacy Policy. If you do not agree to any of the provisions as set hereunder in this Privacy Policy, you have no right to use the Website or Services. This Privacy Policy should be read together with the Terms of Service and together they constitute the entire agreement between you and us. This Privacy Policy and the Terms of Service may be updated from time to time and therefore we ask you to check back periodically to read the most updated Privacy Policy. The most current version of the Terms of Service is available at Terms of Use. Your continued use of the Website and/or Services shall be deemed to be your continued acceptance of the terms of this Privacy Policy, as amended. Terms that are capitalized in this Privacy Policy and not defined herein shall have the meaning set forth in the Terms of Service.

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.

We do not share your Personal Information with: (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you. We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Service or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; or (7) as permitted by applicable law or otherwise described in this Privacy Policy.

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.

To Protect Us or You. In connection with the abovementioned, we may disclose your Personal Information and other related information in the event we reasonably believe such disclosure is necessary to protect the Website or Services, our rights or property, or the rights of any third party. We may disclose your Personal Information and other related information, when we have reason to believe that disclosing such information is necessary to identify, contact or bring legal action against someone who may be violating this Privacy Policy or may be causing injury to or interference with (either intentionally or unintentionally), our rights or property, other Users, or anyone else that could be harmed by such activities. You thus authorize us to disclose any information about you to law enforcement or other government officials if we, in our sole and absolute discretion, believe that such disclosure is necessary or appropriate.

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 support@gochange.co, 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

Please be aware that when you are using the Website and/or Services, you could be directed via hyperlinks or other means to third-party websites, services and online communities that are not affiliated with us. Our Privacy Policy only addresses the use and disclosure of information we collect from you. Different rules or policies may apply to the use or disclosure of the information which you disclose to third parties. These third-party websites, services and online communities may send their own cookies to visitors to collect data or solicit your Personal Information. The privacy policies of these websites, services and online communities may be very different from this Privacy Policy. We are not responsible for the privacy practices of these other websites, services and online communities and cannot guarantee the security of any of your Personal Information collected, used or shared there. 

Plaid API

In order to provide you with the best service possible, the Company uses an Application Programming Interface supplied by Plaid Technologies, Inc. (“Plaid“), used to gather your data from financial institutions. By using the Website and/or Services, you acknowledge and agree to Plaid’s privacy policy, available at https://plaid.com/legal and acknowledge and agree that your information shall be treated in accordance with such policy.

Cookies

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.

Communications

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.

Questions

You may direct questions concerning this Privacy Policy by email to support@gochange.co by adding the word ‘privacy’ in the subject line.