Privacy Policy

 

Last updated: November 28, 2022

Introduction

 

Cambio Financial Health, Inc. (“Cambio”) or (“we”, “our”, “us”) understands that you care about how information about you is collected, used and shared, and we appreciate that you trust this information with us. We are committed to protecting your information. We act in accordance with applicable data protection and privacy laws when we collect and use information about you.

This Privacy Policy (“Privacy Policy”) applies to your use of our mobile application (“Application”) and our websites (collectively, our “Website”) and describes how we collect, use, share and protect any personal information when you use our Application and visit our Website. We may change, add to, or remove all or any portion of this Privacy Policy at any time, and we will post our current Privacy Policy so that you will always have our current Privacy Policy available to you.

How to Contact Us

 

Should you have any comments or questions about how we collect and use your personal information, communication can be directed to Cambio via email to info@cambiomoney.com.

Applicability & Eligibility

 

This Privacy Policy applies to our Application or Website, and our collection, use, disclosure, and protection of your data. It does not apply to third party websites, applications, or services. Before accessing, using, or interacting with our Application or Website, you should carefully review the terms and conditions of this Privacy Policy.

By using our Application or Website, you are agreeing to our Privacy Policy, without modification, and confirming you have read and understand these policies, including how and why we use your information. If you do not want us to collect or process your personal information in the ways described in this Privacy Policy, you should not use our Application or Website.

Our Application and Website are not intended for individuals under the age of 17. We do not knowingly collect personal information directly from individuals under 17 years of age. Cambio’s products and services are not intended for individuals under 17 years of age. If you are under 17 years of age, you should not submit or post personal information on our Application or Website.

Personal Information Collection & Use

 

We collect information about you and your use of our Application and/or Website through various means, including information we receive from you on, application or website forms, as well as through your access, use, or interaction with our Application or Website. Such processing is utilized to provide our Application and Website to our visitors and members.

We collect and process personal information from you only where:

• We have your consent to do You may withdraw this consent at any time by contacting Cambio at info@cambiomoney.com.

• We need the personal information to perform a contract with you or provide a service to

• Provide you with the benefits of our Application, Website and/or operate our

• The processing is in our legitimate business
• To comply with legal requirements, including applicable laws and regulations

Personal Information You Provide to Cambio

 

The following table provides more detailed information on the personal information you provide to Cambio and why we collect it.

Information we collect	Why we collect it
Setting up your membership – We collect information when you set up your Cambio membership or interact with our Application. Personal information may include your contact information (such as your name, address, phone number and email), social security number, driver’s license number, billing information (your payment information), and user ID.	This information is necessary for us to provide services, products, or information you requested. We do not share or sell any personal information to other organizations for commercial purposes.
Joining our waitlist – If you use a form on our Website to join the waitlist for our Application, we may collect your name, email address, phone number, or physical address.	This information is necessary for us to contact when the Application is available for your use or provide you with any other information requested. We do not share or sell any personal information to other organizations for commercial purposes.
Identification information – We collect information to verify your identity, including your name, social security number, social insurance number, driver’s license numbers, government-issued identification details, for example to verify your identity so we can provide you with your Cambio™ reloadable prepaid card.	This information is necessary for us to provide services, products, or information you requested. We do not share or sell any personal information to other organizations for commercial purposes.
Customer support, product research, training, and feedback – We may collect personal information when you reach out to us for support, give us feedback, participate in optional surveys, product research or training and you choose to share.	This information is necessary for us to provide you with support, product improvements, training and/or member services. We do not share or sell any personal information to other organizations for commercial purposes.
Social and community content – We receive content you post on our social media pages and our community pages.	This information is necessary for us to provide you with support, product improvements, training and/or member services. We do not share or sell any personal information to other organizations for commercial purposes.

Personal Information We Automatically Collect

We may collect certain information about you when you access or use the Application or Website. This may include:

• Device information – We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security

• Content – We may receive information about your finances, expenses, details of your financial transactions, payroll details, payment details, income, and wage information.

• Third-party service content – We receive information about you when you connect your Cambio account to a third-party For example, you may choose to connect your Cambio membership/reloadable prepaid card with your employer to set up direct deposit. To sync your financial account information, we must access your financial account information.

