Last Updated: 10/23/18
At Cred, your trust is one of our most important assets. We continually work to protect the privacy of our users. Cred is committed to maintaining the confidentiality, integrity and security of personal information about our users. Cred stresses its privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.
Description of Users and Acceptance of Terms
The Information We Collect and/or Receive
In the course of operating the Platform, the Services and/or interacting with you, Cred will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.
When you sign up to become a Registered User, you will be required to provide us with certain information about yourself, such as your name, e-mail address, date of birth, mailing address and phone number. We may also request some additional information to verify your identity or to meet our regulatory obligations. All information we collect and/or receive under this section is collectively called “Contact Information.”
When Registered Users wish to make any Transaction, they must provide us with certain information about the Transaction they are seeking to execute. Such information is collectively called the “Transaction information.”
In addition to the Contact Information, and the Transaction Information, we may collect or receive additional information (collectively, the “Other Information”). Such Other Information may include:
From Your Activity. In an ongoing effort to improve the Platform and Services, we automatically collect certain information when Visitors visit the Site and when Registered Users use the Platform and/or Services. Such information includes, without limitation:
IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Site Visitors visit; and similar data.
Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data; and
From Cookies. We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Platform and Services. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Platform and Services may not function properly.
For more information on such third party analytics service providers, including how to opt out from certain data collection, please visit the following links:
For Google Analytics, please visit: https://www.google.com/analytics
For Adjust, please visit: https://www.adjust.com/
Information Collected by or Through Third-Party Advertising Companies
Information Collected and/or Received from Third Party Sources
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. We may combine this information with the information collected and/or received from you.
How We Use and Share the Information
You authorize us to use the Contact Information, the Transaction Information, and the Other Information (collectively, the “Information”) to provide and improve our Platform and Services; to process Transactions; to fulfill Know Your Customer and Anti-Money Laundering requirements as set forth by official industry regulators; to analyze Platform usage; to deliver to you any administrative notices, money alerts, and communications relevant to your use of the Services; to fulfill your requests for certain products and services; for market research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity; to administer our promotional programs; to solicit your feedback; to inform you about our products and services and those of our promotional partners.
You also authorize us to use and/or share Information as described below.
We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, order fulfillment, customer service, marketing assistance, and administration of our rewards and promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
In an ongoing effort to better understand our Visitors, Registered Users, Platform, and our Services, we may analyze your information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Platform and/or Services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Platform and Services to current and prospective business partners and investors and to other third parties for other lawful purposes.
In order to provide our Services and administer our promotional programs, we may share your Information with our third-party promotional partners, for the limited purpose of allowing such partners the make the promotion available and track participation within such promotion.
In the event that you access the Services as brought to you by one of our co-brand partners, through a co-branded URL, your email address or phone number may be used for registration on the Services and may be provided to that co-brand partner.
We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Cred or others.
Accessing and Modifying Information and Communication Preferences
You have the right to ascertain whether we hold your accurate and current personal information, to obtain a copy of the personal information that you submitted as permitted by law, and to correct any of your data that is inaccurate. You may also request that we inform you of the type of personal information we hold with regard to you, subject to restrictions on our providing copies of certain data pursuant to our obligations under the Bank Secrecy Act (“BSA”) and Anti-Money Laundering (“AML”) regulations and/or data provided to our legal counsel in defense of a claim against us. You may also request that we delete your personal information, subject to restrictions under applicable laws and regulations, such as those related to the BSA and AML. For data access, correction, or deletion requests, please contact email@example.com.
When handling a data access, correction, or deletion request, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.
In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Cred marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
Accuracy and Retention of Personal Information
We take reasonable and practicable steps to ensure that your personal information held by us (i) is accurate with regard to the purposes for which it is to be used, and (ii) is not kept longer than is necessary for the fulfillment of the purpose for which it is to be used, which is when your business relationship with us ends, unless the further retention of your personal information is otherwise permitted or required by applicable laws and regulations.
The security of your information is important to us. We take commercially reasonable steps to protect the information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. Please understand, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the security of our databases, nor can we guarantee that the information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. If you have any questions about security on the Site or in the App, please contact us.
Important Notices to Non-U.S. Residents
The Platform and its servers are operated in the United States and elsewhere. Please be aware that your information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Platform, you do so at your own risk.
Shuttle Finance, Inc.
1447 2nd Street, Suite 200
Santa Monica, CA 90401
In addition, Cred does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
Shuttle Finance, Inc.
1447 2nd Street, Suite 200
Santa Monica, CA 90401
Copyright 2018 Shuttle Finance, Inc. All rights reserved