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DEALING WITH DEBT operates a website, a mobile application and related platform features available through its website (“Website”) or its mobile application (“App”). We may refer to Dealing With Debt as “we,” “us,” or “our.” We may refer to you as “you” or “your.” The purpose of this policy is to inform you about the personal information we collect, how we use and share that information, and the ways in which you can control how we use and share that information. By using our Website or our App, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your personal information in accordance with this policy.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Account means a unique account created for you to access our Website or App.
Account Information refers to your name, email address, mailing address, date of birth, location and phone number or similar information associated with your Account.
App refers to the Dealing With Debt mobile application.
CCPA, The California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100–1798.199.
Company (referred to as either “the Company,” “we,” “us” or “our” in this Policy) refers to Dealing With Debt Inc. Email: office@us.dealingwithdebt.org. For the purpose of the GDPR, the Company is the Data Controller and Data Processor.
Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on your computer, mobile Device or any other Device by a website, containing the details of your browsing history on that website among its many uses.
Country refers to the United States of America.
Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Data Processor, for the purposes of the GDPR refers to the Company as the legal person which processes Personal Data.
Device means any device that can access the Website or App such as a computer, a cellphone, or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by United States regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
GDPR refers to the General Data Protection Regulation, (EU) 2016/679. (Relatedly, U.K. GDPR refers to the United Kingdom’s privacy rules which adopted the privacy compliance requirements of GDPR.)
Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
Personal Information is, for the purpose of the CCPA, information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer.
Privacy Policy or Policy means this policy.
Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website or App, to provide the Website or App on behalf of the Company, to perform services related to the Website or App or to assist the Company in analyzing how the Website or App is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Website or the App or from the Website or the App infrastructure itself (for example, the duration of a page visit).
User Registration Data means data collected at the time of registration on the Website or App, including your email address, name, date of birth, phone number and location as well as username and password for your profile and your Account.
Website refers to Dealing With Debt, accessible at https://us.dealingwithdebt.org/.
We may receive or collect Personal Data or Personal Information from you when you utilize the Website and App or when you voluntarily provide Personal Data or Personal Information to us. This may include the following:
We collect and maintain Account Information. When you register or sign up on the Website or App for certain features, newsletters and/or special offers, you may provide us, and we may collect, your User Registration Data.
You may elect to provide a variety of information during your interactions with us and the Website and App, such as emails you may send us, ads you respond to, comments, posts, or interactions that you may make through your Account, SMS or text messages that you may sign up for through the Website or App, and emails or newsletters that you sign up to receive from us. We, or third parties acting on our behalf, receive data from you whenever you provide us with this information.
When you access and use the Website or App from a computer, mobile phone, tablet, or other Device, we may use information about those Devices, including your browser type and Internet Protocol (IP) address. If you access the Website from a mobile phone, tablet, automobile, or other Device, we may collect and store information such as Device type, operating system version and type, wireless carrier, performance metrics of our Website or App, and other related information.
When you register for the Website or App, we may collect location information, derived from your IP address, from Devices or web browsers you use while accessing the Website or App.
We may collect data on the pages of our Website or App you visit, the time and date of your visit, and time, frequency, and duration spent on those pages, as well as the particular features you use.
Dealing With Debt may collect Personal Data or Personal Information through the use of cookies or other tracking technologies. For complete information about our cookie policy, see Section E of this Privacy Policy.
Our Website and App store content you post until you delete it. Additionally, Dealing With Debt may store backup copies of content that you post through our Website and App for archival and data redundancy purposes.
We may collect certain information through the use of log files and servers. These servers create log files as part of the process of setup and configuration. Information in a log file may include IP address (and associated geographic information), browser type, Internet service provider, date/time stamps, and other usage or statistical information.
We may receive or collect information about you from third parties or others when we use an outside service provider to display ads on the Website or App. Where these ads contain cookies that store your Personal Data or Personal Information, your Personal Data or Personal Information may be collected and stored on our servers with other information we may have already received or collected from you. This Personal Data and Personal Information is used to serve relevant ads to you and is based on items that may be considered Personal Data or Personal Information under the law, such as your IP address, browser type, time and date, and subject of advertisements clicked or interacted with, but that may be anonymized or non-personally identifiable information.
