Date Last Revised for SquareFairy Inc.: September 17th, 2019
Information we collect
When you use the Services, you may provide and we may collect information about you or that can be used to identify you, including your name, e-mail address, mailing address, billing address, mobile phone number, age, gender, date of birth, username and password. For example, you may provide us with Personal Information when you register for a SquareFairy account, when you fill out forms or fields on the Site, when you participate in online surveys, and when you contact us or request information about us, this Site and our Service (whether by email or other means).
When you use the Services, you may provide and we may collect certain financial information including your social security number, financial account information, investments, income, expenses, investible assets, investing risk tolerance, and other similar types of information. Providing alternative asset/debt splits means you will need to provide the various things you own, when you acquired them, what you still owe on them, if anything, and other information to enable us to assign a value to them, and know the tax consequences if they are sold.
When you use certain Services (such as the prequalifying for credit cards or loans), you authorize SquareFairy to send your information to certain third party partners on your behalf and you authorize these partners to obtain credit reports and related information about you from one or more consumer reporting agencies.
We may also get information from other companies or third parties, such as when you sync a third party account or service with your SquareFairy Service, or when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service.
When you use the Services, we may send one or more Cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both Session Cookies and Persistent Cookies. A Session Cookie disappears after you close your browser. A Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent Cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your Cookie settings. If you delete, or choose not to accept, Cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.
Automatically Collected Information
When you visit the Site, use the Services, or open an email from SquareFairy, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, Global Positioning System (GPS) location data and or motion data, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Services. When you use the Site on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals.
Third Party Web Beacons and Third Party Buttons
We may implement third party advertising or other content on the Site that may use clear gifs or other forms of web beacons, which allow the third party content provider to read and write Cookies to your web browser in connection with your viewing of the third party content on the Site. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser Cookies, even when you do not interact with the button.
A number of different targeting and advertising programs may be used on this Site, including without limitation, Google Analytics. We allow third parties, including business partners, advertising networks, analytics providers, and other advertising service providers to collect information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. These third parties may use this information to display advertisements on our Site and elsewhere online, and across your browsers and devices, tailored to your interests and preferences. Information collected through web beacons, buttons, and similar technologies is collected directly by third parties, and we are not responsible for the privacy practices of these third parties. The information collected by these third parties in this manner is subject to that third party’s own privacy policies. Some of these third parties are members of the Network Advertising Initiative and participate in the industry’s opt out, available at http://optout.aboutads.info/#! or at http://optout.networkadvertising.org/#!/. Additionally, you may opt-out of the use of Google Analytics Cookies here: https://tools.google.com/dlpage/gaoptout.
Information from Other Sources
How we use your information
Your information is an integral part of our operations, and we use it in a variety of ways in providing the Services and operating our business. Unless prohibited by law, regulation, or a contractual obligation, we may use your information, including your Personal Information, for the following purposes:
Account Registration. We may use your name, address, phone number, and email address to register your SquareFairy Account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current.
If you decide to allow your spouse/ex and/or divorce attorney/mediator to see your assets/debts, in order to propose alternative separation of assets and debts, you may allow them to also modify the values and other associated information. We will make efforts to allow you to know when such changes are made, so you can agree with them, or revert the changes and propose your own alternatives.
Communicate with You and Tell You About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that we think may be of use to you. Please see below under "What You Can Do to Manage Your Privacy" for the choices you have regarding these communications.
To Improve Services and Develop New Services. We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of SquareFairy’s Services.
To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information.
Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience. We also offer various Internet chat services, for example, to speak with a SquareFairy support representative or asset split assistant. Internet Chat transmissions may be encrypted but you should not supply more Personal Information than is required to address your specific issue. A transcript of the session is retained to resolve questions or issues related to our Services.
