Rightfoot Privacy Policy

Effective August 1, 2023

At Charitize, Inc. (“Rightfoot”), we are here to provide you with a platform to help you authorize access to your financial data. Before you provide any information to us, we encourage you to read this Privacy Policy (the “Policy”) carefully, as it contains important information about your personal information. When you use, access our website or otherwise interact with us, such as, for example, when you use Rightfoot to connect and share data from the provider that holds your financial account (“Account Providers”) with lenders and other financial institutions or others (collectively, “Partner Financial Institutions”) you are agreeing to our Terms of Use and consenting to how we collect, share and otherwise use information about you as described in this Policy. Among other things, these terms note that you must be 18 years of age or older to use our services.

This Policy explains how Rightfoot collects, uses, and shares your personal information with you when you interact with our “Services,” which include our website, the products and services that we offer to you and to Partner Financial Institutions, accessing and verifying financial information from Account Providers on your behalf, and additional features that Rightfoot offers. Although Rightfoot partners with Partner Financial Institutions and others to provide its Services, Rightfoot is not responsible for the privacy practices or the content of these or other third parties, and their practices may differ from those described in this Policy.

If you have questions regarding this Policy or our practices, or if you need assistance in exercising any of your choices under this Policy, please contact us at info@rightfoot.com.

Personal Information Rightfoot Collects About You

Information Collected From You and from Partner Financial Institutions

We collect personal information about you that you provide when you use our Services. We may collect this information for example, when you authorize Partner Financial Institutions to provide us with information necessary to connect with and access your Account Provider on your behalf. We may also collect personal information when you access our website, or if you communicate with us via telephone, email, or other means. Depending on the way that you interact with Rightfoot (including, where applicable, the application that you interact with Rightfoot through), we may collect the following categories of personal information:

  1. Your basic identifying information (for example, your name, account name, address, email, telephone number, and date of birth) or similar information;
  2. Other information necessary for us to access information on your behalf from your Account Provider(s), such as your full or partial Social Security number and account number;
  3. General loan information, where applicable, such as interest rate, loan amount, payment date, and other similar information;

When you provide us with these types of information, you also give Rightfoot your permission and the authority to act on your behalf to access and transmit your data to and from your Account Provider and the relevant Partner Financial Institution.

We may also collect some information from you automatically, for example, when you visit our website. This information can include:

  1. Activity Information. This information may include details of the activities you carry out when using our Services, including visits to our website. We may also collect your geographic location when you use a location-enabled device with our Services and sensor data from your device.
  2. Technical Information. This information may include the Internet protocol (“IP”) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and device identification information.  Some of this information, such as your IP address, may identify your geographic region, time zone, and other rough location data.
  3. Inferences, such as those drawn from any of the personal information we collect, to better understand your preferences.

Information Collected From Account Providers

Depending on how you use or otherwise interact with our Services, we may collect information from one or more of your Account Providers. This information may include:

  1. Basic account data, such as account name, type, and ownership; and information identifying the Account Provider.
  2. Account details, such as transaction history, payment amounts and dates, interest rate, due dates,, payment plan and terms, and balances owed.
  3. Transaction details, such as amount, date, type, and description.
  4. Employment information, in cases where the account that you have authorized Rightfoot to access includes employment-related information.

Cookies and Other Online Technologies

We use cookies and other technologies, such as web beacons, tags, and scripts, to administer the Rightfoot website, track consumers’ movements around the Rightfoot website, and detect and prevent fraud. We generally receive reports on this activity on an aggregated basis. Through your web browser, you can control the use of cookies, but if you reject cookies, the Rightfoot website may not function as designed, as certain features may be limited. Our Services use these technologies, for example, when you first request a web page and information is then stored on your computer or other device so the website or app can access information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, your search history, and content you have viewed.

Depending on the Services you use, we and our partners may also use these technologies to gather information about how you view and use our Services and content, and to connect your activity with other information we store about you. For example, we use Google Analytics on our Website, which allows us to view information about traffic to our Webpage and helps us understand how Website visitors use our Services. For more information on Google Analytics (including how it uses data for its own purposes, e.g., for profiling or linking it to other information) please visit the Google Analytics Terms of Use, the Google Analytics' Privacy and Data Protection Guidelines and in the Google Privacy Policy.

To learn more about your options with respect to cookies and similar technologies, please see the “Your Rights and Choices” section of this Policy.

