DEBTFREE.COM PRIVACY POLICY

Last updated: August 2018

This Online Privacy Policy (hereinafter sometimes referred to as the “Notice”) applies to this DebtFree.com online interface (i.e., website or mobile application) and any DebtFree.com affiliate or subsidiary online interface that links to this Notice, (each, a Site, and, collectively, Sites). The term DebtFree.com or “we” or “us” or “our” in this Notice refers to affiliates or subsidiaries of DebtFree.com that link to this Notice. This Notice describes how Sites may collect, use and share information from or about you, and explains how information may be collected and used for advertising purposes.

DebtFree.com may provide other online interfaces not covered by this Notice. If you visit or access your services from one of these sites, please review the online privacy practices of that site to understand how your online information may be collected, used and shared.

Agreement to this Policy: By using this Site you consent to this Online Privacy Policy, including your consent to our use and disclosure of information about you in the manner described herein.

We will use and share any information that we collect from or about you in accordance with DebtFree.com‘s Privacy Policy, which provides choices in the use and sharing of information. The terms and conditions of this Notice control, and by using the Site, you agree to the terms and conditions of this Notice.

Collecting and Using Information

Registration and Other Information Provided to Us

When you subscribe to or visit DebtFree.com, you may be asked to disclose personally identifiable information. You may also choose to submit personally identifiable information to us when you send us an email. You acknowledge and agree that we may use and store any such information about you in accordance with our Privacy Policy. We may also process and store your personally identifiable information on a server located outside of your jurisdiction. By providing your Personally Identifiable Information to us, you consent to the transfer of your information across national boundaries. If you do not consent to such transfer as well as the processing and storage of your personally identifiable information outside your jurisdiction, you should not provide such information to us.

Personal Information We Collect Online

Personal Information means personally identifiable information such as information you provide via forms, surveys, applications or other online fields including name, postal or email addresses, telephone, fax or mobile numbers, or account numbers.

How We Use Personal Information

We may use Personal Information:

How Personal Information is Shared

When you submit personally identifiable information to us (which may include first name, last name, email address, zip code and contact phone number), we share this information with 3rd party service providers for the products that you were requesting assistance with and may also be used for cross-marketing purposes with affiliates for offers that we believe may be of benefit to you, based upon your initial request.

We also share non-personally identifiable information about our user base with our advertising affiliates who drive traffic to our website to help them identify and target our ideal customer. We may also share your contact information with third-parties who may contact you for a free, no-obligation consultation. A list of companies with whom we may share your information is here.

Other Information We Collect Online

Other Information is any information other than Personal Information that does not reveal your specific identity or does not directly relate to an individual, such as browser information, information collected through cookies, pixel tags and other technologies, demographic information, other information provided by you such as your date of birth or household income, and aggregated and de-identified data.

How We Collect and Use Other Information

We and our third-party service providers may collect and use Other Information in a variety of ways, including:

Additional Information

Third party widgets – We may allow certain widgets (e.g., social share buttons) on our Sites that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your browsing on pages of our Sites where these widgets are placed. You may wish to review information at the third party site, such as social media platforms where you have an account, to determine how these third parties collect and treat such information. Also, see Linking to other sites and Social media sites below.

Retargeting – As you browse https://www.DebtFree.com, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partners, enable us to present you with retargeting advertising on other sites based on your previous interaction with https://www.DebtFree.com and affiliated pages and sites. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number.

Google Interest Based Advertising Program – In order to enhance your experience when you visit our website, we participate in the Google Interest-based Advertising Program (“Program”) to ensure the advertisements on this Site correspond to your interests. We do this by working with Google and other Program participants who, like us, place ads on our Site and those of other Program Participants. We then share the information we collect using Web Cookies placed in your browser in order to provide you with targeted advertising when you visit the Site. You may opt out of Google’s use of cookies by visiting the Google Advertising Opt-Out Page.

Third-Party Web Beacons – We use third-party web beacons from Yahoo! to help analyze where visitors go and what they do while visiting our website. Yahoo! may also use anonymous information about your visits to this and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo! click here or visit http://info.yahoo.com/privacy/us/yahoo/opt_out/targeting/details.html.