E-mail address. We may use your e-mail address or other Personal Information (a) to contact you for administrative purposes such as customer service, (b) to address intellectual property, right of privacy or defamation issues related to content you have posted on the Services, and/or (c) to send you promotional materials, offers, and/or messages related to the Services and the activities of third parties we work with. Generally, you can opt-out of receiving promotional communications, through links provided in the messages, by updating your account preferences through the Services, or by contacting us directly at email@example.com.
Feedback. We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them. Answering any survey is optional.
Research, Including Publishing or Sharing Combined Information from Many Users, But Only in a Way that Would Not Allow You or Any Other Person to be Identified. Only in a way that would not allow you or any other person to be identified, we may prepare and share information about our customers with third parties, such as advertisers or partners, for research, academic, marketing and/or promotional purposes. For example, we may share demographic data that describes the percentage of our customers who use mobile services or who use a particular operating system. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.
How we share your information
Third Party Service Providers. We may share your information, including Personal Information and Usage Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they're providing to us or on our behalf.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
Protection of SquareFairy and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products' Terms of Service and other agreements; or protect the rights, property, or safety of SquareFairy, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Statement.
Information Sharing Between SquareFairy Entities. We share your information, including your Personal Information, with and among our affiliates and subsidiaries, except where prohibited by law, regulation, or a contractual obligation. The protections provided in this Privacy Statement apply across all SquareFairy entities. Affiliates and subsidiaries means companies related by common ownership or control. The reasons why we share your information include for our everyday business purposes, such as to: process your transactions, maintain your accounts, operate our business, facilitate Single Sign On to your SquareFairy Account, etc. We will also share your information in order for us to be able to offer our products and services to you. We may also share information about your creditworthiness, your transactions and experience so that we can operate our business effectively, detect and prevent fraud, and improve our Services.
Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.
With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.
When we disclose information
We may disclose your information in connection with providing the Services and the operation of our business. For example:
We may share Personal Information with certain of our third party partners to verify your identity in connection with your use of certain aspects of the Services.
For example, we may ask for your social security number, or a portion of it, to verify your identity in connection with services that enable you to see your current credit score or other financial information.
We may share Personal Information with third party service providers in connection with your use of specific aspects of the Services. Some examples include but are not limited to:
When you request answers through our Services, SquareFairy may provide certain of your information to third party experts, advocates, and advisors.
When you request to match with a lender or credit card issuer for a Prequalified Loan Offer, SquareFairy will provide certain of your information to third party service providers.
When you report a complaint about a product or third party service provider featured on our site.
If you submit a request through our Services, a third party service provider may directly contact you with quotes or information via telephone, fax, and/or email. We do not share your information to third party companies without your request. If you have requested information or services from a third party company, you may also receive telemarketing calls as a result of submitting the request, even if you are on the National Do No Call Registry or any other similar registry.
When you choose to share your own information to a publicly accessible area of the Site, such as a public profile page or any section where you can publicly submit questions to us or our third party partners, that information will be available to anyone who is able to access that content, including other Site users. Additionally, questions you submit and answers provided by third parties may be posted on our Site and viewable by other users and the public.
We work with third party service providers to provide website, application development, hosting, data storage, maintenance, and other services for us. To the extent it is necessary for these third party service providers to complete their contractual obligations to us, these third parties may have access to or process your information.
We make certain information available to third parties, to: (i) comply with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services. When possible, we provide this information in a de-identified way.
We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
We reserve the right to disclose your information when we have a good faith belief that doing so is appropriate or necessary to take precautions against liability; to protect SquareFairy from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Services; or to protect the rights, property, or personal safety of SquareFairy, our users, or others.
How can you Manage Your Privacy
a) Managing Marketing Communications From Us. We will honor your choices when it comes to receiving marketing communications from us.
You have the following choices if you have been receiving marketing communications from us that you no longer wish to receive:
Click the "unsubscribe" link in the email or newsletter you received.
Visit the Marketing Preferences Center.
Adjust your preferences in your SquareFairy account settings.
For SMS messages, reply "STOP" or follow the instructions in the message or settings to discontinue the Service.
