Debbie Privacy Policy

Last updated: 07/05/24

OUR COMMITMENT TO PRIVACY
‍Debbie, Inc. (“Debbie”) knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy easy to find, we make it available from the home page of the Debbie website at www.joindebbie.com (the "Site") and through our mobile applications. You may also email us at hello@joindebbie.com with any privacy-related questions you have.

‍SUMMARY
‍While we hope you read this entire Privacy Policy, here is a brief overview of some important points:
‍• We do not sell your data.
‍• We offer a free product and hope you’ll open an account with a Debbie financial institution partner, who will then pay us for your engagement in the Debbie platform.
‍• We have stringent security mechanisms in place to protect your data and maintain your privacy.
‍• We use a small number of trusted third parties to help provide our products. You can exercise your region-specific rights (like GDPR and CCPA rights).

‍APPLICABILITY OF PRIVACY POLICY
‍This privacy policy applies to all information we collect through our web and mobile applications (the “App”) from current and former Debbie users, including you. When you are no longer our customer, we may continue to share your information as described in this policy.Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user. By using the service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the products or services.

‍PERSONAL DATA WE COLLECT
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Personal Data You Provide:
We collect personal information when you create an account, link your third-party account(s) to the service, or connect your credit report. When you visit, use and interact with the service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the service (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern.The personal information collected during these interactions may vary based on what you choose to share with us, but it will generally include:
-Account information: name, email address, phone number, mailing address, date of birth. We may ask for government-issued form of identification to verify your identity.
-Transaction and balance information: masked/last 4 digits of your bank account number, transaction and balance history, transaction log going forwardCredit report: your credit score and tradelines. We do not currently ask for social security, but may in the future.
-Log data and device information: internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, and operating system and platform, cookies, and device information
-Support data: data you share with us when you interact with our support teamUser content: any information you share while completing our educational modules
-Engagement and interaction: we collect information about how you use our service and social media, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

Third Party Credentials, Account Numbers and Other Account Information
When you use certain services, our 3rd party API providers (such as Plaid) may collect from you your usernames, passwords, and other account information in order to obtain your account, transaction, and other banking information from the relevant organization on your behalf, to display the information to you, or to fulfill your requests for certain products, services, or transactions through the service.

We also collect account information from you when you open a Debbie Account and we may share that information with our banking partner(s) and third-party providers in order to offer the services to you.

By using our services, you grant Debbie and each Third-Party Site the right, power, and authority to act on your behalf to access and transmit your information in order to provide the services. In addition, you agree that to the extent that your information is in the possession of a Third-Party Site, such information is subject to the privacy policy of that Third-Party Site.

‍LINKS TO OTHER WEBSITES
‍The Service may contain links to other websites not operated or controlled by Debbie, including social media services.  The information that you share with those third parties will be governed by the specific privacy policies and terms of service of the third party sites, respectively and not by this Privacy Policy. By providing such links we do not imply that we endorse or have reviewed the third-party sites. Please contact such third-party sites directly for information on their privacy practices and policies.
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Cookies
We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
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Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Online Tracking and Do Not Track Signals
We and our third-party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Your Choices
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
‍Internet Explorer
‍Mozilla Firefox
‍Google Chrome
‍Apple Safari‍‍
‍Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.Advertising networks may collect personal information through the use of cookies. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

‍HOW WE USE PERSONAL DATA
‍We may use personal information for the following purposes:
‍• To help you access and use the service;
‍• To respond to your inquiries, comments, feedback or questions;
‍• To send administrative information to you, for example, information regarding the service, and changes to our terms, conditions, and policies;
‍• To analyze how you interact with our service;
‍• To maintain and improve the content and functionality of the service (please see the “Cookies” section above to learn how we use cookies);
‍• To develop new products and services;
‍• To market our services or the services of our affiliates or business partners to you;
‍• To prevent fraud, criminal activity, or misuses of our service, and to ensure the security of our IT systems, architecture and networks; and
‍• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

Aggregated Information
We may aggregate personal information and use the aggregated information to analyze the effectiveness of our service, to improve and add features to our service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through features of the software that supports our service, through cookies, and through other means described in this Privacy Policy.

Marketing
We may contact you to tell you about services we believe will be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, please contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and services and to respond to your requests.

‍SHARING AND DISCLOSURE OF PERSONAL DATA
‍In certain circumstances we may share your personal information with third parties without further notice to you, unless required by the law, as set forth below:
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‍• Sponsor Partners: If a financial institution partner offers Debbie as a benefit to their members, Debbie may share engagement and impact data back with the financial institution you have an existing relationship with. We do this in an effort to track the financial impact of our program on our users.
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‍• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, financial service providers (including payment card processors, banks, and API services), customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the Security standards we apply to your personal information.

‍• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the services, or the public, or (v) protect against legal liability.

‍• Other users: Your personal information may be accessible to other users of the service with whom you interact. For example, where you share a sub-account with other users (such as if you create a sub-account to share expenses related to a family vacation), the other users with access to the sub-account will have access to the transactions you authorize within that sub-account.

‍• Affiliates: We may share personal information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Debbie. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

‍DATA RETENTION
‍We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

‍UPDATE YOUR INFORMATION
‍Please log in to your account or contact us if you need to change or correct your personal information.

‍CHILDREN
‍Our service is not directed to children who are under the age of 13. Debbie does not knowingly collect personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to Debbie through the service please contact us and we will endeavor to delete that information from our databases.

‍SECURITY
‍You use the service at your own risk. We implement reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the service or e-mail. Please keep this in mind when disclosing any personal information to Debbie via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the service, or third party websites.

‍YOUR CHOICES
‍In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our services, you may be unable to use those features. You may have rights under privacy laws to submit requests to us to access, correct, update, stop using for certain purposes, delete, or move your personal data out of Debbie. If you would like to submit a request to exercise your rights, please follow these instructions: 
‍• Request a personal data report. You can submit an access request for your data by using your account settings;
‍• Correct or update your data. You can update your name, email address, and language preferences by contacting helpme@joindebbie.com.
‍• Stop us from using your personal data for marketing emails. You can ask us to stop using your personal data for marketing emails by clicking “unsubscribe” on the emails you receive or via your account settings; 
‍• Delete your data. You can remove your personal data from Debbie by requesting a deletion of your account at helpme@joindebbie.comTo exercise any other rights you may have under privacy laws, please contact us using the contact information further below and describe your request. We may ask for additional information from you to clarify your request and verify that you are authorized to make this request. We will respond to requests to exercise privacy rights according to applicable laws.

‍CHANGES TO THE PRIVACY POLICY
‍The service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our service or providing us with personal information after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

‍CALIFORNIA PRIVACY RIGHTS
‍As a California resident, you have the following rights under the CCPA:
•The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You may only exercise your right to know twice within a 12-month period. 
•The right to delete personal information that we have collected from you, subject to certain exceptions.
•The right to correct inaccurate personal information that we maintain about you.
•The right to opt out of the sale or sharing of your personal information by us. 
•The right to limit our use and disclosure of sensitive personal information to purposes specified at Section 7027(m) of the CCPA Regulations. We do not use or disclose sensitive personal information for purposes other than those specified at Section 7027(m) of the CCPA Regulations.
•The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125.

‍CONTACT US
‍If you have any questions about our Privacy Policy or information practices, please feel free to contact us at hello@joindebbie.com.