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Privacy Policy

Effective Date: November 15, 2023

Privacy and security are very important to us here at FormFree Holdings Corporation (“FormFree”). This Privacy Policy (“Policy”) is meant to help you (the “end user”) understand how FormFree collects, uses, and shares your data when you utilize our products or services.

This Policy applies to FormFree and its affiliates and subsidiaries. You should read this Policy carefully; it contains important information about your privacy rights and choices.

Background

Our goal with this Policy is to provide a simple and straightforward explanation of what data FormFree collects from and about you and how we use and share that information. We value transparency and want to provide you with a clear and concise description of how we treat your data.

This Policy does not cover data we collect through our websites or when you interact with FormFree outside of using our product or services, such as emailing or calling us directly.

FormFree’s services are not directed to individuals under 18 and we do not knowingly collect data relating to individuals who are minors.

Our Data Practices

FormFree is committed to providing consumers with meaningful control over their data. This section describes FormFree’s data practices relating to our processing of information about you. We also provide summaries of our practices organized by category of information collected and by product at the end of this Policy in the Summaries of Processing Activities section.

Data We Collect and Categories of Sources

As explained in greater detail below, the data we collect, use, and share depends on the FormFree products and services that you utilize. Depending on which of FormFree’s products or services you utilize, FormFree may collect the following:

  • Data you provide to us
  • Data from financial institutions when you connect your financial account(s)
  • Data from the electronic device you use to connect

Data you provide to us. When you use FormFree’s products or services, like when you connect your financial institution account(s) through FormFree, we may collect the following data from you:

  • identifiers like name, address, phone number, date of birth and social security number
  • login data required by the provider of your account(s), like your username and password or a security token

When you provide this data, you also give FormFree permission and authority to act on your behalf to access and transmit your data to and from the relevant financial institution that holds your financial account(s) (we’ll call them “financial partners” in this Policy).

Data we collect from financial partners when you connect your financial account(s). Depending on which FormFree products you utilize, as well as what and how information is made available by your financial institution, we may collect the following data from financial partners when you connect your financial account(s) with FormFree:

  • Account data, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, account number, routing number, and sort code;
  • Data about an account balance, including current and available balance;
  • Data about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
  • Data about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
  • Data about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
  • Identifiers and data about the account owner(s), including name, email address, phone number, date of birth, and address information;
  • Data about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and/or
  • Professional data, including data about your employer, via payroll information within the transaction data.

Depending on the FormFree service you utilize, and the manner in which the data is made available, the data collected from your financial account(s) may include data from all accounts (e.g., checking, savings, and joint accounts) accessible through a single set of account credentials. For more specifics about data collected in connection with different products and services, see Summary of Processing Activities by Product.

Data we receive from your devices. When you use a device, like your smartphone, tablet, or computer, to connect to our services, we receive data about that device, including:

  • internet protocol (IP) address;
  • time zone setting and location, device location;
  • hardware model and operating system;
  • which features within our services you access, browser data, and other technical data about the device.

Information we derive from the data we collect. We may derive additional information about you from the data we collect. For example, we may infer your geolocation, your annual income, or the type of account you’ve chosen to connect.  We may also derive additional information about your ability to pay a loan illustrated by a RIKI value.  “RIKI” means Residual Income Knowledge Index and uses direct source asset data (from the financial institutions you link) to illustrate where you fall on a particular ability to pay scale.  A lower RIKI indicates a lower ability to repay a debt and a higher RIKI indicates a higher ability to repay a debt.

How We Use Your Data

We use your data for the following business and commercial purposes:

  • Provide Services: To operate, provide, and maintain our services.
  • Develop Existing Services: To improve, enhance, modify, add to, and further develop our services.
  • Help Prevent Fraud or Protect Privacy: To help protect you, our partners, FormFree, and others from fraud, malicious activity, and other privacy and security-related concerns.
  • Develop New Services: To develop new products and services.
  • Develop Insights: To develop insights based on the data we’ve collected about you. This includes your transaction data and data from other sources, to help provide services and/or a better user experience to you, like providing you with a streamlined loan application process.
  • Provide Support: To provide support to you, including to help respond to your inquiries related to our services or developers’ apps.
  • Investigate Misuse and Misconduct: To investigate any misuse of our products or services, including criminal activity, or other unauthorized access to our services.
  • For Legal Purposes: To comply with contractual and legal obligations under applicable law and for other legal purposes such as to establish and defend against claims.
  • With Your Consent: For other notified purposes with your consent or at your direction.

