Privacy Policy

Updated July 13, 2022

General

Thank you for using Affordably, Inc. (“Affordably”, “us” or “we”) and our services made available through websites including www.affordably.me (the “Site”), the downloadable applications (collectively, the “Apps,” together with the Site, the “Service”), and the Affordably widget placed on the websites of third-party merchant partners we work with.

This Privacy Policy describes the data that we collect, how we use and share that data, and the steps we take to protect your information. 

This Privacy Policy is incorporated into and is subject to the Affordably Terms of Service. By using the Service, you agree to the privacy practices described here and to our Terms of Service, plus any other policies made available by us to you. Capitalized terms that are not defined in the Privacy Policy have the meaning given to them in the Affordably Terms of Service. 

Data We Collect

 

A. User-Provided Data

We do not automatically collect any Personally Identifiable Information or Sensitive Information without your consent. When you use the Service, we collect information, such as your name, email, address, phone number, and other data. You may provide us with data when you fill out forms on our application or when you apply for a job, when you contact us about our Service (including by email or other means), when you submit User Content, and when you register for an account. The categories of information we collect include:

  • Contact Data: May include your name, email, address, and phone number.
  • Identifiers: May include your social security number or another national identifier number.
  • Demographic Data: May include your age, gender, and country. 
  • Commercial or Transactions Information: May include records of products, services, and subscriptions purchased, obtained, or considered.
  • Financial Data: May include your current or historical income level, expenses, assets, and other financial information.
  • Payment Information: May include tokenized bank account or credit card payment information.
  • Profile Data: May include your interests, inferences, and preferences. 
  • Content: May include content within any messages you send to us when contacting customer support or asking a question, for example.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information. 

‍We collect this information through a variety of means, which may include from your identity documents, text you input and/or images we ask you to provide, or through connecting with third-party services as described below. We will only share your Personally Identifiable Information to the extent necessary to allow us to manage our relationship with you.

You may be asked to provide data or documentation to verify your eligibility for discounts for various businesses & services. This documentation might be provided by government agencies, telecommunications networks, credit card bureaus, or financial institutions.

The decision to share specific items of your Personally Identifiable Information and/or Sensitive Information with the Service or opportunities offered by Third-Party Websites which are conditioned upon certain eligibility requirements is yours and yours alone. However, if you decline to provide any of the above information, you may not be able to register for an Affordably Account or to access certain discounts. We reserve the right to audit your eligibility; to audit user accounts for fraud by, for example, verifying that purchases, upgrades, or benefits (both tangible and intangible) are delivered to registered user addresses or used by the registered user and not otherwise resold, transferred, or distributed by Users for their personal, financial gain; and to prevent duplicate Affordably Accounts from being created with the same information.

Users should understand that merchants that use the Affordably.me Service (collectively referred to hereafter as the “Third-Party Websites”) are not bound to this Privacy Policy and We are not responsible for the privacy policies of the Third-Party websites. Users should review the privacy policy and practices of Third-Party websites to determine how information collected from Users will be handled.

Users 

B. User-Provided Data Through Third-Party Integrations

Our Service allows you to connect your third party accounts, including financial accounts, to your Affordably account. We use Plaid, Argyle and other third-party integrations to provide this functionality. To connect your third party accounts to your Affordably account, you must authorize such connection when registering your Affordably account. You may terminate this connection at any time by contacting support@affordably.me, and, in the future, directly in your account settings. 

When connecting your third party accounts to your Affordably account, you permit Affordably and the third party integration to act on your behalf to access and transmit your information from the relevant bank or other entity that provides your accounts. The data we receive from the entities that maintain your accounts varies depending on the data made available by those entities. Examples of the types of information we receive from such accounts include financial account information, account balance data, credit account data, loan account data, investment accounts data, identifiers and information about account owners, account transaction data, pay data, and employment data. 

Affordably is not responsible for the third party’s privacy practices and we encourage you to review their privacy policies before connecting your third party accounts with your Affordably account. Plaid’s privacy policy is available at https://plaid.com/legal. You are responsible for the accuracy and completeness of the data provided through any third parties you connect to the Service.