The Facebook Companies – Facebook owns and operates each of the companies listed below, in accordance with their respective terms of service and privacy policies. We may share information about you within our family of companies to facilitate, support and integrate their activities and improve our services. For more information on the Facebook Companies’ privacy practices and how they treat individuals’ information, please visit the following links:

Opt-Out Policy, Your Newsletter and Email Subscriptions

You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. Client service-related communications are an integral part of the services you receive from us and you may continue to receive such service-related emails unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided. You may also opt-out of receiving our newsletter or marketing emails by contacting us at [email protected] or by replying to an existing email with your request to be removed from the mailing list.

Short Message Service

We may make available a service through which you can receive financial advice on your wireless device via short message service (“SMS Service”). Data obtained from you in connection with this SMS service may include your name, address, cell phone number, your provider’s name, and the date, time, and content of your messages. You represent that you are 18 years of age and the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges. In addition to any fee of which you are notified, your provider’s standard message and data rates may apply to our confirmation and all subsequent SMS correspondence. All charges are billed by and payable to your mobile service provider. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. SMS message services are provided on an AS IS basis. We may also obtain the date, time and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service in accordance with this Privacy Policy. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies.

You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. You must have a two way text-enabled phone with compatible carrier and plan. Compatible major carriers include Alltel Wireless, AT&T, Boost Mobile, Nextel, Sprint, T-Mobile, Verizon Wireless and Virgin Mobile USA. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. We may also access the content of your account and wireless account with your carrier for the purpose of identifying and resolving technical problems and service-related complaints.

By joining our subscription program you authorize us to send you autodialed marketing text messages at the mobile number provided. Consent isn’t required to purchase goods or services.

You may remove your information by emailing us at [email protected] by replying or sending “STOP”, “END”, “QUIT”, “UNSUBSCRIBE”, or “CANCEL” to the Company.

Advertising

DebtFree.com advertises online (e.g., pages within our Sites and mobile apps through company managed social media presences, and on other sites and mobile apps not affiliated with DebtFree.com) and offline (e.g. through call centers, and direct marketing). In order to understand how advertising performs, we may collect certain information on our Sites and other sites and mobile apps through our advertising service providers using cookies, IP addresses, and other technologies. The collected information may include the number of page visits, pages viewed on our Sites, search engine referrals, browsing activities over time and across other sites following your visit to one of our Sites or apps, and responses to advertisements and promotions on the Sites and on sites and apps where we advertise.

DebtFree.com uses information described in this Notice to help advertise our products and services in a variety of ways. We use such information to:

How we tailor ads:

Relationship based advertising

In order to help make our advertising informative and useful, we may use information about your relationship with us (such as types of services, transactional information or the state in which you reside) to help determine which advertisements or offers to present to you.

Online Behavioral Advertising

We or our advertising service providers may use certain information about your activities on our Sites, such as pages visited and search key words entered to help determine which of our advertisements or offers may be of interest to you. We limit access and collection of information for specific purposes by advertising service providers. We may use this online information for online and offline advertising, which we may feel will be a benefit to you.

Advertising on third party sites and mobile apps

DebtFree.com may contract with advertising companies to advertise our products and services on sites and mobile apps not affiliated with us. We may use Aggregated and De-identified Data and information provided by you to these third-party sites and mobile apps to select which of our advertisements or offers may appeal to you, display them to you and monitor your responses. Third Party sites and mobile apps are not subject to DebtFree.com Privacy Notices. Please visit the individual sites and mobile apps for additional information on their data and privacy practices and opt out policies.

Online Behavioral Advertising on third party sites and mobile apps

Some of our tailored ads are online behavioral advertising and may be served using data collected by third party providers. Ads served on our behalf by these companies do not contain unencrypted Personal Information and we limit the use of information by companies that serve our ads. To learn more about this practice and your choices in connection with it, see the section Advertising Choices below.

