Privacy and Communications Policy

This Privacy and Communications Policy ("Policy") is effective as of October 7, 2021.

This Policy sets forth how Cashbasic LLC, a Nebraska limited liability company (“We” or "Us"), in operation of www.cashbasic.com ("Website") collects and uses the information you provide to us and certain other information that we automatically collect through your access and use of this Website and our financial tools platform (“Services”), or through any communications with us generally.

HOW TO CONTACT US

If you have any general questions or concerns about this Policy, you can email us at info@cashbasic.com.

MODIFICATIONS TO THIS POLICY

If we decide at any time to change this Policy, we will revise the effective revision date posted at the top of this Policy and we will also notify you by posting a notice of the change prominently on our home page and/or upon the next time you access this Website. Failure to opt-out after receiving notice and following the opt-out instructions contained in the notice shall be deemed to be your assent to any such changes.

Personal Information from Users Under 18

Users under the age of 18 are expressly prohibited from submitting or posting any PII on this Website. If it does come to our attention that any child under the age of 13 has submitted any personal information to this Website, we will delete all such information that we have collected immediately. If you are a parent or guardian and you discover that your child under the age of 13 has submitted any of his or her PII without your permission or consent, we will remove the information immediately upon your request. All requests should be made by email and sent to assistant@cashbasic.com. Please include the email address your child used to log in to our Website and a description of the type of information you think he or she may have submitted to this Website.

PERSONAL INFORMATION WE COLLECT

We collect your first name and email address as the only direct item of personally identifiable information (collectively "PII") that you submit through your use of the Services when you create a user account. You will be asked to create and provide a username and password each time you log-in to access the Services and we collect and store this information in our database.

Your physical shipping address is collected for physical product and promotional item shipping, but is not saved in our database in the same manner as your email and your first name. Your address information is only used as part of a logistical prompt in connection with the shipping process.

Website Forms

When you provide any PII or other personally identifiable data through any form contained on this Website in order to subscribe to our email list or to contact us, we collect and store this information. We may use your email or any other PII you provide as expressly set forth in this Policy.

Services & Financial Information

The following financial and demographic information is collected for purposes of analysis when you use some of our modules/tools; your salary/wages, assets, debts, college attendance, and other similar information, and sometimes including your bank account balance and transactions history data when you voluntarily provide such data using our financial tools (collectively known as "Financial Information") we collect and store such Financial Information. This information is primarily used in producing outputs for personal finance modules/tools offered on the Website. We may also use this information internally to assist us to analyze the profiles of users of the Services and our web traffic in general. We will never share this information in association with your Identity Information. As our website grows, we may generate and share anonymous statistics about retirement readiness to help policymakers, employers, and business leaders better understand the needs and challenges of our retirement system. However, no such data we aggregate and share would be able to identify any users of the Services and would never be bundled in such a manner that would allow any such recipients to be able to identify you. Your information used in such studies will be anonymized.

Please note that some of our tools allow us to also collect very basic information about our registered member-users in order to develop certain statistics, such as an age range (18-24, 25-34, etc.). This data will be used to let registered members know how their responses to certain questions compared to other member responses in their age range and within the same module. No PII will be collected or shared in connection with such collection and this data is not bundled with any PII.

Forum Comments

When you leave any comments in connection with any of our articles, we collect and store this information in our database along with your email address. We use any PII we collect from you as described in this Policy. Comments posted on our forums, by their nature, are immediately and publicly visible to all visitors to this website and they are not private. When you share information publicly, it may be indexable by search engines. Do not post information you consider to be private in nature.

HOW WE AUTOMATICALLY COLLECT NON-PII

When you access our Website, we may collect and store through our host provider certain non-PII sent automatically by your browser using standard web server logs and automatic data collection tools such as cookies and web beacons. This information may include your IP address, which may tell us your general location information such as your country and sometimes your city, state and/or zip code, the domain name from which you access our Website, your browser type and language, the pages you access, the date and time you access pages on our Website and your operating system version. We also may determine what technology is available through your browser in order to provide you with the most appropriate version of any of our web pages.

Cookies & Similar Tracking Technologies

We along with third parties that assist us to operate this Website may monitor your use of this Website through cookies, web beacons and other “automatic data collection tools." Unless you have adjusted your browser setting to refuse all cookies, some cookies are placed on your browser immediately as soon as you visit our site. Cookies and similar collection tools are files with a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and transferred to your device. We reserve the right to monitor your use of this Website and track you as described in this Cookies policy by the use of any automatic data collection tools at all times and you consent to the use of these tools when you use and access our Website.

This Website may use both "first-party cookies" and "third-party cookies." First-party cookies are those used by our Website each time you visit our Website. Third-party cookies are cookies that are set by a third-party source other than our Website. We do not have access to or control over these cookies. We also use both "persistent cookies" that remain on your device for the period of time specified in the cookie (these cookies are activated each time you visit our Website), and "session cookies," which allows us to track your actions on this Website during a browser session. Each time you open up a browser window and close the browser window represents a single browser session. All session cookies are created temporarily and are deleted once you close your browser window.