These third parties may provide us with certain information about their customers for the purposes of serving advertisements and/or marketing offers to their customers on the Website or through the App. We are not responsible for, and will assume no liability, if a business partner or other entity collects, uses, or shares any information about you in violation of its own privacy policy or any applicable laws, rules, or agreements. You are directed to review the privacy policies of any third parties that advertise on or through the Website or App.
We may use your User Registration Data, Account Information, Personal Data, and Personal Information, as well as data which we derive or infer from combinations of the foregoing, for a variety of purposes and situations, such as:
We do not sell or give your Personal Data or Personal Information to companies, or any other organization, for their own marketing purposes without your permission. We do use Personal Data and Personal Information, however, to contact you, provide you with technical support, send you notices about the Website and App or other promotional offers you have elected to receive, and to serve you with ads that are more relevant to your interests. If you provided your Personal Data or Personal Information as part of your use of the Website, the App or your Account, we may use your Personal Data or Personal Information to update you on new features and products. You may contact us at any time to request that we cease using your Personal Data or Personal Information.
Dealing With Debt may collect Personal Data or Personal Information through the use of cookies or other tracking technologies. Cookies and other tracking technologies help Dealing With Debt understand how you use the Dealing With Debt Website and App and provide us with an understanding of how our users utilize our services. Dealing With Debt’s use of cookies aids in developing or improving our services in response to your needs and wants and to provide you with relevant offers from our advertisers, where applicable.
Dealing With Debt may use session or persistent cookies. Session cookies are only stored on your computer or mobile Device while you use the Dealing With Debt services and are automatically deleted when you close your web browser or cease using the App. If you are located in Canada, the United Kingdom, or the European Union, Dealing With Debt requests your consent before storing session cookies on your computer or mobile Device.
Persistent cookies can be read by the website or mobile applications that placed the cookie when you revisit the website or mobile application. Persistent cookies authenticate you as a user and track your behavior on the website or through the mobile application. Persistent cookies thereby allow a fast, consistent user experience tailored to your preferences. Dealing With Debt requests your consent to utilize persistent cookies when you register a user account with Dealing With Debt and agree to its Terms of Use Agreement and Privacy Policy.
If you object to Dealing With Debt’s use of cookies, you can clear your web browser cache and stop using the Website or App to remove session cookies. To remove persistent cookies, clear your web browser, delete your user account, and stop using the Website or App.
Dealing With Debt uses third-party session cookies provided by Cloudflare’s BotManagement technology to protect its website from harmful automated attacks. To understand how Cloudflare uses information collected from you through this session cookie, please review Cloudflare’s Cookie Policy at the following link: https://www.cloudflare.com/cookie-policy/.
We will retain your Personal Data and Personal Information only for as long as we determine is necessary to achieve the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Your Account Information will be retained by us while your Account and profile is active. We will retain and use this information for the purposes for which it was collected (as specified in this Policy or as we disclose to you outside of this Policy), including, to provide information and products to you, comply with our legal obligations, resolve disputes, and enforce our agreements.
Your Personal Data and Personal Information is processed at our offices and data centers or the offices and data centers of our third-party partners. This means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the applicable data protection laws may differ than those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your Personal Data and Personal Information, is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Data and Personal Information will take place to an organization or a country unless there are adequate access and security controls in place to maintain the same level of protection as is provided under this Privacy Policy.
We may share information that we collect with our subsidiaries, successors, or related companies for the purposes described in our respective privacy policies, and to offer, provide, and improve services and products offered both individually and jointly with these companies.
We may share information that we receive or collect, such as when you give us permission through an affirmative election (for example, clicking “yes” in response to a message or email inquiring as to whether to “share my email with this advertiser”). We may also share information if we partner with a third party to provide services on our behalf, such as credit card processors, customer support, advertising services, or bulk email processors who may send out emails on our behalf.
These companies are authorized to use your Personal Data and Personal Information only as necessary to provide these services to us. They are not authorized to use your Personal Data and Personal Information for their own, unrelated purposes.
