Privacy Policy

Last updated: June 24, 2024

Overview

This Privacy Policy describes how and why Kredit (“we,” “us,” or “our”) might collect, store, use, and/or share (“process”) your information when you use Kredit’s services or visit our website. Definitions of terms used in this policy are the same as are found in our Terms of Service. If at any time you have questions about this policy please contact us at compliance@trykredit.com. If you do not agree with our policy or practices, please discontinue use of our services.

Kredit provides a platform designed to facilitate communications between consumers and financial institutions in their personal financial network and empower consumers to make personal financial decisions (collectively, including the Site and any mobile applications and related products and services, the “Service”). Kredit follows this Privacy Policy according to the applicable law in the places in which we operate. We also work collaboratively with other internet and computer and mobile applications which frequently have their own privacy statements and policies and we encourage you to review them. Please know that our site and applications may contain links to other sites we do not own or control but that you may find useful. Kredit is not responsible for the privacy practices of those sites.

Our Service is not intended for children or anyone under the age of 18. Kredit does not knowingly collect personal information from anyone under the age of 18. If you have reason to believe that a child or anyone under the age of 18 has provided personal information to us through the service please contact us at compliance@trykredit.com and we will endeavor to delete that information from our databases.

We do not, and without your consent will not sell, lease, or rent your information to third parties for monetary or other valuable consideration.

1. What information do we collect?

We collect information that you voluntarily provide to us when you register for our services, express an interest in obtaining information about us or our services, when you actively participate in the use of those services within the Kredit platform, or otherwise access Kredit’s platform. A chart of the specific categories of personal information we collect is found at the bottom of this policy.

Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Generally, this information establishes your account, method/means of identifying institutions in your personal financial network, and potentially also your methods and means of payment, services and other data related to our relationship with you. This information may also be required by applicable laws to verify your identity before you can use certain services. The personal information we collect from you may include the following:

  • Names
  • Phone numbers
  • Email addresses
  • Physical addresses
  • Date of birth
  • Gender
  • Usernames that you create
  • Passwords that you create
  • Contact preferences
  • Contact or authentication data

Sensitive Information

When necessary, with your consent or as otherwise permitted through other means and applicable law, we process the following categories of sensitive information:

  • Financial data
  • Credit worthiness data
  • Social security numbers
  • Government Identification information

Payment Information

We may collect data necessary to allow you to process payments through Kredit’s third party payment service providers, Nuvei (https://www.nuvei.com/legal/privacy-notice ) and Repay (https://repay.com/privacy-policy/ ). All payment data is handled and stored by Nuvei and Repay and you should review their privacy policies before using their services.

This information you provide must be true, complete and accurate, and you must notify us of any changes to such information.

Administrative Data

This information may include device and system information, product license information, and/or usage and preference information including how you want us to communicate with you. This data helps us to understand and best serve your expectations, needs, interests and requirements.

Security Data

This data may include specifics about your financial accounts or transactions, location data and other information you provide to organize your personal financial network.

Diagnostic Data

If and as you use our Services and platform we may capture and preserve application crash reports, information you share regarding your customer experience as necessary to troubleshoot any malfunctioning Services. For example, when you call, in message, chat, email, or otherwise communicate with us, we may retain, and review recordings and records and the contents of the communications as required or permitted by law and our recording and information management policies.

Information automatically collected

When you visit, use or interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), which browsers are used to access the Service (e.g., Google Chrome, Microsoft Internet Explorer, etc.), and geographical location information. This information does not reveal your specific identity.

In particular, the following information may be created and automatically logged in our systems:

  • Log data: Information that your browser automatically sends whenever you visit the Service (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Service.
  • Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
  • Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

Cookies

We use essential cookies to operate and administer our Service, gather usage data on our Service and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it) and help recognize your computer when you open your 3 browser and browse the Internet again (persistent cookies). For more details on cookies we use, please visit our Cookie Policy.