Both the first-party and third-party cookies and tracking technologies that may be used on this Website can be broadly divided into the following categories:

• Necessary cookies help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. Our website cannot function properly without these cookies.
• Statistic cookies help us understand how visitors interact with websites by collecting and reporting information anonymously.

First-Party Cookies/Tracking Technologies

Website Session Management: We enable users to log-in and use for other authentication purposes or in order to store specific user preferences and settings (for instance, form blocking the same pop-up from appearing).

Google Analytics Services: We may use third party web analytics services, such as Google Analytics, in order to collect information. This information is collected in the aggregate and may include the number of page visits, duration, sources of traffic, visited pages, preferred sections, keywords used to find our Website, technical details of visitors’ devices, our visitors age, gender, interests, and location. Google Analytics only shows us a unique user ID and does not share your personal information, Google user name or IP address, which means you can't really see and analyze how specific users behave on our Website. We pass a "first party cookie" onto your browser directly from our Website when we use Google Analytics. You may opt-out of Google Analytics by using Google's Browser Add-on at https://tools.google.com/dlpage/gaoptout.

Third-Party Cookies/Tracking Technologies

• Pinterest

  If you are a Pinterest user, your browsing and web activity information may be shared with them for online behavioral advertising. You can opt out of online behavioral advertising through your Pinterest personalization settings, the AdChoices website, or your mobile ad identifier settings.

How To Manage Cookies

You can block our cookies or third-party cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to use all or parts of our site in the manner intended.

Your Internet browser allows you to change your cookie settings in the 'options' or 'preferences' menu of your browser. Please visit the following link for more information on these settings in various browsers:

https://www.thewindowsclub.com/disable-enable-cookies-internet-explorer

For even more information about deleting or blocking cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=2

Social Media Features and Widgets

We allow you to log-in using your Facebook account and may also provide access to services or features on our Website that enables you to share information with certain social networks and interact with us on our social media fan pages or other social media platforms that we may utilize. This may include the Facebook "Like" or share buttons or the Facebook "Comments" feature, social media "follow-us" buttons, etc., all of which are administered via third-party applications or scripts that run on our Website. (For example, Facebook will attempt to track your use on our Website by placing Javascript code through the "like" button and that piece of code then allows Facebook to run a script on your browser which can set cookies and make more tracking requests.) Your use of these features may result in the collection or sharing of information about you by these third-party social media websites. This may include collecting your IP address, tracking your use on our Website and other third-party websites containing the same social media features, including the pages you visit, duration, time, etc., through the use of a cookie or other unique identifier placed on your browser by such third parties. Your interactions with these social media features are governed by the privacy policy of the party that provides the specific feature or application. You should carefully review the privacy policies and settings on those specific social media sites. In addition, these standalone plugins that integrate into our website may also communicate with an external server controlled by the plugin provider as part of their service. We shall, under no circumstances, have any liability to you whatsoever for the information collection and use/disclosure practices of any such third party that has provided or made available any social media feature or application that you use on our Website.

Our Data Processors & Subprocessors

A data processor is any third-party that we use to operate this Website or provide our Services to you who has or potentially will have access to or process any personal data you provide to us. These data processors may engage different types of subprocessors to perform various functions. This limited access is incidental to the services being provided by such third parties to us to operate this Website and/or to provide the Services to you and no permission or consent is granted by us to use or disclose this information in any manner other than as necessary to provide the applicable services to us or to facilitate any transactions with you. By using this Website, you affirmatively consent to have that information shared with these third parties for the limited purposes stated herein.

In addition, we require all of our data processors and subprocessors to:

• Process personal data in accordance with our documented instructions;
• Use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws, in connection with their subprocessing activities;
• Provide regular training in security and data protection to personnel to whom they grant access to any personal data;
• Implement and maintain appropriate technical and organizational measures (including measures consistent with those to which we may be contractually committed to adhering to insofar as they are equally relevant to the subprocessor’s processing of personal data on our behalf);
• Promptly inform us about any actual or potential data breaches; and
• Cooperate with us in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

We use the following data processors:

1. Infrastructure & Data Storage

Hosting/Data Storage. We use Bluehost, Inc. (“Bluehost”) and Firebase, a Google company, to host this Website and store your data on their cloud-based servers.

1. Specific Services
2. Payment Processors. When you purchase paid access to any of our financial tools or enter into a paid membership, you share the PII you provide and your credit/debit card or bank account information with third party credit card and payment processors including PayPal and/or Stripe (which may include fraud screening and/or automated data processors). We do not collect and store this data and this data will only be used for the strict purpose of processing your payment, unless otherwise stated in the separate privacy policy of such third-party processor.
3. Plaid Balance Display. Users are able to link bank accounts, credit cards, and/or other accounts through Plaid as integrated on this Website. The purpose of this is to provide account balances, which will be downloaded and cached once per day through your use of this tool for viewing and use in various tools/modules. This information may be stored by Plaid on its servers in order to facilitate your use of this tool and you should review the separate privacy policy contained on plaid.com to determine how any data may be used or shared by Plaid.