C. Data Automatically Collected

When you use the Service, we (or our service providers or vendors) may automatically collect certain information from your web browser and through your device by using different types of technology, including “cookies,” “log files,” "pixels," and other tracking technologies. This automatically-collected information includes:

  • Device Data: May include data about device identifiers such as IP address or other device address or ID, web browser and/or device type, your device’s operating software, your internet service provider, and your device’s regional and language settings. 
  • Service Use Data: May include data about the web pages or sites that you visit just before or just after the Service, the pages you view on the Service, your actions on the Service, features you use, emails and advertisements you view, products and services you view and purchase, and the dates and times that you visit, access, or use the Service.
  • Location Data: May include imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

The types of tracking technologies used include: 

  • Cookies. When you use the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service to personalize your experience, remember your preferences, and support security features. Persistent cookies can be removed. Please review your web browser "Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential

For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, see the “Analytics” and “Your Rights and Choices” sections below.

E. Information from Other Sources

We also collect information from sources other than the Service, such as:

  • Partners & Vendors 
  • Identity Verification and Fraud Prevention Services.
  • Data brokers from which we purchase data to supplement the data we collect. 
  • Publicly-available sources, including data in the public domain.

 

We treat the information collected from other sources subject to any laws or contractual obligations applicable to us. In the event we are permitted to process the information for our own purposes, we will process the information in accordance with the practices described in this Privacy Policy. 

 

How We Use Data 

We use your data in providing the Service and operating our other business and commercial purposes. We use the information we collect about you for the following purposes:

  • For purposes about which we notify you and with your consent.
  • To operate, maintain, enhance and provide the features of the Service.
  • To perform services requested by you, such as responding to your comments and questions. 
  • To communicate discount eligibility for you with customized discounts to various partner merchant websites or apps for whom you give us explicit consent.
  • To understand and analyze the usages trends and preferences of our users, to improve the Service and other Affordably websites, apps, marketing efforts, products & services, and to create new features and functionality.
  • To contact you for administrative purposes such as customer service, sending technical notices regarding updates, security alerts, information regarding our policies.
  • To send you promotional materials, offers, messages related to the Service and the activities of partners, vendors, and advertisers we work with. Generally, you have the ability to opt-out of receiving any such communications, either through links provided in the messages or by updating your account preferences through the Service.
  • To address fraud, breach of policies or terms, and threats or harm. 
  • To personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service.
  • To develop and provide advertisements, direct marketing, communications, content, and information about our and other entities’ products, offers, promotions, rewards, events, and services.
  • To monitor and analyze the effectiveness of Service and our partners’ marketing activities.
  • To monitor aggregate site usage metrics such as total number of visitors and pages/screens viewed.
  • To track your entries, submissions, and status in any promotions or other activities, including verifying your eligibility and delivering prizes in connection with your entries.
  • To fulfill any other purpose at your direction, such as when you request a custom discount derived from the data you previously provided to the Service.
  • To conduct research, including focus groups and surveys.

 

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

When We Disclose Information

We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

  • Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, fraud prevention, data analytics, marketing, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
  • Third Party Integrations. We share information with third parties (such as Plaid) and any relevant banks or other entities in connection with you connecting your third party accounts to your Affordably account. You may terminate this connection at any time through your account settings.
  • Analytics. We share information with vendors and other parties for our analytics purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on analytics, see the “Analytics” section below. 
  • Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
  • Partners, Vendors, and Marketing. We share information in connection with offering co-branded services, selling or distributing our products, engaging in joint marketing activities, or providing marketing on our Service. 
  • Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in marketing materials.
  • Merger or Acquisition. In the event that all or a portion of Affordably or its assets are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users in connection with such merger, acquisition, sale, or other change of control.
  • Security and Compelled Disclosure. We share information to comply with the law or other legal processes, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security, and safety of us, the Service, or anyone else. For example, we share information with identity verification services and fraud prevention services. 
  • Facilitating Requests. We share information at your request or direction. 
  • Consent. We share information with notice to you and your consent. For example, where we have received your consent, we will share your Service account with your spouse. Where we have received such consent, we are not responsible for the acts or omissions of your spouse on the Service. You can opt out of such sharing at any time by disabling “Account Sharing” in the "Profile” section of the app.

 

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

Analytics

We use analytics services, such Amplitude, to help us understand how users access and use the Service.

