Privacy Policy

Last Updated: September 21, 2023

This privacy policy describes how Best Friend Finance, LLC (“BFF,” “we,” “us”or “our”) collects, uses, stores, shares, and protects your information when youaccess and use BFF’s website (the “Website”).

1. Important information

Purpose of this privacy policy

We know how important privacy is to our users, which is why we only collect the information we need and will not share your personal information with any third parties, unless necessary to perform the services you request. It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions, and which may be applicable to you when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Changes to the privacy policy and your duty to inform us of changes

We may change this privacy policy from time to time. When we do make updates, we will let you know by changing the date at the top of this privacy policy. It is your responsibility to review this privacy policy periodically. You hereby consent to any updates to this privacy policy whenever you access the Website after the privacy policy has been updated.

2. The data that may be collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, username, and/or other similar information.
  • Contact Data includes email address and/or telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type, and/or other similar information.
  • Usage Data includes information about how you use the Website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Location Data includes information about your device location.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3. How we use your personal data

BFF uses collected information for the following purposes:

  • To provide the information or content you have requested, including the full functionality of the Website;
  • To improve our Website and for internal business purposes;
  • To ensure the security of the Website;
  • To enforce compliance with our User Agreement and other policies
  • To stay connected with you: whether it be for providing customer service, notifying you of new features or updates, or providing notices or other information; and
  • Fulfill any other purpose for which the information was collected.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

4. How we share your personal data

Sharing with third parties

We do not sell your personal data to other organizations for commercial purposes. We only share your personal data to provide products or services you’ve requested, when we have your permission, or under the following circumstances:

  • In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our User Agreement, or as otherwise required by law.
  • In order to carry out our legal obligations, we may need to share information about you with professional advisers who provide consultancy, legal, accounting, or other professional services.
  • We may publish aggregated and anonymized data for statistical and research purposes. In any such instance, the information will not be able to be traced back to any individual.
  • We may choose to sell, transfer, or merge parts of our business or our assets to third parties. Alternatively, we may acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

5. How we protect your personal data

BFF takes precautions to ensure the security of your personal information. We ensure that the Website is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures. We cannot protect, nor does this privacy policy apply to, any information that you transmit to other users. You should never transmit personal information to other users.

6. Children under the age of 18

The Website is not intended for children under 18 years of age, and we do not knowingly collect information from children under 18 without parental consent.If we learn we have collected or received personal information from a child under 18, we will delete that information.

7. European Union Privacy Rights

If you are a resident of the European Union you may have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. You have the right to access your personal data and, if necessary, have it amended, deleted or restricted. In certain instances, you may have the right to the portability of your data. Please contact us at the email address in Section 10 to fulfill any requests relating to your data subject rights.

8. California Privacy Rights

Residents of California may have additional rights regarding our use of your personal information. California residents have rights to request a copy of personal information collected about them over the past 12 months. California residents will not be discriminated against because they choose to exercise rights under the California Consumer Privacy Act.

9. Data retention

We retain information as long as it is necessary to provide access to products and services on the Website, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the products and services or untilyou ask us to delete it or your account is deleted, whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our User Agreement, and take other actions permitted by law. The information we retain will be handled in accordance with this privacy policy.10. Contact InformationPlease contact our privacy team with any questions, concerns, or feedback regarding this privacy policy or if you want to opt-out of data collection and/or usage by sending an email to legal@bestfriend.finance.