Online Tracking and Do Not Track Signals

Kredit does not knowingly track or target users of its website for the purposes of marketing or advertising (“sale”/ “sharing”). Some tracking technologies are used to help us maintain the security of our Services and your account, to prevent crashes, fix bugs, save your preferences, and assist with basic site functions. For more information on these types of technologies please view the “Cookies” section above and the underlying Cookie Policy.

On most web browsers, you can find the Do-Not-Track (“DNT”) feature or setting where you can choose your privacy preferences. you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off or otherwise manage them. Kredit has no control over your choice of browser or the policies and practices of the browser companies. Please assure you review any browser companies’ own policies and procedures. For your convenience here are links to a few browser companies where you can review the policies and procedures each has:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Service and the choices you make about setting cookies may have an impact on the scope of functions associated with features of the Service you are able to access.

As articulated above, any User Content provided through the chat platform may interact with third party language models and you are solely responsible for the content of any Message you send through that channel.

Advertising networks unrelated in any way to Kredit may collect Personal information through the use of cookies. Should you desire to opt in or out of advertising preferences, review the unique privacy policies and procedures of your browser or website or the Network Advertising Initiative’s online resources at http://www.networkadvertising.org. You will be able to review opt-in and opt-out instructions there as well as other information about those unrelated sites’ and networks’ privacy statements. Kredit has no relationship of any sort to any of these sites or resources and notes them here solely for your convenience.

If you access the Service on your mobile device, the configuration of the applications or technology on your mobile device may, through no control of Kredit, limit your opportunities to control tracking, advertising or other settings.

If you feel your information has been tracked or targeted for purposes other than those necessary to maintain the security of our Services as described above, under applicable US Laws, you can opt out of these online tracking technologies by taking the steps outlined above and by submitting a request to compliance@trykredit.com for further assistance.

2. How do we process your information?

Consistent with applicable law and choices and controls that may be available to you, we may use all or some of the personal information we collect from you or from devices associated with you, for purposes including the following:

  • To personalize your experience
  • To provide and facilitate your engagement with the Service, including account creation, to verify your identity, facilitate user-to-user communications, facilitate payments between you and third-party financial institutions via our platform, and obtain your credit report from a third-party upon your request
  • To respond to your inquiries, comments, feedback or questions
  • To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies
  • To analyze how you interact with our Service
  • To maintain and improve the content and functionality of the Service and to troubleshoot any issues you or other users may report to us
  • To develop new products and services
  • To prevent fraud, criminal activity, or misuse of our Service, and to assure the security of our IT systems, architecture and networks; and
  • To comply with our legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties

Aggregated, Anonymized, and Pseudonymized Information

We may collect or generate aggregated, anonymized, and/or pseudonymized Personal information and use the information to analyze the effectiveness of our Service, to improve and add features to our Service, and for any other lawful purpose. In addition, we may share aggregated, anonymized, and/or pseudonymized information with our business partners and other third parties. We may collect or generate aggregated, anonymized, and/or pseudonymized information through the Service, through cookies, and through other means described in this Privacy Policy.

3. With whom do we share or disclose your personal information?

Our platform is designed to facilitate communications between you and financial institutions you tell us about that are in your personal financial network. Accordingly, we will share your Personal information with those financial institutions in accordance with your use of our Service, including to facilitate payments from you to such financial institutions. In certain circumstances we may share your Personal information with third parties, subject to applicable laws, as set forth below:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal information with vendors and service providers we contract with or coordinate with, including providers of hosting services, cloud services and other information technology services providers, email communication software and email newsletter services, payment processors, and banking, credit or financial service providers, customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Service, please see our Cookie Policy). Pursuant to our instructions, these parties will access, process or store Personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your personal information.
  • Companies You Select: If you direct us to share your personal information with another company, by electing to share your personal information with others to fulfill your request, we will share your Personal information and once shared it will be subject to the privacy policies and practices of those other companies.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
  • Affiliates: We may share Personal information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Kredit. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

4. How long do we keep your personal information?

We keep Personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is longer. Whenever your Personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the security and privacy of your personal information. These steps may include implementing standard contractual clauses with third parties, encouraging you to review the privacy statement of other companies you direct us to share your information with, and if required by law, obtaining your consent or other lawful approval of transferring your information.

5. How do we keep your personal information safe?

You use the Service at your own risk. We implement reasonable technical, administrative, and organizational measures designed to protect Personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal information to Kredit via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

6. Do US Residents have rights regarding their personal information?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to know or request access to and receive details about the personal information we maintain about you and how we have processed it. You may have the right to correct inaccuracies, get a copy of, or delete your personal information. Kredit will not discriminate against you for exercising your rights. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances, and we may decline your request as permitted by applicable law.

You may have the right to obtain a list of the categories of third parties to which we have disclosed personal information (as permitted by applicable law, including California’s and Delaware’s privacy laws). Those categories are listed within this Privacy Policy.

You may have the right to obtain a list of specific third parties to which we have disclosed personal information (as permitted by applicable law, including Oregon’s privacy law).

You may have the right to opt out of the collection of sensitive and/or personal information collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law).

You may have the right to limit use and disclosure of sensitive personal information (as permitted by applicable law, including California’s privacy law).

California Residents

You may have the right to opt-out of the “sale” or sharing of your personal information. You can opt-out using the following methods:

  • Accessing your Cookie consent settings as described above
  • By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

You should know that we have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the categories of data as detailed in this Privacy Policy, only with your consent and only to the parties detailed in this section.

California Civil Code Section 1798.83. also knowns as the “Shine The Light” law, permits users who are California residents to request and obtain information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We want you to know that Kredit does not share any personal information for the purposes of direct marketing. If you have any questions about this and how it applies to your data with Kredit, please contact us at compliance@trykredit.com California consumers may make all other requests to access, correct, or delete pursuant to their rights under the CCPA by contacting us at compliance@trykredit.com

Virginia Residents

In addition to the rights described above, you also have the right opt-out from the processing your personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which Kredit does not do. You also have the right to opt out of targeted advertising and selling (as such terms are defined under the VCDPA), however, as noted above, Kredit does not participate in the selling of your personal information.

Regardless, we must inform you that If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section. In such an appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

Kredit will honor the exercise of rights or appeals of decisions of Virginia residents requested via email at compliance@trykredit.com

7. How can you exercise your rights?

You control the data you provide to Kredit. You can access it anytime to make corrections, deletions, provide or revoke consent for certain services and uses of your data. In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our Service, those features of our Services may be unavailable to you. You can also contact us to ask any questions, make recommendations, or to seek assistance in updating or correcting your personal information.

Under certain US laws, you can designate an authorized agent to make data requests on your behalf. In accordance with applicable law, we may deny a request from an authorized agent that does not submit adequate proof of your authorization for them to act on your behalf.

Upon receipt of your request, we will need to verify your identity to determine you are the same person about whom we have information in our systems. We will only use personal information provided in your request to verify your identity or authority to make a request. However, if we cannot verify your identity with the information provided and available to us, we may ask for additional information or deny the request for security and fraud-prevention. You can appeal our decision to decline your request by contacting compliance@trykredit.com . If your appeal is denied, you may wish to contact your state attorney general for assistance.

8. Changes to this Privacy Policy

The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page noting the revision date, unless another type of notice is required by the applicable law. Your continued use of our Service, including by way of example but not limitation, providing us with persona information after we post an update Privacy Policy, or notified you by other means if applicable, shall be regarded as your consent to revisions to our Privacy Policy and practices related to it.

9. Still have questions?

If you have any questions regarding this Privacy Policy, you may contact our Data Privacy Officer (“DPO”) by email at compliance@trykredit.com