PRIVACY POLICY

Last updated: September 18, 2023

This privacy notice is for Abound Financial Technologies Inc., ("we," "us," or "our"). It describes how and why we might process your information when you use our services ("Services"). This includes when you:

1. Visit our website at http://www.aboundfi.com or any website of ours that links to this privacy notice.
2. Download and use our mobile application (Abound ChMS), or any other application of ours that links to this privacy notice.
3. Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns?
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@aboundfi.com 

Disclaimer: Throughout this document, the terms "Privacy Policy" and "Privacy Notice" are used interchangeably. Both terms refer to the same document and are intended to have the same meaning, detailing our practices and principles regarding the collection, use, and protection of personal information.

SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice. For more details on any of these topics, click the link following each key point.

What personal information do we process?
When you use our Services, we may process personal information based on your interactions and the features you use.
Learn more about the personal information you disclose to us.

Do we process any sensitive personal information?
We do not process sensitive personal information.

Do we receive any information from third parties?
We do not receive any information from third parties.

How do we process your information?
We process your information to provide and improve our Services, communicate with you, ensure security, prevent fraud, and comply with the law. We only process information when legally justified.
Learn more about how we process your information.

In what situations and with which parties do we share personal information?
We may share information in specific cases and with certain third parties.
Learn more about when and with whom we share your personal information.

How do we keep your information safe?
We take measures to protect your information. But no electronic method is 100% secure, and there's always some risk of unauthorized access.
Learn more about how we keep your information safe.

What are your rights?
Your location determines your privacy rights regarding your information.
Learn more about your privacy rights.

How do you exercise your rights?
To exercise your rights, submit a data subject access request or contact us. We will respond in line with data protection laws.
Find out how to exercise your rights.

For a deeper understanding of our practices, please review the privacy notice in full.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when:

Personal Information Provided by You:
The personal information we collect depends on the context of your interactions with us and the Services, your choices, and the products and features you use. This information may include.   

- Name
- Phone Number
- Email Addresses
- Mailing Addresses
- Job Titles
- Usernames
- Passwords
- Contact Preferences
- Contact or Authentication Data
- Billing Addresses
- Debit/Credit card Numbers

Sensitive Information:
We do not process sensitive information

Application Data:
If you use our application(s), we may also collect:
Geolocation Information: We may request access or permission to track location-based information from your mobile device, either continuously or while using our application(s). You can change these permissions in your device settings.
Mobile Device Access: We may request permission to access certain features on your mobile device, such as the camera, storage, reminders, microphone, contacts, calendar, Bluetooth, sensors, social media accounts, etc. Adjust these permissions in your device settings.
Mobile Device Data: We collect information like mobile device ID, model, manufacturer, operating system, version information, browser type, IP address, and related data. If using our application(s), we gather details on your phone network, device ID, and application(s) features accessed.
Push Notifications: We may request to send you push notifications regarding specific features. You can turn these notifications off in your device settings.

This data helps maintain our application(s)’s security and operations and aids in troubleshooting and internal analytics.

Information automatically collected
In Short: We collect data like your IP address and/or device characteristics automatically when using our Services.

When navigating our Services, we automatically gather certain information. This data doesn’t pinpoint your identity but may consist of device and usage information, such as:

- IP address
- Browser and device characteristics
- Operating system
- Language preferences
- Referring URLs
- Device name
- Country
- Location
- Information about how and when you use our Services
- Other technical information

This data is crucial for our Services' security, operation, internal analytics, and reporting.

