Chipkie — Privacy Policy (United States)

Last updated: [INSERT DATE]

Chipkie Pty Ltd (ABN 75 663 915 884) (we, us, or our) understands that protecting your personal information is important. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you interact with us through the United States section of our websites, applications, and services (the Platform).

We are a software company based in Australia. Our Platform is a record-keeping and document-generation tool that helps people who already know each other (such as friends and family) record a loan, track repayments, and optionally generate a simple loan agreement. We are not a lender, broker, money transmitter, debt collector, or consumer reporting agency, and we do not hold, transfer, or process loan funds. Because we operate from Australia, your personal information will be transferred to and processed in Australia and may be processed in other countries (see “International Data Transfers” below).

This Privacy Policy is designed to address U.S. federal and state privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the CCPA), and comparable laws in other states such as Virginia, Colorado, Connecticut, and Utah (together, U.S. State Privacy Laws). Specific rights and disclosures for residents of certain states appear in the “Your U.S. Privacy Rights” and “State-Specific Disclosures” sections below.

1. Information We Collect

Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It does not include publicly available information or de-identified or aggregated information.

The types of personal information we may collect about you include:

• Identity Data — your name, age, and gender.
• Contact Data — your telephone number, address, and email.
• Financial Data — bank account and payment card details, collected and stored through our third-party payment processor (such as Stripe). The processor stores this information; we do not have access to your full card or bank account numbers.
• Identity Verification Data — government-issued identification details we may request to verify your identity and help prevent fraud, where reasonably necessary or required by applicable law.
• Transaction Data — details about payments between you and us (such as subscription Fees) and other details of products and services you have purchased from us. (Note: we do not collect, hold, or process the loan funds exchanged between you and another user; we record only the loan information you choose to enter.)
• Technical and Usage Data — when you access our websites or Platform: your internet protocol (IP) address, login data, browser session and geolocation data, statistics on page views and sessions, device and network information, acquisition sources, search queries and browsing behavior, and your access to and use of our website (including through cookies and analytics).
• Profile Data — your username and password, profile picture, your activity on the Platform, and support requests.
• Interaction Data — information you provide when you take part in interactive features, including surveys, contests, promotions, activities, or events.
• Marketing and Communications Data — your preferences for receiving marketing from us and our third parties, and your communication preferences.
• Professional Data — if you are a worker of ours or apply for a role, your professional history, such as previous positions and experience.

Sensitive personal information. Some of the above may be considered “sensitive personal information” under the CCPA and similar laws — for example, your government-issued identification number, and account log-in or financial-account information together with any required access credential. We use sensitive personal information only for the purposes permitted by law (such as verifying identity, providing the Platform, preventing fraud, and complying with law) and not to infer characteristics about you. See “Right to Limit Use of Sensitive Personal Information” below.

How these categories map to the CCPA

2. How We Collect Personal Information

We collect personal information in a variety of ways, including:

• when you provide it directly to us (in person, by phone, by email, or online);
• when you complete a form, such as registering for events or newsletters or responding to surveys;
• when you use any website or application we operate (including from analytics, cookie, and marketing providers — see “Cookies and Tracking Technologies”);
• from third parties, such as our payment processor (Stripe) or identity-verification providers; and
• from publicly available sources.

3. Why We Collect, Use, and Disclose Personal Information

We collect, hold, use, and disclose your personal information for the following business and commercial purposes:

• to enable you to access and use our software, including to provide you with a login;
• to do business with you, including to respond to support requests or assess an application;
• to contact and communicate with you about our business and any inquiries you make;
• for internal record-keeping, administrative, invoicing, and billing purposes;
• for analytics, market research, and business development, including to operate and improve our Platform and associated social media;
• for advertising and marketing, including to send promotional information about our products, events, and offerings that we consider may interest you;
• to run promotions, competitions, or additional benefits;
• to verify your identity and to detect, prevent, and respond to fraud, security incidents, and misuse;
• to consider your employment application, if you apply; and
• to comply with our legal obligations or as otherwise required or authorized by law.