How Rightfoot Uses Your Information

We may use the above-listed categories of personal information we collect for one or more of the following business purposes:

  1. To accomplish the purpose for which you provided the information to us or to our Partner Financial Institution. Depending on how you are interacting with us, these purposes may include to access information from Account Providers on your behalf and provide and verify that information to Partner Financial Institutions; to set up an account or aggregate loan data; or to provide similar services on your behalf.
  2. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  3. To carry out obligations and enforce our rights arising from this Policy, our Terms of Use, and any other contracts we enter with you.
  4. To provide, support, personalize, and develop our Website, products, and services.
  5. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  6. To personalize your experience on our website and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  7. To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  8. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  9. To defend our legal rights and to comply with national, state, local, federal, regional or international laws.

How Rightfoot Discloses Your Information

There are certain circumstances in which we share information collected through the Services with third parties, as set forth below. We do not share your data with non-affiliated third parties except as permitted by law.

  1. With Your Account Providers and Partner Financial Institutions. To provide our Services, including to establish a connection to your Account Provider and to provide and verify your information with Partner Financial Institutions on your behalf, and for other purposes, such as facilitating loan payments on your behalf;
  2. With Our Service Providers. We provide access to or share your information with third parties so they can perform services for us. Examples of such functions include marketing, mailing information, data storage and integration, data security, identity verification, fraud prevention, legal services, and database maintenance. We limit the personal information provided in this context to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information; 
  3. With our Successors-in-Interest. We may share your information with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) and related diligence activities. 
  4. To Meet Legal Requirements. We may disclosure your personal information when we have a good faith belief that doing so is necessary to: (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to inquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organizations; (ii) protect and defend the legal rights, privacy, safety or property of Rightfoot, its affiliates, subsidiaries, employees, agents, contractors, or its users; (iii) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or our Terms of Service.

We additionally may share aggregated, anonymized, or otherwise de-identified information collected from our about you so that the information no longer identifies you.

Information Security

We take information security seriously, and have implemented reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure, and to the fullest extent permitted by applicable law, we do not accept liability for any unauthorized disclosure.

If you have reason to believe that your personal information is no longer secure, please immediately contact us as set forth below in the “Contact Us” section.

Children

Our Services are not designed for use by individuals under the age of 18. If you are under the age of 18, please do not use the Services and/or submit any information through the Services. If you have reason to believe that a child under the age of 18 has provided personal information to Rightfoot through the Services, please contact us, and we will delete that information from our databases to the extent required by law.

Data Retention

We retain your information for as long as necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, that your information is only retained to the extent permitted or required by applicable laws. When we no longer need to retain your information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.

When determining the retention period for your information, we take into account various criteria, such as the type of Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on the Services that we provide to you if we delete some information about you, and mandatory retention periods provided by law.

Your Rights and Choices

Rightfoot is committed to help you exercise your rights regarding your personal information.

Deleting Your Information

To use Rightfoot’s Services, including applications that are powered by or integrated with Rightfoot, you must provide your permission and the authority for Rightfoot to act on your behalf to access and transmit your data to and from your Account Provider(s). You may revoke this consent at any time. If your use of Rightfoot’s Services involves or results from your relationship with a Partner Financial Institution, please contact them directly.

Communications Preferences

Depending on where you live and how you interact with us and with our Services, you may receive marketing communications from us. Please follow the instructions below to opt out of marketing communications. 

  • Emails. In order to opt-out of email communications, please click the “unsubscribe” link at the bottom of the email or contact us. ‍
  • Text Messages. If you receive an unwanted text message or phone call from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth below in the “Contact Us” section.

Please note that if you opt out of receiving marketing communications, we may still send you informational communications about your account or any Services you have requested, used, or received.

Cookie Choices

You may stop or restrict the placement of some types of cookies on your device or remove them by adjusting your preferences as your browser or device permits. You can also consult the “Help” section of your browser for more information (e.g. Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). However, please note that cookie-based opt-outs are typically not effective on mobile applications. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others. 

The online advertising industry additionally provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, the Your Ad Choices for App tool, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

Do-Not-Track  

Do Not Track (“DNT”) is a privacy preference that players can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browser, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and developing a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

Changes to this Privacy Policy

Rightfoot may update or modify this Policy periodically and at any time. If we make any updates or changes, we will post the new policy on our website at https://app.rightfoot.com/policies/privacy and update the effective date at the top of this Policy. We will also notify our Partner Financial Institutions of any material changes, as they may be better positioned to notify you about changes to this Policy. If you have an active Rightfoot account, we will also send an email to the email address you provided us notifying you of the update. By using our Services after any such update or modification, you acknowledge that you have read and understood the terms of the Policy as updated or modified.

Contact Us

Please contact us at info@rightfoot.com if you have any questions about this Policy or our information practices.