Subject to your control, our mobile applications may send push notifications to your mobile device. If you are receiving push notifications and no longer wish to receive these types of communications, you may turn them off at the device level.
Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.
b) Updating Your Personal Information. In connection with your right to manage your Personal Information you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the "How to Contact Us" section of this statement.
c) Cookies and Similar Tracking Technologies. The following is a high-level summary of our practices and your controls for cookies and other tracking technologies.
In accordance with applicable law, SquareFairy and our service providers may use commonly-used tools to recognize your visit and track your interactions with our Services such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, "Cookies"). Sometimes this tracking is necessary in order for us to provide you the Service you requested. Other times, we combine Usage Data collected from Cookies with that of other customers to improve your and other customers' experience. You have control over some of the Usage Data we collect from Cookies and how we use it. Information on changing your browser settings to opt out of Cookies can be found in your browser settings.
In accordance with the Digital Advertising Alliance Principles, SquareFairy also uses advertising networks and other third parties to display advertising on our website or to manage our advertising on other sites. Our third party partners may place Cookies on our Services and unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests, and to determine the effectiveness of such advertisements. If you wish to opt out of interest-based advertising, click here, or if located in the European Union, click here.
You also have the following additional choices to opt-out of certain tracking through Cookies for such purposes:
Visit the Digital Advertising Alliance's or Network Advertising Initiative's opt-out page.
Clicking here to opt out of targeted ads on Facebook.
To manage Flash cookies, please click here.
For mobile apps, please refer to your mobile device's settings, or download the AppChoices app.
Please note that even if you opt-out of such Cookies or otherwise opt-out of interest based advertising, you may still receive advertisements, they just won't be tailored to your interests. Also, if you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.
d) Do Not Track. Like most other companies, our Services are not currently configured to respond to browsers' "Do Not Track" signals because at this time no formal "Do Not Track" standard has been adopted. Click here for more information on "Do Not Track."
e) Social Media Features. Many of our Services may use social media features, such as Facebook sharing ("Social Media Features"). These features may collect your IP address and which page you are visiting within our Service, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing the relevant Social Media Features.
DATA RETENTION AND YOUR ACCESS RIGHTS
a) Data Retention. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and SquareFairy's records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.
b) Your Access Rights. If you have created an online account with us and would like to update the Personal Information you have provided to us, you can access your account to view and make changes or corrections to your Personal Information.
If you wish to request access, to limit use, or to limit disclosure, please contact us at firstname.lastname@example.org or the mailing address provided under "How to Contact Us" and please provide the name of the SquareFairy customer who submitted your Personal Information to our services. We will refer your requests to that customer, and will support them as needed in responding to your request.
SECURITY OF YOUR INFORMATION. Keeping your Information safe is important to us. We provide reasonable and appropriate security measures in connection with securing Personal Information we collect.
For example, we:
Constantly work to update our security practices to implement accepted best methods to protect your Personal Information, and review our security procedures carefully.
Comply with applicable laws and security standards.
Securely transmit your sensitive Personal Information.
Train our staff and require them to safeguard your data.
Our Commitment to Children’s Privacy
Protecting the privacy of young children is especially important. For that reason, we do not allow children under 13 years of age to use the Services, we do not knowingly collect or maintain information from persons under 13 years of age, and no part of the Services are directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access the Services at any time or in any manner. If we learn that information has been collected through the Services from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained a SquareFairy account or provided us with information, please alert us at email@example.com to request that we delete the information from our systems.
Our Service is hosted in the United States and is intended solely for visitors located within the United States. The information we provide and the third-party products and services featured are tailored for the United States market only. You agree that if you choose to use the Services from outside the United States, you will be transferring your information outside of those regions to the United States for storage and processing.
YOUR CALIFORNIA PRIVACY RIGHTS
We do not share your Personal Information with third parties for their marketing purposes without your consent.
In the Event of Merger or Sale
SquareFairy reserves the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Our Contact Information