• Usage information – We may collect usage information such as the pages you viewed, the features you use, your browser type and details about any links with which you

• Location information – Certain features in the Application may collect your precise location information, device motion information, or both, if you grant permission to do so in your device

• Camera – Certain features may have access to your camera if you grant permission in your device

• Information from cookies and other technologies – Cambio and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’

We do not store any sensitive information within your cookies. Our Application and Website do not read any information stored in cookies given to you from other websites, except in rare cases where the other website is a provider of information or functionality within our Application or Website and that cookie is necessary to make our Application or Website function correctly.

Most of the cookies we use are “session cookies” which are automatically deleted as soon as you leave the site. Other cookies, so-called “persistent cookies,” remain on your computer until you delete them. Using these cookies allow us to enhance your experience in interacting with our Application or Website, such as by helping recognize your browser the next time you visit and loading previously viewed pages faster. We use cookies to offer you the best possible experience on our Application or Website.

We also use cookies to collect browsing information in order to improve your overall experience. We use this information to track website usage and compile statistics. This helps us improve our Application Website, so you will find it more useful and informative, and enable customized promotions you may be interested in. We may use the combination of data we collect, such as browsing information and email address, to join known devices together and provide you personalized experiences on the device you are currently using. Impression data from cookies, which indicates who has seen advertisements about our products and services on our Application or Website or third-party websites, may be used to improve our marketing practices. If you are a current customer, have logged into your account or provide your email address, we may use analytics software to link data we collect, such as use of our Application or Website, opening emails we send you or contacting our customer service center via phone, back to you.

We may use browsing information we collect (including IP address, email address and data received from Google Analytics) to match with information received from third parties (including behavioral information and device identifiers) and customer information to learn more about an individual or a group. These actions help us analyze interactions with our Application or Website, improve marketing efforts, inform our strategic approach, and improve your experience. We also may use this information to directly market our products and services, to the extent permitted by law. We may use third parties to perform these and other activities.

You can set your web browser to notify you when you receive a cookie from our Website, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. Disabling cookies is unique to each browser and device you use. Disabling cookies on one device will restrict the ability to tie that device to other devices you use. Parts of our Website may not function properly if you disable cookies. To provide you with the best possible experience while visiting our Website, please enable cookies within your browser.

We also enable cookies to be placed or accessed on your device by third party advertising networks. These kinds of persistent cookies remember the websites you visit, and that information is shared with other parties, such as advertisers. We may use third-party advertising networks to help us deliver tailored online ads to you. To learn more about opting-out of this type of interest- based advertising, please visit the Network Advertising Alliance (NAI) Consumer opt-out website.

Do Not Track

Most web browsers and some mobile operating systems and mobile applications include a “do not track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored or collected. Our Application and web services do not alter, change, or respond upon receiving Do Not Track (DNT) requests or signals in browsers. As described in more detail above, we track user activity using cookies and similar technologies.

Google Analytics

We use a tool called “Google Analytics” to collect information about use of our Website and Application. This tool uses persistent cookies to allow us to see behavior information relating to visitor age, gender, and interests. We may also use this data to create remarketing lists. You can opt out of Google Analytics without affecting how you visit our Website and Application. For more information on opting out of Google Analytics tracking and customizing Google Display Network ads, visit Google’s Ad Settings.

Categories of CCPA Personal Information Collected

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.   Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

How we use your information?

 

Personal information is used to operate our business, including but not limited to:

• Provide you with the Application and set up your Cambio™ membership

• Improve our products and services

• Run and manage our business, including resolving billing and financial disputes

• Evaluate your eligibility for offers, products and services

• Connect you with experts and other users

• Communicate with you

• Advertise and market our services and experiences

• Personalize your experience, including through the development of insights about you and your needs
• Provide you with support and resolve disputes

• Conduct research, including by partnering with academic institutions and others

• Comply with our legal and regulatory requirements

• Protect the rights, property, safety, or security of Cambio, our customers, employees or others and prevent fraudulent or illegal activity

• To enforce, remedy or apply our Terms of Use or other agreements

To provide you with valuable personalized advice, recommendations, and experiences, we may process your personal information using automated and manual (human) methods. Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience in the Application.

We may also use your personal information for other purposes that are compatible with the disclosed purposes if and where this is permitted by applicable law.

With whom do we share your information?

Bottom line, we only share information with your consent, to comply with laws, to provide you with purchased services, to protect your rights, or to fulfill business obligations. Third parties who may receive your personal information include:

• Business partners – These are businesses that we work with to offer you certain services or
• Card Issuing Credit Union – We may share the information we collect with our credit union partner, Services Credit Union, which issues the Cambio™ reloadable prepaid card.
• Nonaffiliated service providers – These nonaffiliated service providers may offer services like, but not limited to, payment processing, data analysis, email delivery, hosting services, customer service, marketing efforts, etc. These companies may use information about your visits to our Application, Website and/or other websites that are contained in cookies to provide services, advertisements, or to collect data about how you interact with our Application or Website over time
• Affiliates – If we share your information with affiliates, they are required to adhere to this Privacy
• Government and regulatory authorities – We may provide information to government and regulatory bodies to provide the services you have purchased or because of legal and regulatory obligations on our
• Our auditors and legal advisors – We may need to provide information to assist with provision of services or management of our business.
• Relevant industry self-regulatory bodies – We may need to provide information to assist with provision of services or management of our business.
• Others only as permitted by law

 

We do not sell your personal information, and we have agreements with our service providers to prohibit any sale of your personal information and to provide written assurances regarding the security and privacy protections they have in place to protect your personal information.

In the event there is a change in the corporate structure of Cambio, such as, but not limited to, merger, consolidation, sale, liquidation, or transfer of substantial assets, Cambio may, in its sole discretion, transfer, sell or assign personal information we have about you to one or more affiliated or unaffiliated third parties.

Your information may only be transferred to another country for processing as permitted and in compliance with applicable law.

Where and how long is your personal information stored?

We store personal information about you on computer systems operated by us or our service providers. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable laws and regulations.

How is my personal information secured?

We maintain physical, technological, and administrative safeguards to protect your personal information and prevent unauthorized or accidental use, access, or loss. We limit access to personal information about you to those who have a business need for such access. Individuals who process personal information on our behalf generally may do so only in an authorized manner and are required to keep your information confidential. We limit access to our premises and to our computer networks and take steps to safeguard against unauthorized access to such premises and networks.

 

What are your rights?

You may have various rights with respect to your personal information depending on where you live, the information we have about you, and the context in which it was obtained. These rights are defined under a variety of privacy laws and regulations, each of which may or may not apply to our relationship with you or your personal information. We may choose to extend these rights to you even if we are not required to under applicable law.

Privacy Rights under the California Consumer Privacy Act (“CCPA”)

 

For residents of California, to the extent we have collected information about you, you may have rights to your personal information as described below:

• Right to know – You may be entitled to request that we disclose to your personal information we have collected about you, the categories of sources from which we collected the information, the purposes of collecting the information, the categories of third parties with whom we have shared the information, and the categories of personal information that we have shared with third parties for a business purpose. Before providing any of this information, we must be able to verify your
• Right to opt-out – We currently do not sell personal information to third parties, and therefore do not offer this We may share personal information about you with our business partners and others as permitted by law. Please see the “With whom do we share your information?” portion of this Privacy Policy for more information.
• Right to deletion – Subject to certain conditions, you may be entitled to request that we delete personal information about Before deleting information, we must be able to verify your identity. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with a product and/or service or where required to be retained.

We do not discriminate against you if you choose to exercise these rights.

Submitting Privacy Requests

You can exercise your privacy rights by submitting requests to us to exercise those rights and by taking other steps that will limit how information about you is collected, used, and shared.

 

Opting out of email marketing

If you no longer wish to receive marketing or promotional emails from us, please click the unsubscribe link included in the footer of every promotional email we send, or contact us directly as provided in the “How to Contact Cambio” section of this Privacy Policy.

Submit personal information requests under the CCPA

For residents of California, you may exercise your privacy rights under the CCPA by submitting a Personal Information Request by emailing info@cambiomoney.com

We must verify your identity before fulfilling your personal information request. To verify your identity, we will collect information from you, including, to the extent applicable, your name, government identification number, date of birth, contact information, your account information, answers to security questions, or other personal identifying information. We will match this information against information we have previously collected about you to verify your identity and to respond to your request. Information collected for purposes of verifying your request will only be used for verification and to respond to your personal information request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.

If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, we require you to verify your identity with us directly before we provide any requested information to your approved agent.

Linking to Third Parties

When you leave our Application or Website and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, we do not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by Cambio.

 

Changes to this Policy

We reserve the right to change this Privacy Policy at any time in our sole discretion. If we make changes, we will post the revised policy here, so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our Website, Application or services after notice is provided, you accept and agree to this Privacy Policy as modified.