‍Your Rights and Choices

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. Below is further information regarding your rights and choices for the Service:

  • Account Information. If you have an account with us, you may update, correct, or delete your account and any profile information you set within the account at any time by emailing support@affordably.me, and in the future, by accessing your account-preferences page through the Service. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 
  • Emails. If you do not wish to receive email or text offers or newsletters from us, you can opt-out of receiving such information from us (except for emails related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions on the Service) by using the unsubscribe process at the bottom of the email or replying STOP to our text messages. Please note that while your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.
  • Push Notifications. If you have opted-in to receive push notifications on your device, you can opt-out at any time by updating your account preferences through the Service, through your device settings, or by uninstalling the app.
  • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit https://www.allaboutdnt.com.

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser, device, account, email address, and/or phone number from which you opt out. It will not affect subsequent subscriptions (where applicable). We are not responsible for any other entities’ effectiveness of, or compliance with, any opt out options or programs, or the accuracy of their statements regarding their opt out options or programs.

Third Parties

The Service may contain features or links to websites and services provided by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. Some examples include:

  • Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. We may get a commission if you purchase a product or service after clicking on a link to an affiliate partner’s website. 
  • Third Party Integrations as detailed in Section 2 above.
  • Logging-In. We may embed a pixel or SDK on our Service that allows you to log-in to your Affordably account through your social media account. If you choose to log-in, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through your use. 
  • Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Affordably in a tweet or post), we may use your reference on or in connection with our Service.

 

Any information you provide on another party’s sites or services is provided directly to that party and is subject to that party’s policies and practices regarding privacy and security, even if accessed through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children's Privacy

The Service is intended for general audiences and is not directed at anyone under the age of 18. For that reason, we do not allow anyone under the age of 18 to use the Service or knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from anyone under the age of 18. If you are under 18 years of age, please do not use or access the Service at any time or in any manner. If we learn that personal information has been collected on the Service from children, we will take the appropriate steps to delete this information in accordance with COPPA. If you are a parent or guardian and discover that your child has obtained an account on the Service or provided us with personal information, you may submit a request to our Privacy Request Form to request that we delete the personal information from our systems. We will remove the personal information in accordance with COPPA.

Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of your information. Nevertheless, transmission via the internet is not completely secure and we cannot ensure or warrant the security of any information you transmit to us or store on the Service and you do so at your own risk. We also cannot guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. See the Information Security Policy for more details.

International Transfers

The Service is hosted in various countries. Your use of the Service, or provision of any information on the Service, is your consent to the transfer, storage, usage, sharing, and processing of information about you in the region that the Service deems most appropriate to process that information subject to the privacy requirements of your country and as set out in this Privacy Policy.

Changes and Updates to the Privacy Policy

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which may be revised periodically. In the event that a change to the Privacy Policy materially modifies your rights or obligations, we may provide additional notice to your email address or through Service. Any changes are effective upon publication of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

Our Contact Information

Please contact us with any questions or comments about this Privacy Policy, your information, our use and disclosure practices, or your consent choices by email at privacy@affordably.me

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us by emailing us at privacy@affordably.me.

Additional Disclosures for Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at privacy@affordably.me.

Additional Disclosures for California Residents

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

A. Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: 

  • Identifiers, including name, email address, mailing address, social security number, and online identifiers (such as IP address).
  • Customer records, including phone number, billing address, and financial information.
  • Characteristics of protected classifications under California or federal law, including gender.
  • Commercial or transactions information, including records of products, services, and subscriptions purchased, obtained, or considered.
  • Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
  • Geolocation data.
  • Employment and education information.
  • Inferences drawn from the above information about your predicted characteristics and preferences. 

For further details on information we collect, including the sources from which we receive information, review the “Information We Collect” section above. We collect and use these categories of personal information for the business purposes described in the “How We Use Information” section above, including to manage our Service.

We do not generally sell information as the term “sell” is traditionally understood. To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Advertising” section above, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review the “When We Disclose Information” section above for further details about the categories of parties with whom we share information.

 

B. Right to Know and Delete

You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

  • The categories of personal information we have collected about you;  
  • The categories of sources from which the personal information was collected; 
  • The categories of personal information about you we disclosed for a business purpose or sold; 
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold; 
  • The business or commercial purpose for collecting or selling the personal information; and 
  • The specific pieces of personal information we have collected about you.

 

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request using our Privacy Request Form. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

‍C. Right to Opt-Out.

To the extent Affordably sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information in your account settings.

D. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. 

E. Right to Non-Discrimination. 

You have the right not to receive discriminatory treatment by us for the exercise of any your rights. 

F. Shine the Light. 

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Our Contact Information” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.