We may also share your personal information in the good faith belief that such action is necessary to:
Additionally, we may share information we gather from Devices you use to access the Website or App with third-party vendors, manufacturers, service providers or advertising entities. We share this information for a variety of purposes, such as tracking advertising, estimating the number of users, security and fraud detection, debugging problems, and for providing you with more relevant advertisements on the Website and App.
If there is a transfer or sharing of your Personal Data or Personal Information in accordance with this Policy, we will seek assurances from the recipients of such information (prior to the transfer) that they will safeguard the information in a manner consistent with this Policy.
Dealing With Debt offers users the ability to send direct messages to their connections, allowing for more private, one-to-one communications. Dealing With Debt does not encrypt these direct messages. When you communicate with others by sending or receiving Dealing With Debt’s direct messages, we will save the messages along with certain information necessary for processing them for a specified or unspecified number of days, or as may be elected by the user. (The default setting is 365 days.)
In the event that a user reports a message for a violation of Dealing With Debt’s rules or any applicable law, Dealing With Debt typically will keep the reported message – and associated portions of the related conversation – for one year (365) days after reporting.
Remember that when you use Dealing With Debt’s Direct Messages to communicate, recipients retain their own copy. Recipients may duplicate, store, or re-send your messages. If you delete your copy of a message sent from your account, you will delete that message in your recipient’s account as well, but Dealing With Debt will retain the message for the time periods described above. Dealing With Debt does not use information collected from direct messages for advertising purposes.
You will have the ability to access and modify your Account Information on your Account, which you may do through the settings section of our Website or App at any time. You have control through settings on your Account and on your profile to limit data we collect from you and how we use it. You can also download the information you have shared with the Website and App.
Your Account Information will be retained by us while your Account and profile is active. We will retain and use this information for the purposes for which it was collected (as specified in this Policy or as we disclose to you outside of this Policy), including, to provide information and products to you, comply with our legal obligations, resolve disputes, and enforce our agreements.
Upon your registration of an Account on the Website or App, you may elect to receive promotional, marketing, or other similar emails tailored to your interests. You may change this election at any time. Additionally, you may also unsubscribe from any promotional, marketing, or other similar emails you receive. We will send you confirmation emails and other Website-related or App-related announcements when it is necessary to do so.
When necessary, we have implemented security measures designed to protect against the loss, misuse, and alteration of the information we collect or receive from you. Nevertheless, no security measures are impenetrable and there are always security risks.
We will use the information we collect in ways that are relevant and compatible with the purpose for which that information was collected or provided to us as disclosed in this Policy. We will use safeguards to ensure that all information collected, processed, and/or stored is protected from loss, destruction, or use in a manner inconsistent with our policies or the purpose for which we received it.
Our Website and App, as well as advertisements on our Website and App, may include links to other websites whose privacy practices may differ from ours. If you submit Personal Information and Personal Data to any of those websites, the privacy statements and practices of those websites govern their use of your information. Please be sure to review the privacy statement of any website you visit.
Other third parties or advertisers may utilize framing techniques to serve content to and from webpages accessible through our Website and App while preserving the look and feel of our website. Please note that you may be providing your Personal Information and Personal Data to this third-party (and not to us) in this situation.
This Privacy Policy addresses the concerns set forth by the GDPR, including what and how we collect your data, how we use and store your data, marketing, data protection rights, cookies and how we use them, relevant privacy policies of other websites, how we change our Privacy Policy, and how to contact us and appropriate privacy authorities. For information about these topics, please consult the relevant sections of this Policy.
Legal Basis for Processing Personal Data under GDPR. We may process Personal Data under the following conditions:
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
These rules apply solely to all visitors, users, and others who are residents of the State of California (“California residents”). We adopt these rules to comply with the California Consumer Privacy Act (“CCPA”) and any terms defined in the CCPA have the same meaning when used here. Where noted, the CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.
California residents have the right to request that we disclose what Personal Information we collect, use, disclose, and sell (if applicable). Our uses of Personal Information and instructions for submitting a verifiable Consumer request for such disclosures are detailed further below.
In particular, we collected the following categories (A, B, and F), as defined in the CCPA, of Personal Information from our Consumers within the last twelve (12) months:
We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose Consumers’ Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We may share Consumers’ Personal Information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:
In the preceding twelve (12) months, we have not sold Personal Information.
We do not knowingly collect Personal Information from minors under the age of 16 through our Website or App, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children’s internet usage and instruct their children to never provide information on other websites without their permission.
At this time, we do not sell the Personal Information of Consumers, including Consumers we actually know are less than 16 years of age.
If a Consumer has reason to believe that a minor under the age of 16 has provided us with Personal Information, please contact us with sufficient detail to enable us to delete that information.
The CCPA provides Consumers (California residents) with specific rights regarding their Personal Information. This section describes Consumers’ CCPA rights and explains how to exercise those rights.
We do not provide these access and data portability rights for business-to-business personal information until the exemption expires.
Only a Consumer, or a person registered with the California Secretary of State that a Consumer authorizes to act on his or her behalf, may make a verifiable request related to a Consumer’s Personal Information. A Consumer’s request to us must:
We will disclose and deliver the required information free of charge within 45 days of receiving a Consumer’s verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. For data portability requests, we will select a format to provide Consumer Personal Information that is readily useable and should allow a Consumer to transmit the information from one entity to another entity without hindrance
We do not knowingly collect any information from anyone under the age of 18 without explicit parental approval as specified by the applicable privacy law. As a general matter, prospective users must enter a birthdate reflecting an age of 18 or greater when signing up for the Website or App. For more information about our policy towards minors using the Website or App, please see our Terms of Service. If you are a parent or guardian and you are aware that you child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a minor without verification of parental consent, we take appropriate steps to remove that information from our servers.
Please see below for additional provisions, as required under the consumer privacy law of your state.
Your rights under Cal. Civ. Code § 1798.83 (Shine the Light law): We only share Personal Information (as defined) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide Personal Information or when you choose to participate in a feature on the Website or on the App. If you do not opt-in or if you opt-out at that time, we will not share your Personal Information with that identified third party for direct marketing purposes.
Your rights under Cal. Bus. & Prof. Code § 22575(b) (“Do Not Track” Browser Settings): You are entitled to know how we respond to “Do Not Track” browser settings. Like many other websites, we do not currently alter our practices when we receive Do Not Track signals as there is no consensus among industry participants as to what “Do Not Track” means in this context. However, you have the option to opt-out of interest-based advertising. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com/.
Your rights under California Privacy Rights for Minor Users (California Business and Professions Code Section 22581):California Business and Professions Code § 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us, and include the email address associated with your Account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you are a resident of Nevada, you may apply limits to the sale of certain Personal Information to third parties for resale or licensing purposes, subject to applicable law. We do not sell your Personal Information for such use. You are entitled to register your preference for limits on such sales in the future by sending an email to us with the subject line, “Nevada Do Not Sell Request” along with your first and last name, zip code, and whether you are a former or current Account holder or user. Your email address must match the email address on your Account to process this request.
Our Privacy Policy will be periodically reviewed and evaluated in connection with new products, new services, new technologies, changes in law, and your needs. We may make changes or modifications to our Privacy Policy as a result thereof. Our Privacy Policy will be updated from time to time. If we make any material changes to this Privacy Policy, we will post the updated terms of the Privacy Policy on the Website and the App. Notice of such changes may include notice by email through a message sent to the email address you use to access the Website and App or to register as a user on the Website and App or posting a message on the Website or App. You are responsible for updating your Account Information to provide us with your most current email address as the email notice constitutes effective notice of said changes.
From time to time, we may conduct compliance audits of our relevant privacy practices to verify adherence to this Privacy Policy and that said Privacy Policy is current and accurate. Any employee that we determine is in violation of this Privacy Policy may be subject to disciplinary action.
Any complaints or disputes as to collection or use of Personal Information or Personal Data under this Policy shall be completely investigated to seek a resolution or cooperate with dispute resolution procedures, if applicable to the dispute.
If you have any questions about this Privacy Policy, our privacy practices or how we collect or process your personal data, please contact us – Attn: User Support at office@us.dealingwithdebt.org