We may collect, use, and share data that has been aggregated or anonymized in a manner that does not identify you personally for any purpose permitted under applicable law. This includes creating or using aggregated or anonymized data to develop new services or to facilitate research, to the extent permitted under applicable law.

We may collect and share cookie data with third parties when you visit our website, or we may allow third parties to collect this cookie data from our sites.

Our Retention and Deletion Practices

We retain your data for as long as is necessary. To determine whether the data is needed, we consider the reason your data was collected and used and any legal requirements to hold onto your data. We review your data periodically to ensure it is still needed to fulfill the purpose for which it was collected or any other legal requirements.

Your data will only be processed as required by law or in accordance with this Policy.

Please refer to the “Your Data Protection Rights” section of this Policy for options that may be available to you, including how to request deletion of your data. You can also contact us about our data retention practices using the contact information in the “Contacting FormFree” section below.

Protection of Data

FormFree’s security policies and practices are designed to protect the confidentiality and integrity of your data (such as Social Security number and other personally identifiable information), as well as any other data we collect about you. FormFree implements least privileged access controls designed to limit access to this data to personnel who have a business reason to know it and prohibits its personnel from unlawfully disclosing this data.

Additional Details

Your Data Protection Rights

FormFree will honor the following rights related to your personal data, subject to some limitations and exceptions provided by law, and you will not be discriminated against for exercising them:

  • Access data collected about you
  • Request, under certain circumstances, that we erase or restrict the processing of your data
  • Where processing of your data is based on consent, withdraw that consent

We welcome and appreciate the chance to address any concerns you may have and encourage you to contact us. In addition, and depending on your jurisdiction, you may have the right to make a complaint at any time to your (data protection) supervisory authority.

To exercise any rights you have, you can email your request to support@formfree.com. You can also contact us as described in the “Contacting FormFree” section below to exercise any of your data protection rights. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

If we receive your request from an authorized agent, we may ask for evidence that the agent has valid written authority, like a power of attorney, to submit requests on your behalf.

We will consider requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain data may be exempt from such requests, for example if we need to keep the data to comply with our own legal obligations or to establish, exercise, or defend legal claims.

Changes To This Policy

We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on this website: portal.formfree.com/privacy and update the effective date at the top of this Policy.

Contacting FormFree

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at compliance@formfree.com or by mail at:

FormFree Holdings Corporation

8830 Macon Highway, Building 200

Athens, GA 30606

 

Summaries of Processing Activities

Summary of Processing Activities by Category of Information

To help provide even greater transparency around our practices, we consolidated the information provided in our Policy above into a table that matches the categories of data FormFree collects about you with the sources of the data, uses of the data, and the categories of recipients with whom FormFree shares the data. For more detailed descriptions of our data collection, use, and sharing practices, please refer back to the sections of the Policy above.

Category of Personal Information & Examples Source of Personal Information Uses of Personal Information Categories of Parties with Whom Personal Information May Be Shared
Identifiers

for example: name, address, phone number, date of birth, social security number and financial institution credentials

  • Data you provide
  • Data we collect from your financial accounts
  • Data we receive from your devices
  • Data we receive about you from other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us
  • Professional advisors
  • Cloud storage services providers
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities
Financial Data

for example: account number, balance, and transaction history

  • Data you provide
  • Data we collect from your financial accounts
  • Data we receive about you from other sources
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us
  • Professional advisors
  • Cloud storage services providers
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities
Location Data

for example: timezone setting and device location

  • Data we receive from your devices
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us
  • Professional advisors
  • Cloud storage services providers
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities
Professional Data

for example: information about your employer and payroll information

  • Data you provide
  • Data we collect from your financial accounts
  • Data we receive about you from other sources
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us
  • Professional advisors
  • Cloud storage services providers
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities
Electronic Network Activity Data

for example: your device hardware model and operating system, and browser data

  • Data we receive from your devices
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us
  • Professional advisors
  • Cloud storage services providers
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities
Information We Derive

for example: we may derive location from IP address or your annual income from your pay stubs

  • Information we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us
  • Professional advisors
  • Cloud storage services providers
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities