Privacy policy

Effective Date: 10/07/2024
Kiwipop, Inc. (“we,” “us,” or “our”) respects your privacy. This Privacy Policy (“Policy”) describes how we
collect, use, protect, and share your Personal Information in connection with our products and services
(“Services”) when you use our mobile application (“App”).
If you have any questions about our privacy practices, please contact us by email at hello@kiwipop.co.
1. PERSONAL INFORMATION
For purposes of this Policy, “Personal Information” means information that alone or in combination
identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be
linked, directly or indirectly, with a natural person. Personal Information does not include information
that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT?
We may collect the following categories of Personal Information from you, electronically or from third
parties, including when you use the App or otherwise interact with us:
▪ Identifiers: name, email address, IP address, and other contact information
▪ Customer Records: transaction history data from your credit cards, bank and other financial
institution accounts you connect to the App
▪ Protected Class Information: age, gender
▪ Internet Activity: IP address, operating system, browser type, device identifier, Internet, or other
electronic network activity information, including, but not limited to, and information regarding
your interaction with the App
▪ Geolocation Data: imprecise location information, such as the city, state, and ZIP code associated
with your IP address
▪ Inferences: personal preferences, characteristics, psychological trends, behavior, predispositions,
attitudes, intelligence, abilities, aptitudes.
3. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION
Directly from You
We collect your Personal Information directly from you, for example when you access, use, or otherwise
interact with the App, create an account, accounts you link to the App such as information from your
credit card account or bank accounts and when you request information from us.
From You Automatically
We may collect certain information about you automatically when you use the App, such as your IP
address, mobile carrier, and other device identifiers that are automatically assigned to your computer ordevice when you access the Internet. For more information, see the “Cookies and Other Tracking
Technologies” section below.
From Third Parties
We may receive your Personal Information from third parties in connection with providing the Services
such as from our payment processors and financial aggregators.
4. PURPOSE FOR WHICH WE COLLECT PERSONAL INFORMATION
We collect and use Personal Information for the following purposes:
▪ Communications. We may communicate with you through emails or calls; provide you with alerts,
updates, promotions, and other information; communicate with you regarding updates to the
App or our Services; respond to you when you contact us; send technical notices, updates, security
alerts, support and administrative messages; and to notify you of changes to our terms or this
Policy.
▪ Account Creation. We may use your Personal Information to create and service your App or online
account with us.
▪ Access Financial Information. We may use your Personal Information to provide the Services
when you choose to link your account on our App or online account to your bank, credit card or
other financial institution accounts through one of our third-party financial data aggregator
partners.
▪ To Operate and Improve the Services and the App. To analyze, operate, maintain, support and
improve our Services and the App.
▪ Develop Insights. We may use Personal Information collected from you to develop insights
necessary to provide you a better user experience.
▪ For Research and Development. We may use Personal Information that you have shared on a
deidentified and aggregated basis to perform research and development for academic and
scholarly reasons, to develop a data set or algorithm using a large learning model and to
improve our Service or as otherwise permitted by applicable law.
▪ Business Purposes: We may use Personal Information for our business purposes such as to (1)
operate our business, the Services and the App; (2) carry out our obligations and enforce our
rights arising from any contracts we have entered into, including, without limitation, any contracts
between you and us; (3) conduct statistical or demographic analysis; (4) prevent fraud; (5) assess
the success of our marketing and advertising campaigns; (6) inform our business strategies; (7)
operate our information technology systems; (8) perform research and development as further
described above; (9) administer surveys and solicit feedback; (10) engage in business transactions
and (11) engage in other business purposes permitted under applicable law.
▪ Advertising and Marketing: We may use your Personal Information to serve customized
advertising to you, to customize content, to improve our ability to contact you, to enhance our
marketing capabilities and to inform our marketing and advertising strategies. We may use
Personal Information to advertise and market to you including notifying you of special
promotions, sweepstakes, contests, opportunities, offers and events, via e-mail and text
messages.▪ Analytics: We use Personal Information to improve the Services, the content of the App and to
enhance your user experience when using the App or our Services. We use Personal Information
to generate statistical information about the usage and traffic patterns of the App and the Services
and to prevent fraud.
▪ Law Enforcement/Legal Purposes: We may use Personal Information to respond to requests from
law enforcement or for other legal purposes including to: (1) comply with legal and regulatory
requirements; (2) satisfy contractual obligations; (3) cooperate with law enforcement or other
governmental agencies for purposes of investigations, public safety or matters of public
importance when we are legally required to do so or believe that disclosure of Personal
Information is necessary or appropriate to protect the public interest; and (4) protecting and
defending against legal actions or claims.
▪ At Your Direction: We may use Personal Information for any other purpose which you authorize.
5. DISCLOSING AND SHARING PERSONAL INFORMATION
We may share or disclose with service providers or other third parties certain Personal Information that
we, or third parties acting on our behalf, have collected. We may disclose or share such Personal
Information with the following parties:
▪ Service Providers: We may disclose Personal Information to our service providers who are
contractually obligated to maintain the confidentiality of that Personal Information. For example,
we may disclose Personal Information to service providers that: (a) help us host and manage the
Services and the App; (b) help us improve the content and functionality of the Services and the
App; (c) perform data analysis and statistical analysis services; (d) troubleshoot problems with the
App or the Services; (e) provide email or text messaging services; (f) provide marketing,
advertising or public relations services for us; (g) provide data processing and storage services; (h)
support or provide the security of the Services and the App; (i) to assist us in research and
development and (j) payment processors.
▪ Third Parties. We may disclose Personal Information to third parties who perform targeted
advertising or website analytics services for us.