Like many businesses, we also gather information via cookies and similar tech. The details include:

Log and Usage Data: This includes IP address, device info, browser type, interaction data, device events, error reports, and hardware settings.
Device Data: Data about the device you use to access our Services, like IP address, device and application IDs, browser type, hardware model, ISP/mobile carrier, operating system, and system configuration.
Location Data: Data about your device's location, precise or imprecise. The data amount depends on your device and its settings. We might use tech like GPS to determine your location (based on your IP address). You can refuse or disable this feature, but some Service aspects might become unavailable.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for various reasons, based on your interaction with our Services:

To facilitate account creation and authentication: We process your information for account creation, login, and maintaining its functionality.
To deliver and facilitate the delivery of services: Your information is used to provide the services you request.
To respond to inquiries and offer support: We handle your details to answer questions and resolve any service issues.
To send administrative information: Your data is used to inform you about our products, services, changes in our terms, policies, and other relevant details.
To enable user-to-user communications: If you use our features that allow communication with other users, we may process your information.
To request feedback: We might use your information to seek feedback and communicate with you about your experience with our Services.
To send marketing and promotional communications: Based on your preferences, we might process your information for our marketing efforts. You have the option to unsubscribe from our marketing communications at any time. For more details, refer to "WHAT ARE YOUR PRIVACY RIGHTS?" below.
To protect our Services: We use your data to ensure our Services remain safe and secure, which includes fraud monitoring and prevention.
To evaluate and improve our offerings: Your information helps us identify usage patterns, assess our promotional campaigns' effectiveness, and enhance our Services, products, marketing strategies, and user experience.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations as detailed below and/or with specific third parties.

We might share your personal information under the following circumstances:

Business Transfers: Should there be any mergers, sales of company assets, financing, or acquisition of our business, in full or in part, to another entity, we may share or transfer your data.
When using Google Maps Platform APIs: In instances where we utilize certain Google Maps Platform APIs (e.g., Google Maps API, Places API), we might share your information.
Other Users: Be cautious when you disclose personal details in public areas of our Services (e.g., through comments, contributions, or other content). This information can be accessed by all users and might also become publicly available outside our Services indefinitely. Also, other users can view descriptions of your activities, engage with you within our Services, and observe your profile.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking tools to gather and save your information.

We might use cookies and other similar tracking technologies (such as web beacons and pixels) to obtain or save information. For specific details about our use of these technologies and how you can decline certain cookies, please refer to our Cookie Notice.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We store your information as long as needed for the purposes highlighted in this privacy notice, unless the law dictates otherwise.

We retain your personal information only as long as necessary for the purposes detailed in this privacy notice, unless the law mandates or allows for a more extended retention period (e.g., for tax, accounting, or other legal reasons). None of the purposes mentioned in this notice will necessitate retaining your personal information longer than the duration you maintain an account with us.

If we no longer have a valid business reason to process your personal information, we will either:
Delete or anonymize the data, or
If direct deletion or anonymization is unfeasible (e.g., if the data is in backup archives), securely store and isolate your personal information, preventing further processing until deletion becomes feasible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We utilize both organizational and technical measures to safeguard your personal data.

We have put in place suitable technical and organizational security procedures to help ensure the protection of any personal information we handle. However, it's essential to understand that no matter how stringent our protective measures are, no online data transmission or storage mechanism can be assured of 100% security. This means we cannot guarantee the absolute security of your data against potential breaches by hackers, cybercriminals, or other unauthorized entities.

While we are committed to defending your personal information, transmitting personal data to and from our Services always carries some level of risk. It's crucial to ensure you're accessing our Services in a secure setting.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We refrain from collecting data from or marketing to individuals under 18.

We do not intentionally gather data from or market to children below 18 years of age. When you use our Services, you are confirming that you are either 18 years or older, or that you have the approval of a parent or guardian for a minor's use of our Services. If it comes to our attention that we have inadvertently gathered information from users younger than 18, we will disable the relevant accounts and take steps to quickly erase this information. If you discover we might have information from someone under 18, please reach out to us at support@aboundfi.com

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have the right to oversee, modify, or close your account whenever you wish.

Withdrawing Consent: If our processing of your data is based on your consent, you can withdraw it at any moment. This won't impact prior processing done with your approval. To withdraw consent, see the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section.
Opting Out: You can opt out of marketing communications by following unsubscribe instructions in our emails or SMS, or by getting in touch as detailed below. Service-related communications will continue.
Account Information: To review or change your information, or to deactivate your account:
- Sign in and adjust your account settings.
- Contact us with the provided details.
Post your request to terminate your account, we'll deactivate it and remove your data. But, some information might remain in our records for specific purposes, like preventing fraud.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

To address your privacy rights concerns, please email us at support@aboundfi.com

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, as well as some mobile operating systems and mobile applications, include a Do-Not-Track ("DNT") feature or setting. This allows you to signal your privacy preference to not have data about your online browsing activities monitored and collected.

Currently, there is no uniform technology standard for recognizing and implementing DNT signals. Therefore, we do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Should an online tracking standard that we are required to follow be adopted in the future, we will update you on this practice through a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.)

CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
1. Every individual who is in the State of California for other than a temporary or transitory purpose and
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:

Category A: Identifiers
Examples:
Contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
Collected: YES

Category B: Personal Information Categories Listed in the California Customer Records Statute
Examples:
Name, contact information, education, employment, employment history, and financial information
Collected: NO

Category C: Protected Classification Characteristics Under California or Federal Law
Examples:
Gender and date of birth
Collected: YES

Category D: Commercial Information
Examples:
Transaction information, purchase history, financial details, and payment information
Collected: NO

Category E: Biometric Information
Examples:
Fingerprints and voiceprints
Collected: NO

Category F: Internet or Other Similar Network Activity
Examples:
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
Collected: NO

Category G: Geolocation Data
Examples:
Device location
Collected: NO

Category H: Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
Examples:
Images and audio, video or call recordings created in connection with our business activities
Collected: NO

Category I: Professional or Employment-Related Information
Examples:
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
Collected: NO

Category J: Education Information
Examples:
Student records and directory information
Collected: NO

Category K: Inferences Drawn from Other Personal Information
Examples:
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
Collected: NO

Category L: Sensitive Personal Information
Collected:
NO

Usage and Retention of Collected Personal Information:
Category A:
We will retain the collected personal information as long as the user has an account with us.
Category C: We will retain the collected personal information as long as the user has an account with us.

We may also collect other personal information through:
- Receiving help through our customer support channels.
- Participation in customer surveys or contests.
- Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete:
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law. These exceptions may include, but are not limited to, the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know:
Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information.
- The categories of personal information that we collect.
- The purposes for which the collected personal information is used.
- Whether we sell or share personal information to third parties.
- The categories of personal information that we sold, shared, or disclosed for a business purpose.
- The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose.
- The business or commercial purpose for collecting, selling, or sharing personal information.
- The specific pieces of personal information we collected about you.

Please note, in line with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request. Nor are we obligated to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights:
We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information:
We do not process consumer's sensitive personal information.

Verification Process:
Upon receiving your request, we will need to verify your identity. This verification process may require us to ask you to provide specific information for us to match with what is already in our system. Depending on the nature of your request, we may contact you through a previously provided communication method (e.g., phone or email). We may also employ other verification methods as the situation warrants.

The information provided in your request will solely be used for verification purposes. If we can't verify your identity from our existing records, we may request additional information for verification, security, or fraud-prevention reasons. This additional information will be deleted after we've completed the verification process.

Other Privacy Rights:
-
You may object to the processing of your personal information.
- You may request the correction of incorrect or outdated personal data or ask to restrict its processing.
- An authorized agent can be designated to make a request under the CCPA on your behalf. We may deny requests from agents not able to provide proof of their authorization in line with the CCPA.
- You can ask to opt out from future selling or sharing of your personal information to third parties. Following an opt-out request, we will act upon it within fifteen (15) days from its submission.

Contact Us:
To exercise any of these rights, you can reach out to us via email at support@aboundfi.com or refer to the contact details provided at the document's end. If you have concerns or complaints about how we manage your data, we welcome your feedback.

11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you are granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" refers to a natural person who is a resident of the Commonwealth acting only in an individual or household context. This term excludes a natural person acting in a commercial or employment context.
"Personal data" encompasses any information that can be linked or is reasonably linkable to an identified or identifiable natural person. It excludes de-identified data and publicly available information.
"Sale of personal data" denotes the exchange of personal data for monetary consideration.

If the definition of "consumer" applies to you, we must adhere to specific rights and obligations concerning your personal data.

The information we collect, use, and disclose about you will depend on your interaction with us and our Services. To learn more, please visit the following links:
- Personal data we collect
- How we use your personal data
- When and with whom we share your personal data

Your Rights with Respect to Your Personal Data:
1. Right to be informed about whether or not we process your personal data.
2. Right to access your personal data.
3. Right to correct inaccuracies in your personal data.
4. Right to request the deletion of your personal data.
5. Right to obtain a copy of the personal data you've previously shared with us.
6. Right to opt out of the processing of your personal data if used for targeted advertising, the sale of personal data, or profiling that results in decisions producing legal or similarly significant effects ("profiling").

Note: We have not sold any personal data to third parties for business or commercial purposes, nor do we plan to do so in the future for website visitors, users, and other consumers.

Exercise Your Rights under the Virginia CDPA:
For further details about our data collection and sharing practices, please refer to this privacy notice.

To contact us, you can:
Email us at support@aboundfi.com

Should you choose to use an authorized agent to exercise your rights, we might deny the request unless the agent presents valid proof of their authorization to represent you.

Verification Process:
We might ask for additional information, deemed reasonably necessary, to confirm your identity and the nature of your request. If a request comes via an authorized agent, we may seek more details to validate your identity before proceeding.
Upon receiving your request, we will respond promptly, ensuring a reply within forty-five (45) days. If necessary, this response period can be extended by another forty-five (45) days. Should this occur, we will notify you of the extension and the reasons behind it within the first 45-day period.

Right to Appeal:
Should we decide not to act on your request, you will be informed of our decision and the reasons for it. If you disagree with our decision, please email your appeal to support@aboundfi.com. Within sixty (60) days of receiving an appeal, we will notify you in writing about any action taken or not taken in response to the appeal, including a written explanation for the decision. If your appeal is denied, you have the right to contact the Attorney General to lodge a complaint.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@aboundfi.com or contact us by post at:

Abound Financial Technologies Inc.
46 Pine Knoll Dr
Suite A1
Greenville, SC 29609
United States

14. CONTENT MODERATION AND USER RESPONSIBILITY (ChMS)

1. Scope of Content Moderation:
Abound ChMS is a Church Management System designed to facilitate administrative and community engagement functionalities for churches. It is not a social media platform. As such, the responsibility for content moderation within the app lies solely with the respective church administrators using our system.

2. Administrator Responsibility:
Each church, through its designated administrators, is responsible for managing and moderating the content shared within its specific instance of the application. Administrators have access to tools and features within the platform enabling them to moderate content effectively, ensuring a safe and respectful environment for all users.

3. Content Guidelines:
While each church is responsible for setting its content guidelines in line with its values and principles, we expect all users and administrators to maintain a respectful and inclusive environment within the app. Any content deemed harmful, abusive, discriminatory, or offensive is strictly prohibited and should be addressed promptly by the administrators.

4. User Reporting:
Users have the right to report any content they find inappropriate or harmful. It is the responsibility of the respective church administrators to review these reports promptly and take appropriate action, which may include removing the content or implementing disciplinary measures, as necessary.

5. Our Role:
Abound Financial Technologies Inc. provides the platform and tools necessary for effective content moderation but does not directly moderate content. However, we reserve the right to take appropriate action, including removal of content or suspension of accounts, in cases where content violates applicable laws or regulations or this policy.

6. Changes to Content Moderation Policy:
We may update this content moderation policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We encourage users and administrators to review this policy regularly to stay informed about our content moderation practices.

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact our support team at support@aboundfi.com

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