Your California Resident Privacy Rights: California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of their personal information to third parties for their direct marketing purposes. California law also allows California residents to opt-out of having this information disclosed. We would hereby like to disclose that we do not share your personal information or information you have entered into our website, or information we might have gathered in the course of operating our website with any third party for their direct marketing purposes. This applies to all of our users regardless of their state or country of residence.

Your Rights Under The GDPR

Under the General Data Protection Regulation (GDPR), EU citizens (and individuals located in the EU during data collection) have the following rights:

• The right to access stored personal data and have it provided to you in an electronic, machine-readable format.
• The right to rectify errors in your personal data.
• The right to know how you personal data will be used.
• The right to know how long you personal data will be stored.
• The right to know with whom your personal data is being shared.
• The right “to be forgotten” and have any stored personal data permanently deleted.
• The right to withdraw your prior consent to and/or restrict certain uses of personal data we collect.
• The right to know the source of your personal data collection if informed consent was not given.

If you are an EU natural citizen, please email assistant@cashbasic.com to contact us in order to exercise any of these rights.

THIRD PARTY PRIVACY PRACTICES

You may be given the opportunity through this Website to purchase or obtain more information regarding certain content, products or services that are sold by third parties by clicking on any third party links contained on this Website. In addition, you acknowledge that we rely on third party service providers to operate this Website that may have limited access to your information. By using this Website including submitting any requested information, you affirmatively consent to have that information shared with these third parties for the limited purposes stated herein. Any information used by any third parties may be subject to a different set of practices than those described under this Policy and we are not responsible for the privacy practices of any of such third parties. You should read the privacy policy contained on the website of any third parties before you provide any information to that party. You agree that we shall not, under any circumstances, have any liability to you for any damages of any kind whatsoever for the manner in which any such third parties use or disclose any personal, billing or other information you provide voluntarily, or that is collected by those websites, through your access or use of this Website.

HOW WE USE/SHARE YOUR INFORMATION

Promotional & Informational Use of Emails

We use the e-mail address provided by our registered members and users who check-out to send periodic promotional or routine e-mails about our services or any promotional products or about any new or upcoming services, but only if you have elected to receive such email communications from us. You can opt-out of receiving any promotional or routine emails at any time by either clicking "unsubscribe" in the body of the email communication and following the opt-out procedure contained in the email, on your user Dashboard, or by sending an email to assistant@cashbasic.com and requesting to opt-out of receiving such communications.

Do We Sell Your Identity Information?

We are committed to keeping this Website ad-free to provide you with a comfortable and bias-free environment for your planning. We do not share any PII with any third parties including advertising agencies or our commercial users. We make every effort to respect your privacy and we will never sell, license or disclose any of your Identity Information, by itself or bundled with any Use Information or other information you provide or that we collect to any third parties for any purpose not expressly set forth in this Policy without your express written consent. We only share or disclose any PII or other information collected from You as expressly set forth in this Policy.

Required Disclosures

We may disclose certain PII if i) requested via a subpoena, court order, or local, state, federal or international law enforcement request to release any such information; or ii) in order to investigate and help prevent security threats, fraud or other malicious activity; or iii) to protect our rights or protect our property, or any of the rights of our customers or other third parties.

Communications

When you visit this Website, submit posts on our forums or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. You agree that all agreements, notices and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. All posts submitted by you on the forums or comments sections of this Website shall not be treated as confidential and shall be deemed to be accessible to the general public. You should not transmit any information in your posts that you intend only the intended recipient(s) to read. Notice is hereby given that all messages or electronic data transmitted onto this Website can and may be read by us, regardless of whether we are the intended recipient of any such message(s).

HOW WE PROTECT YOUR INFORMATION

We take the security of your data very seriously. All traffic between your browser and our servers is encrypted during transmission using Secure Sockets Layer (SSL) encryption. We also use Standard best practices using Google Firebase. We make no guarantee, warranty or representation that your credit card or other billing information, or any other information you provide through this Website, will remain secure at all times from any illegal or unauthorized access of the information by third parties. We shall not, under any circumstances, be held responsible or liable for information or transmissions that are accessed by third parties illegally or without authorization through this Website and/or network. We will report any unauthorized access of your information promptly upon discovery, and we will use our best efforts to remedy any security vulnerability that contributed to the unauthorized access. Our databases are also strongly encrypted at rest.

GENERAL INFORMATION

Information Storage And International Transfer

Any PII and all other information which we collect on this Website will be stored and processed in our servers located in the United States. If you reside outside the United States, you consent to the collection, transfer, storage and processing of any information from your country to the United States.

How to Update, Change or View Your Identity Information

If you are a free basic user, the only PII we store is your first name and email address. Please email us if you wish to update your information at any time through assistant@cashbasic.com.

Successors

Upon any acquisition, merger, sale or other change of control of our business/organization, we reserve the right to transfer any PII you have submitted to this Website as part of the property owned by us to our successor resulting from such merger, acquisition, sale, etc. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, We reserve the right to transfer your PII to protect any of our rights or as required by law.