We will not collect, use, or disclose sensitive personal information for purposes other than those permitted under applicable law without providing you any notice and choice required by law.

4. Cookies and Tracking Technologies

We may use cookies and similar technologies on our website. Cookies are text files placed in your browser to store preferences. By themselves, cookies do not tell us your email address or other identifying information, but they recognize you when you return and allow third parties to display our advertisements on your social and online feeds as part of retargeting campaigns. If you choose to provide personal information, it may be linked to data stored in a cookie.

Google Analytics. We have enabled Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as Google advertising cookies) together. These may collect Technical and Usage Data about you. You can opt out of Google Analytics Advertising Features using the Google Analytics Opt-out Browser Add-on, and you can control personalized ads through Google’s Ads Settings. To opt out of interest-based ads on mobile devices, use your device’s advertising-identifier settings (Android: Google Settings > Ads; iOS: Limit Ad Tracking / advertising identifier settings).

Your choices. You can block cookies through your browser settings, but if you block all cookies (including essential cookies) you may not be able to access all or parts of our website. You can also opt out of many interest-based advertising cookies through the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org).

Global Privacy Control. Our website is designed to recognize opt-out preference signals, including the Global Privacy Control (GPC), where required by law. When we detect a GPC signal from your browser, we will treat it as a request to opt out of the “sale” or “sharing” of personal information for that browser or device.

5. How We Disclose Personal Information

We disclose your personal information to third parties where necessary for our business, where we have your consent, or where permitted or required by law. We may disclose personal information to:

• our employees, contractors, and related entities;
• IT service providers, data storage, web-hosting, and server providers;
• marketing or advertising providers;
• professional advisors, bankers, auditors, insurers, and insurance brokers;
• payment systems operators or processors (such as Stripe);
• identity-verification providers;
• our existing or potential agents or business partners;
• a successor entity or acquirer (and their advisors) if we merge, are acquired, or sell all or part of our assets, in which case your personal information may be among the assets transferred;
• courts, tribunals, and regulatory authorities, including where you fail to pay for services we provided, or in connection with actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights;
• law enforcement and government authorities, as required or authorized by law (such as in response to a subpoena or lawful request); and
• any other third parties as required or permitted by law.

6. “Sale” and “Sharing” of Personal Information

U.S. State Privacy Laws define “sale” broadly (disclosing personal information for monetary or other valuable consideration) and “sharing” to include disclosing personal information for cross-context behavioral advertising (targeted advertising).

We do not sell your personal information for money. However, our use of advertising and analytics technologies (such as Google Analytics Advertising Features and retargeting cookies) may be considered a “sale” or “sharing” of certain personal information under those laws. The categories that may be “shared” for these purposes are: Identifiers, Internet/network activity, Geolocation data, and Commercial information, disclosed to advertising and analytics partners.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

Your right to opt out. You may opt out of the sale or sharing of your personal information at any time by:

• using the “Do Not Sell or Share My Personal Information” link on our website [INSERT LINK];
• enabling a Global Privacy Control signal in your browser; or
• contacting us using the details in the “Contact Us” section.

7. Retention of Personal Information

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Platform, comply with our legal, accounting, or reporting obligations, resolve disputes, and enforce our agreements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements. When we no longer need personal information, we will delete or de-identify it.

8. Your U.S. Privacy Rights

Depending on your state of residence and subject to certain exceptions, you may have the following rights regarding your personal information:

• Right to know / access — to request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties to whom we disclose it.
• Right to delete — to request deletion of personal information we collected from you.
• Right to correct — to request correction of inaccurate personal information.
• Right to data portability — to receive a copy of your personal information in a portable format.
• Right to opt out of sale or sharing — to opt out of the sale or sharing of your personal information (see Section 6).
• Right to opt out of targeted advertising and certain profiling — where provided by your state’s law.
• Right to limit use of sensitive personal information — see below.
• Right to non-discrimination — we will not discriminate against you for exercising any of these rights.
• Right to appeal — if we deny your request, residents of states that provide an appeal right may appeal our decision as described in our response.

Right to Limit Use of Sensitive Personal Information. You may request that we limit our use and disclosure of your sensitive personal information to those uses permitted by law. Because we already use sensitive personal information only for permitted purposes (such as identity verification, providing the Platform, fraud prevention, and legal compliance), this request may not change how we handle it, but you may submit one using the details below.

9. How to Exercise Your Rights

To exercise any right, contact us using the details in the “Contact Us” section, or use any request mechanism we provide on our website. We will need to verify your identity before responding, which may require you to confirm information we already hold about you. We will respond within the timeframe required by applicable law.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We may require the agent to provide proof of authorization and may require you to verify your own identity directly with us.

Fees. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded, in which case we may charge a reasonable fee or decline the request as permitted by law.

10. State-Specific Disclosures

California — “Shine the Light.” California Civil Code §1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. You may make one request per year using the contact details below.

California — Do Not Track. Our website does not currently respond to “Do Not Track” browser signals, but we honor the Global Privacy Control as described in Section 4.

Nevada. Nevada residents may opt out of the sale of certain “covered information” to third parties who will license or sell it. We do not currently engage in such sales, but you may submit a request using the contact details below.

Other states. Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may exercise the applicable rights described in Section 8, including the right to appeal a denied request.

11. Children’s Privacy

The Platform is intended for users who are at least 18 years old. We do not knowingly collect personal information from children under 13 (or, for purposes of sale/sharing, under 16). If you believe a child has provided us with personal information, please contact us, and we will take reasonable steps to delete it.

12. International Data Transfers

We store and process personal information in Australia, and our service providers may store, transfer, or access personal information in other countries. If you are located in the United States, your personal information will be transferred to, and processed in, Australia and potentially other countries, which may have data-protection laws that differ from those in your state. By using the Platform, you understand that your personal information will be processed as described in this Privacy Policy. We take reasonable steps to ensure that personal information transferred internationally is handled consistently with this Privacy Policy and applicable law.

13. Single Sign-On Accounts

If you connect your account with us using a single sign-on account (for example, Google or Facebook), we will collect your personal information from that provider in accordance with the privacy settings you have chosen with them. The information we may receive includes your name, ID, username, handle, profile picture, gender, age, language, list of friends or follows, and any other information you choose to share. We use this information to create your profile and provide our services.

Where we accessed your personal information through your Facebook account, you may request deletion of the personal information Facebook provided to us by emailing us at the address below and specifying what you would like deleted. If we deny your request, we will explain why.

14. Storage and Security

We are committed to keeping personal information secure and have implemented suitable physical, electronic, and managerial procedures to safeguard it from misuse, interference, loss, and unauthorized access, modification, and disclosure. However, no method of transmission or storage is completely secure, and we cannot guarantee the security of information transmitted to or by us over the internet. Transmission is at your own risk. If we become aware of a security incident affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

15. Links to Other Websites

Our website may contain links to third-party websites we do not control and are not responsible for. Those websites are not governed by this Privacy Policy, and we encourage you to review their privacy policies.

16. Changes to This Privacy Policy

We may vary this Privacy Policy at any time at our discretion by publishing the amended version on our website, and the “Last updated” date reflects the most recent changes. Where required by law, we will provide additional notice of material changes. We recommend you review this Privacy Policy regularly.

17. Contact Us

For any questions, requests, or complaints, or to exercise your privacy rights, please contact us at:

Chipkie Pty Ltd (ABN 75 663 915 884) Email: [email protected]

If you are not satisfied with our response to a complaint, you may have the right to contact your state attorney general or, where applicable, the relevant state privacy regulator (such as the California Privacy Protection Agency).