Advertising Choices

You may set your choices for advertising in the following ways:

Online Behavioral Advertising: If you prefer that we not use information based on online Site behavior to provide online and offline tailored content and advertising, you may opt out of online behavioral advertising by emailing us your request at [email protected].

DebtFree.com Managed Direct Marketing: If you prefer that we not deliver you marketing offers in email, postal mail or through telemarketing you may manage your direct marketing choices by emailing us your requests at [email protected] or writing to us at DebtFree.com, 6360 NW 5th Way, Suite 302, Fort Lauderdale, FL 33309.

Important Reminder

In order for online behavioral advertising opt outs from our Sites and on other sites to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access our Site or other sites from a different device, login under a different screen name, or change web browsers, you will need to opt-out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser’s security settings to validate whether scripting is active or disabled.

Linking to other sites

We may provide links to third party sites. If you follow links to sites not affiliated or controlled by DebtFree.com, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites. DebtFree.com does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.

Social media sites

DebtFree.com provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. Any content you post on official DebtFree.com managed social media pages, such as pictures, information, opinions, or any Personal Information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. Please refer to them to better understand your rights and obligations with regard to such content. In addition, please note that when visiting any official DebtFree.com social media pages, you are also subject to DebtFree.com‘s Privacy Notices.

Security

To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third party service providers to ensure information remains confidential and secure. While we follow generally accepted industry standards to protect the personal information submitted to us (both during and once we receive it), no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our website, you can e-mail us at [email protected].

Using other aggregation websites

Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to Personal Information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any Personal Information accessed by any company or person to whom you provide your Site username and password.

If you provide your Site username, password or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide, whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for the Site to ensure that the aggregation website cannot continue to access your account.

Making sure information is accurate

Keeping your information accurate and up to date is very important. If your information is incomplete, inaccurate or not current, please email or write to us at the appropriate address for changes listed on your service materials as provided by us.

Business Transitions

In the event that DebtFree.com goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via prominent notice on our website for 30 days of any such change in ownership or control of your personal information, as well as any choices you may have regarding your personal information.

California Do Not Track Disclosures

How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services

We currently do not respond to DNT signals in browsers because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit www.DebtFree.com?

No.

Notice to California Residents

In response to a California law, we will automatically treat accounts with California billing addresses as if you requested DebtFree.com to not share your information with nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us.

Residents of the State of California may request a list of all third-parties to which this website has disclosed certain information during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at [email protected].

For all requests, you must put the statement “California Shine the Light Privacy Request” in the body of your request, as well as your name, street address, city, state, and zip code. Please note that we are not responsible for requests that are not labeled or sent properly, or that do not have complete information.

Notice to Vermont Residents

In response to Vermont regulations, DebtFree.com automatically treats accounts with Vermont billing addresses as if you requested that DebtFree.com not share your information with nonaffiliated third parties, and that DebtFree.com limit the information it shares with its affiliates. If DebtFree.com discloses information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

Notice to Nevada Residents

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions set forth above. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: [email protected].

Notice to Users Outside of the United States

This Online Privacy Policy is intended to cover collection of information on our websites from residents of the United States. If you are visiting our websites from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third-parties with whom we share it as described in this Notice.

Protecting children’s privacy online

The Site is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Site. We do not knowingly collect information from children under 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA). If you believe that DebtFree.com has received information from a child or other person who is not a majority age in their relevant jurisdiction, please contact us at our e-mail or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information.

Protecting individual health information

To the extent that we receive, maintain, or process an individual’s protected health information, DebtFree.com may disclose that information as authorized by and in accordance with applicable federal and/or state law.

Updates to this Privacy Notice

This Online Privacy Notice is subject to change. Please review it periodically. If we make changes to the Privacy Notice, we will revise the “Last Updated” date at the top of this Notice. Any changes to this Notice will become effective when we post the revised Notice on the Site. Your use of the Site following these changes means that you accept the revised Notice.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us at [email protected] or write us at:

DebtFree.com
6360 NW 5th Way, Suite 302, Fort Lauderdale, FL 33309

PLEASE PRINT AND RETAIN A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS.