Business Partners and Your Rights
Nickels is solely a technology and tools provider to Business Partners. Your Business Partner has the ability to access your personal information stored in the Service, and further, has the contractual right to do so under the agreement between the Business Partner and Nickels. The collection, retention, processing and other uses of personal information by Business Partners, whether or not in connection with the Service, is governed by their own privacy policies and applicable laws, rules, or regulations. Nickels does not control those Business Partner activities.
Under the applicable laws in certain jurisdictions, you may have certain rights concerning your personal information, such as under EU or California law, the right to access to, rectification or erasure of, and/or restriction or objection to certain processing of your personal information, and the right to data portability. If you believe that a Business Partner has collected or processed your personal information (other than Log Data, as described below), and you have any questions or want to exercise any of your rights with respect to your personal information, you should contact them directly. If you have trouble reaching the relevant Business Partner directly, please contact Nickels at the email address below. Before we process any request, we may request personal information to verify your identity where allowed by law. Where permitted by local law, we may reject requests that are unreasonable or impractical.
The Information We Collect on Behalf of Business Partners
Generally speaking, we collect personal information necessary for you to establish an account and use the Service under the relevant Business Partner’s agreement with us, and associated information we use to administer and secure the Service on behalf of the Business Partner (e.g., logging access attempts under user login IDs). All such information is collected and processed on behalf of the relevant Business Partner.
We may collect and process the following personal information from you in order to provide the Service on behalf of the Business Partner:
- When you first create an Account to use our Services, we will collect your email address and password (or a sign-on confirmation token), either directly from you or from the Business Partner you work with. If you want us to send you text message reminders, we will need your phone number.
- If you want us to collect information on the status of your credit cards or loans through your credit card provider(s) or loan servicer(s) (“your creditor(s)”), you will have to connect us to that account by providing us with login information or your account number at your creditor. By connecting us to your creditor account you authorize us to retrieve from your creditor(s) when you connect us into that account. The information we may retrieve from your creditor(s) includes information such as when your next bill is due, what the bill amount due is, and what payments you have already made.
- We also collect personal information from you when you answer questions in our System that helps us to guide you on your credit cards and loans, and recommend new or additional credit cards or loans to you.
- In order to better support you, if you make an inquiry through our website, or contact us in any other way, we will keep a copy of your communications with us.
Nickels’ Day-to-Day Use and Disclosure of Information Identifying You
Simply put, we do not and will not sell or rent your personal information to anyone other than the relevant Business Partner, for any reason, at any time.
With respect to the login information for your creditor accounts, we will use that information only to retrieve your credit card and loan information to load into your Account.
Except in extraordinary cases, as we discuss below, Nickels uses and discloses your personal information in a form that identifies you only for these purposes:
- to provide the Service to you on behalf of the Business Partner, including running the Service and providing technical support to you, and making the Service more secure;
- to analyze the use of the Service so that we can improve it;
- to send you any emails, texts, or other communications relevant to your use of the Service, or as requested by the Business Partner, including sending reminders, customer surveys, or other communications you have requested that we send;
- unless you have opted out, to deliver communications about products and services that we or the Business Partner (or its partners) can offer to you;
- for research, planning, and troubleshooting problems;
- to Plaid in order to retrieve your creditor account information, as described above;
- to other third-party contractors that provide services (e.g. email notifications) to Nickels and are bound by these same privacy restrictions;
- to enforce Nickels’ Terms of Service;
- to the Business Partner for the purposes they have disclosed to you separately; and
Nickels’ Use of Aggregated Information That Doesn’t Identify You
Nickels may use and disclose anonymous or aggregate information, which does not identify you individually, to:
- Users of the Service for purposes of comparison to the broader community (for example, how much you owe in credit card debt or loans compared to an average credit card user or borrower);
- Organizations approved by Nickels for research about how to better support people with credit card debt, loans and similar issues; and
- To Business Partners.
How We Collect and Use Traffic and Log Data
Just like any website, Nickels may also collect certain technical information (collectively “Log Data”), that is naturally available when you use our Services. Log Data includes data like IP addresses, the kind of device uses to access the Services, browser type and operating system, referring URLs, and website usage patterns.
Log Data is primarily used to improve the design and functionality of the Service, and for security and similar purposes. We collect Log Data in a variety of ways
“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. Nickels or its third party providers may set and access cookies on your computer to track and store information about your preferences. Nickels may gather information about you through cookie technology. For example, Nickels or its third party providers may assign a cookie to you to limit the amount of times you see a particular notification, to keep you logged into the Service for a period of time or to allow continuity of communication if you leave the Service and return. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Service may be impaired for you.
Some of our Service’s pages may contain electronic images known as Web beacons, which are also called single-pixel gifs. These images allow us to count users who have visited those pages. We also may include Web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal Information but they are a technique we use to compile aggregated statistics. You may disable Web beacons in your emails by disabling HTML images in your email program, which may also affect other images in emails you receive.
Do Not Track
Disclosure to Protect Legal Rights or if Required by Law
Nickels reserves the right (and you authorize Nickels) to share or disclose your personal information when Nickels determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:
- To prevent prohibited or illegal activities or harm to another person;
- When required by any applicable law, rule regulation, subpoena or other legal process; or
Change of Control or Selling Our Business
Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control. If we sell, merge or transfer any part of our business, part of the sale may include your personal information.
Opting Out; Terminating Your Account; Information Retention and Deletion
You can opt out of most communications from us by so indicating in the relevant part of your Account profile, by clicking the opt-out link in emails, by emailing us at firstname.lastname@example.org or by other methods that we may provide which match the communication method (e.g., texting STOP in reply to a text message from us). As long as you have an Account with us, we will need to send you certain administrative communications, so you can’t opt out of receiving those communications.
To terminate your relationship with us and delete your Account for the Service, you can email us at email@example.com.
We will retain your personal information that we process in connection with the provision of the Service on behalf of a Business Partner for as long as needed to provide Service to that Business Partner or until they direct us to delete it. We will retain other personal information we collect independently only for as long as necessary in our business.
When you request us to delete your Account, your personal information will be permanently expunged from our primary production servers and further access to your Account will not be possible. However, portions of your data, consisting of aggregate data derived in part from your personal information, may remain on our production servers indefinitely. Your personal information may also remain on a backup server or media until we overwrite it or deleted according to our standard practices. Nickels keeps these backups to ensure our continued ability to provide the Service in the event of malfunction or damage to our primary production servers. We may also retain personal information as required of us or our partners by applicable law or regulations, or to comply with law enforcement, resolve disputes, and enforce our agreements.
Our Security Practices
We use a combination of authentication procedures, firewall barriers, and encryption techniques (for example, we always encrypt your personal information when it’s at rest in our servers, and we use “https” for secured web browsing), among others, to maintain the security of your online session and to protect Service accounts and systems from unauthorized access.
Your Login ID and Password
No Users Under 16
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at firstname.lastname@example.org.
Information for persons outside the US
If you use our Service from outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law.