Effective date: May 29, 2015

 

  1. OUR COMMITMENT TO YOUR PRIVACY

Cashpath Financial LLC (“Cashpath,” “we,” “us” or “our”) is committed to ensuring the confidentiality, security and protection of your Personal Data (as defined below) that we and our representatives collect in connection with the operation of our Service (as defined below). This Privacy Policy (or “Policy”) explains how we and some of the companies we work with collect, use, share and protect Personal Data and other information that are collected, used, shared and protected by us in connection with the operation of our services through the numys application, our web site, and any software provided on or in connection with Cashpath services (collectively, the “Service”), and your choices about the collection and use of your Personal Data and information.

 

Our Policy applies to all visitors, users, and others who access the Service (“Users”).

 

  1. THE INFORMATION WE COLLECT

In order to provide our Service, we collect the following types of information.

 

Information you provide us directly:

  • Your username, password and e-mail address when you register for an account
  • Your credentials to certain of your financial accounts so that we may access your transaction data and provide our services
  • User Content (e.g., comments, and other materials) that you post to the Service.
  • Communications between you and Cashpath. For example, if you contact Cashpath with questions about your account or the Service, we will collect the information that you provide to us in that communication. .

 

Information we receive from Transaction Aggregators:

To provide our Service, Cashpath integrates with software systems of certain transactions aggregators (“Aggregators”) including Yodlee Inc. and Plaid Technologies.  Please review the privacy polices of these aggregators for further information about the policies of the Aggregators. The privacy policy of Yodlee is available at: http://www.yodlee.com/privacy-policy/. The privacy policy of Plaid Technologies is available at: https://www.plaid.com/legal/#privacy-policy.

 

Analytics information:

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

 

Cookies and similar technologies:

  • When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use Cashpath and provide features to you.

 

  • We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

 

Log file information:

  • Log file information is automatically reported by your browser each time you make a request to access (i.e. visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

 

  • When you use our Service, our servers may automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

 

Device identifiers:

  • When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Cashpath.

 

  • A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

 

Metadata:

  • Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

 

  • Users can add or may have Metadata added to their User Content.

 

Physical Location:

If you use a mobile device, if you have your location setting turned on for our Service, we will collect location information.  Location information enables our mobile application to establish the approximate location of your mobile device.  Cashpath and/or its authorized service providers may use and store this information, in combination with other location-based information (such as IP address), to provide requested location services and to deliver enhanced location based services and other content, including push notifications.  You may withdraw your consent at any time to the collection of your location information and/or to receive push notifications (see “Opt-Out Procedures” below).

 

Telephone Number:

Through our Application, we may also provide you with an opportunity to opt in to receive special offers and other text messages on your wireless telephone by giving us your wireless telephone number.

 

  1. PROTECTING YOUR PERSONAL DATA

To prevent unauthorized access, maintain data accuracy, and ensure correct use of Personal Data, we will employ reasonable and current Internet security methods and technologies. To protect transaction data while in transit, Cashpath currently uses Secure Socket Layer technology to encrypt Personal Data.

  1. HOW WE USE YOUR INFORMATION

In addition to the specific uses of information described in other sections of this Privacy Policy, we may use information that we receive in connection with the operation of the Service to:

  • help you efficiently access your Personal Data after you sign in
  • remember Personal Data so you will not have to re-enter it during your visit or the next time you visit the Service;
  • fulfill your requests for certain products and services;
  • facilitate market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
  • provide personalized content and information to you and others, which could include online ads or other forms of marketing
  • provide, improve, test, and monitor the effectiveness of our Service
  • develop and test new products and features
  • monitor metrics such as total number of visitors, traffic, and demographic patterns
  • diagnose or fix technology problems
  • automatically update Cashpath applications on your device.

 

  1. SHARING OF YOUR INFORMATION

We will not rent or sell your Personal Data to third parties outside Cashpath (or the group of companies of which Cashpath is a part) without your consent, except as noted in this Policy.

 

Certain areas and features of our Service are available to you without registration or the need to provide to us any information. However, other features of the Service may require registration, which involves provision to Cashpath of an email address, and a password. In order to benefit from the full functionality of the Service, you also must provide your third-party account credentials (“Account Credentials”) to allow Cashpath to access your account data at your financial institutions (“Account Information”) for your use. Access to your registration information, Account Credentials, Account Information and any other Personal Data you provide is strictly restricted and used in accordance with specific internal procedures and safeguards governing access, in order to operate, develop or improve the Service.

