White-Label Privacy Policy 

Author Date Last Revised: July 19, 2024

Overview

Nickels, Inc.  (“Nickels”, “we” or “us”) knows that your privacy and protecting your personal information is important to you.  It’s also important to us.  This Privacy Policy describes how we protect your personal information when you visit our website and use the credit card and loan monitoring, recommendation, and guidance service we provide (the “Service”) on behalf of the business partner with which you work (i.e. the entity that shared Nickels with you and whose logo is at the top of your screen while you’re logged into the Service (“Business Partner”).   

Business Partners and Your Rights

Nickels emphasizes that this Privacy Policy does not address the practices or policies of the Business Partner.  Each Business Partner uses the Service to collect and process personal information for the legitimate interest of providing credit card and loan monitoring, recommendations, and guidance to individuals who have accounts or loans with that Business Partner.  Certain Business Partners may also base their collection and processing of personal information on your consent.

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 may use Plaid Technologies, Inc. (“Plaid”) to verify and retrieve your creditor(s) account information. We only share your information with Plaid in accordance with this Privacy Policy. Information shared with Plaid is treated by Plaid in accordance with its privacy policy, available at https://plaid.com/legal/.
  • 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
  • as otherwise set forth in this Privacy Policy.

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.

Third Parties

We use third party service providers to help us analyze certain online activities, and the information we receive from such service provider is also Log Data. For example, these service providers may help us analyze visitor activity in the Service. We may permit these service providers to use cookies and other technologies to perform these services for Nickels. We do not share any personal information about our users with these third party service providers, and these service providers do not collect such information on our behalf.

These services include Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You may also download the Google Analytics opt-out browser add on, available here.

Do Not Track

We do not respond to the Do Not Track setting in your browser.  While we do not use cookies to collect personally identifiable information or track users’ online activities over time or across different web sites, certain of the third party tracking providers we use (e.g., Google) may be able to do so, though we do not have access to that information.  For information regarding Do Not Track mechanisms, see http://allaboutdnt.com.

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
  • To enforce our rights under this Privacy Policy or our Terms of Service

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 support@nickels.us 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 support@nickels.us.

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

You are responsible for maintaining the security of your Login ID and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at support@nickels.us and you should change your password immediately via the Service. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Policy or the Terms of Service.

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 support@nickels.us

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.

Updates

We update this Privacy & Security Policy periodically. The date last revised appears at the top of the Policy. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, a notice will be posted on the Service, a notification of the change will be posted in the Account login screen, and if we have your email address, we will attempt to reach you at that email address to inform you that the Privacy Policy has been changed. You are deemed to accept and agree to be bound by any changes to the Privacy Policy when you use the Service after those changes are posted.

Contact us

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send us an e-mail at support@nickels.us.