▪ Parties to Business Transactions: In the event of an anticipated or actual merger or acquisition,
bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to
use information owned or controlled by us, including Personal Information. We reserve the right,
in connection with these types of transactions, to transfer, share, assign, or sell your Personal
Information and other information we have collected to third parties or to authorize such third
parties to use any such information, including for due diligence, as part of any of the transactions
described in this paragraph. Any Personal Information you submit or that is collected after this
type of transfer may be subject to a new privacy policy adopted by the successor entity.
▪ Government and Law Enforcement: We may share your Personal Information with individuals or
private parties where necessary to enforce and comply with the law, to protect our property or
legal rights, for the safety of the public or any person, to prevent harm, to protect the security
and integrity of the App and any equipment used to make the Services or the App available.
▪ Professional Advisors: We may share Personal Information with our professional advisors, such
as our attorneys, accountants, financial advisors, and business advisors, in their capacity as
advisors to us.6. COOKIES AND OTHER TRACKING TECHNOLOGIES
We use cookies, web beacons, pixel tags and other analytics or tracking technologies (collectively
“Tracking Technologies”) on our App. Tracking Technologies allow the App to remember your actions and
preferences and recognize you or your browser, along with some information you provided. Web beacons
and pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
We use these tools to make the App function properly; perform data analytics, serve you with targeted
advertising; provide personalized experiences; tailor our interactions with you; help with our marketing
efforts; provide us with valuable data and statistics about the usage and effectiveness of the App and to
help us improve the App and Services.
7. YOUR PRIVACY CHOICES
We offer you several choices with respect to how we use your Personal Information.
▪ You may update or correct any Personal Information you have provided us by editing your account
information on our App, or by contacting us at hello@kiwipop.co.
▪ Opt out of marketing emails. If you opt in to receive electronic marketing communications from
us, you consent to our sending such electronic communications to you using the email address
you provide. We may use third-party providers to deliver communications to you. If you no longer
want to receive email marketing communications from us, you may opt out of such emails by
using the unsubscribe link in the email you received from us or by contacting us at
hello@kiwipop.co with “Unsubscribe” in the subject line.
▪ You may reduce the number of targeted advertisements by changing your preferences online. To
change your preferences with respect to certain advertisements and to obtain more information
about third-party ad networks and online behavioral advertising, visit National Advertising
Initiative Consumer Mobile Opt Out Page or the Digital Advertising Alliance AppChoices Mobile
App. Changing your settings with individual apps or ad networks will not necessarily carry over to
other devices or ad networks. As a result, depending on the opt-outs you request, you may still
see our ads.
8. SOCIAL MEDIA
We are active on social media, including Facebook, Instagram, Tik Tok, LinkedIn, and Twitter (“Social
Media”). Anything you post on Social Media is public information and will not be treated confidentially.
We may post (or re-post) on our Social Media pages any comments or content that you post on our Social
Media pages. Your use of Social Media is governed by the privacy policies and terms of the applicable
Social Media providers.
9. SECURITY OF INFORMATION
We are committed to protecting the security of your Personal Information. We use commercially
reasonable safeguards to maintain the security and privacy of Personal Information we collect and use in
connection with our Services and the App.10. CHILDREN’S PRIVACY
We do not direct or target any content of our App or Services to children under the age of 13. If we learn
that we have collected the Personal Information of anyone under the age of 13, we will take appropriate
steps to delete this information. If you are a parent or guardian of someone under the age of 13 and
discover that your child has submitted Personal Information to us, please send us and email at the contact
information below. We will make reasonable efforts to remove such information from our databases.
11. CALIFORNIA SHINE THE LIGHT
Under California Civil Code Section 1798.83, California residents have the right to obtain: (a) a list of all
third parties to whom we may have disclosed your Personal Information within the past year for direct
marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please
contact us as set forth at the end of this Privacy Policy to receive this information.
12. CHANGES AND UPDATES TO THIS POLICY
This Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as
they are posted. If changes are made to this Policy, we will prominently display that we have made
updates on the top of this Policy, on the App or will communicate to you in another manner. Please check
back periodically to see if our Policy has been updated.
13. THIRD-PARTY SERVICES
As part of your relationship with us, and to provide you with the services or products you requested, you acknowledge and agree that:
13.1. We use Method Financial (“Method”), a third party service, to validate your identity and prevent fraud. You authorize your wireless carrier to use or disclose information about you and your wireless device, if available, to Method or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud. See Method's Privacy Policy for how they treat your data;
13.2. You authorize Method to obtain a consumer report and information about you from one or more consumer reporting agencies ("credit pull"). You understand the credit pull is a soft inquiry that will not impact your credit score. Method will use this information solely in connection with identifying and obtaining data on your liability/debt accounts such as account number, type, balance, interest rate, payoff information, late fees, payment history, etc. ("Account Data");
13.3. You authorize and direct Method to act on your behalf to access and obtain the Account Data from your financial institutions, lenders, creditors, and service providers, or any of their third parties, and you consent to Method sharing the Account Data with us. Your authorization, direction, and consent remains effective for the duration of your business relationship with us, solely for the purpose of providing you with services or products that you may request from us from time to time;You acknowledge and agree to Method's Privacy Policy (https://methodfi.com/legal/privacy) and Terms of Service (https://methodfi.com/legal/terms).
13.4. You acknowledge and agree to Method's Privacy Policy (https://methodfi.com/legal/privacy) and Terms of Service (https://methodfi.com/legal/terms).
14. CONTACT US
We welcome your questions, comments, and concerns about our privacy practices. Please contact us
through using the information below with any questions or feedback you have pertaining to our privacy
practices.
hello@kiwipop.co