 

If your registration information changes during your subscription to numys, you may update it any time via the Service.

 

Parties with whom we may share your Personal Data and other information:

  • We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Cashpath is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).

 

  • We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

 

  • We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

 

  • We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information with various third parties.

 

  • If you use a bulletin board, blog, chat room, support center, or other online forum on our Service, you should be aware that any information you submit there can be read, collected or used by other users and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to submit in these forums. These forums may be hosted by Cashpath or by one of our third party service providers on Cashpath’s behalf.

 

  • The Application may use third party authorized service providers to provide us with analytical data about your use of the Application. Third parties that we engage to provide analytics services and to assist in providing the Application’s tools and services cannot use your personal information for their own purposes, unrelated to the Application, without your explicit consent

 

Parties with whom you may choose to share your User Content:

  • Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. Once you have shared User Content or made it public, that User Content may be re-shared by others.

 

  • Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users and subject to use under our Cashpath API. The use of the Cashpath API is subject to the API Terms of Use which incorporates the terms of this Privacy Policy.

 

  • If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the Cashpath API have copied or saved that information.

 

What happens in the event of a change of control:

If we sell or otherwise transfer part or the whole of Cashpath or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your Personal Data such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred but we will require the buyer or transferee will have to honor the commitments we have made in this Privacy Policy unless you subsequently agree to be bound by a different privacy policy presented by such buyer or transferee.

 

Responding to legal requests and preventing harm:

We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests in the United States and from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

 

  1. HOW WE STORE YOUR INFORMATION

Storage and Processing:

  • Your Personal Data and information collected through the Service may be stored and processed in the United States or any other country in which Cashpath, its Affiliates or Service Providers maintain facilities and/or services.

 

  • Cashpath, its Affiliates, or Service Providers may transfer information that we collect about you, (including Personal Data) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data protection and privacy and use that may differ from U.S. law, please note that we may transfer information, including Personal Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

 

  • By registering for and using the Service you consent to the transfer of your Personal Data and other information to the U.S. or to any other country in which Cashpath, its Affiliates or Service Providers maintain facilities and/or servers and the use and disclosure of information about you as described in this Privacy Policy.

 

  • We use commercially reasonable safeguards to help keep the Personal Data and other information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Cashpath cannot ensure the security of any information you transmit to Cashpath or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

 

  • Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Cashpath, at all times. Your privacy settings may also be affected by changes the social media services you connect to Cashpath make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

 

  1. YOUR CHOICES ABOUT YOUR INFORMATION

Your account information and profile/privacy settings:

  • Update your account at any time by emailing support@numys.com
  • Unsubscribe from email communications from us by clicking on the “unsubscribe link” provided in such communications. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

 

How long we keep your User Content:

  • Following termination or deactivation of your account, Cashpath, its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, legal and/or regulatory compliance, archival, and/or audit purposes.

 

Opt-Out Procedures for the Service:

  • You can stop all collection of information by the Application by uninstalling our mobile application from your mobile device.  You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

 

  • You can also withdraw your consent to receive “push” notifications and/or to the collection of your physical location information at any time by disabling or changing the related functionality or setting as provided in your mobile device.

 

  • You can also opt-out of receiving future text messages at any time by emailing support@numys.com

 

  1. CHILDREN’S PRIVACY

The Service is not intended for or directed at children. Cashpath does not knowingly collect or solicit any Personal Data from anyone under the age of 13 nor do we knowingly allow such persons to register for the Service. In the event that we learn that we have collected Personal Data from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

 

  1. OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from our Service (each, a “Third Party Service”), including the information or content contained within them. Please remember that when you use a link to go from our Service to a Third Party Service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content you do so at your own risk.

 

  1. HOW TO CONTACT US ABOUT A DECEASED USER

In the event of the death of a Cashpath User, please contact us at support@numys.com. We will usually conduct our communication via email; should we require any other information, we will contact you at the email address you have provided in your request.

 

  1. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please email support@numys.com

 

  1. CHANGES TO OUR PRIVACY POLICY

Cashpath may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of numys or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.