Privacy Policy

Last Updated on December 20, 2023

This Privacy Policy (this “Policy”) is intended to give you notice about how Divvy Homes Credit Services, LLC and its affiliated companies (collectively, “we,” “us” or “our”) collect, use, and share information in connection with your interactions with of our Services (which is defined in the “Introduction” section of our Terms and Conditions, available at /up/privacy-policy) It does not cover the privacy practices of third parties that we do not own or control.

This Policy encompasses data gathered directly and indirectly from your interactions with our Services, as well as information obtained from third-party sources. We may offer content from third parties, provide links to third-party websites or applications, or incorporate features enabling you to link your Account (which is defined in the “Registration and Accounts” section of our Terms and Conditions, available at /up/terms-and-conditions) to third-party accounts, such as financial institutions or social media platforms like Facebook. When engaging with a third-party feature, it is advisable to review the respective third-party's privacy policies and terms of service to ensure a clear understanding of how they collect and share information about you.

When you access or interact with our Services, you are agreeing to our Terms and Conditions, available at /up/terms-and-conditions. You are also consenting to and acknowledging receipt and understanding of our E-Sign Consent, available at /up/esign-agreement, including consenting to receive notifications concerning your privacy from us electronically.

By using our Services, you signify your acknowledgement of this Policy and consent to the privacy practices described in this Policy. You also agree to obtain annual notices and changes to this Policy electronically by visiting our privacy policy located at /up/privacy-policy.

How We Collect Your Information

We collect personal information from you directly or indirectly through our Services (for example, when you create an Account with us or access or interact with forms, applications, features, or other items offered through our Services or third parties relating to the Services), by communicating directly with you by telephone and by email, and when you contact our customer service. The personal information we collect depends on how you interact with us and third parties, and the products or services you obtain from us or third parties. We also collect personal information from third party sources, such as credit reports and credit scores from credit bureau partners, including TransUnion®.

Personal information that we may collect from you directly or indirectly includes the following:

• Your name, Social Security Number, mailing address, billing address, and phone number;
• Your application, user registration and log-in credentials, and third-party account log-in credentials;
• Demographic information;
• Information you provide for identity and device verification and/or to use features in our products or services;
• Financial account information, including your bank account information, balances, and credit or debit card or other payment account information when you purchase products and services from us;
• Information about the products and services you considered, obtained, or purchased in the past, and other consuming histories or tendencies;
• Information you provide when you communicate with us via email, chat, text (SMS), paper correspondence, and telephone (including voice recordings as permitted by applicable law when you speak with our representatives);
• Your credit profile, credit report, credit history, credit scores, including balances, payment amounts and history, and any other credit information;
• Your general feedback, comments, content, or posts submitted to us through any channel; and
• Device information such as publisher identifiers, web browser type, web browser plug-in details, operating system version, search engine referral, device type, and information collected through cookies and web beacons, such as pixels.

We automatically track and collect the personal information about you and your device(s), including your browser type, your operating system, your IP address and device identifiers, your browsing behavior, websites that you visit before or after our Services, and other technical data about you and your device(s).

Through our Services we may request your permission to also collect certain information from you on your mobile device (for example, your photographs, information about your contacts in an address book application, or your list of personal connections on a social network). If you give us permission to do so, we may share your personal information collected in this manner (subject to this Privacy Policy) and send communications to your contacts or social network connections about our Services and products available through our Services.

We may use certain information like your IP address or other device information or log Information to estimate your location (e.g., your city or state). Log information may also include things like your IP address, browser or device configuration, date and time of access and cookie information. We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance or provide our Services. We will only use these location-enabled services on your device with your consent. Failure to permit these location-enabled services on your device, however, may result in suspension, deactivation, or termination of the Services to you.

When you access or interact with our Services, we use "cookies," web beacons, and other data collection tools and behavioral information to track and gather personal information and customize our Services to you. Cookies are small files stored on your device by a web server. We may use both session cookies (that expire when you close your web browser) and persistent cookies (that stay on your device until you delete them). Our Services may use cookies from third parties (including third-party advertisers) that are placed on your device when you use our Services. These third parties may collect personal information through the use of cookies, web beacons, and other data collection tools to track your activity on the internet over time and across third-party websites when you use our Services. We may also use web beacons, such as “pixel tags,” and local storage, such as browser web storage or application data caches and databases. Pixel tags are a form of technology placed or embedded on a website or an email to monitor specific activities, such as website views or email openings. We may also obtain non-personal information, including information about you or your household that does not identify you personally, like your sex, gender, income, or what types of products and services you are interested in.

Third Party Information About You

Some of our Services rely on or use information about you obtained from third parties, such as credit reports and credit scores from credit bureau agencies like TransUnion®. We may collect personal information about you from third parties and commingle that information with information we collect in other ways. In particular, we may collect personal information about you when you use social networks, for example, when you post to your feed and when you log into our Services using your credentials from social networks or other third-party websites or applications (for example, when you authorize Facebook or Google to log in and create an account for you on our Services). We may also collect personal information about you from third-party service providers such as payment processors, financial institutions, and other businesses that we partner with to offer our Services or sell, solicit, or offer products through the Services, which may include account balance and transaction information, employment, asset, or other income data or insights into your credit profile. By doing this, we are able to provide you with more personalized recommendations, such as products or offers tied to your credit profile.

Depending on the products and services that you obtain from us, we may obtain information about you from others, such as:

• Information from other companies, business partners, affiliates, and third-party providers that enables us to provide or offer you products and services;
• If you provide information that enables us to access data from your financial and/or other accounts, we will obtain information from those accounts, including account details, individual payment transactions, balances, charges, fees, deposits, withdrawals, and other account and transaction details;
• Employment, asset, and income data or insights; and
• Credit reports, credit history, and credit scores from our credit bureau partners; and
• Information that you provide on a third-party website in order to obtain our products and/or services.

How We Use Your Information

We use your personal information to provide, promote, offer, operate, maintain, enhance, and improve our Services and products we offer (including conducting market research). We use the information we collect to provide you with credit reports and credit scores from our credit bureau partners. The information we collect may also be used to develop and present you with various other services and features like free credit monitoring, ID monitoring, trade lines and other loan products, tracking of your spending, and other personalized offer recommendations, products, and services. We may use your credit report, credit score, and other information we obtain to analyze, sort, and otherwise use certain information to present services, products, and features to you, which are offered by us, our partners, or third parties.

We use your personal information to communicate with you about our Services and products, about our company, and about your Account generally, including, but not limited to sending you credit reports, credit scores, identity protection, and transactional alerts to your e-mail, device, and/or phone number. We may use your personal information to send you promotional, marketing, and/or offer materials from some of our partners and third parties. We may use your personal information to provide you with customer service. We use your personal information to improve the security of our Services and to anticipate and respond to unauthorized, fraudulent, or unlawful activity. We may use your personal information to personalize the Services to you, including in communications to you through social networks and in advertising through our Services, social networks, and third-party services (including advertising on other websites that we do not operate).

If you give us permission on your mobile or other handheld devices, we may send you promotional, marketing, and non-promotional "push" notifications to such devices about our Services and products available on our Services. We also may send you browser notifications, emails, or physical mail.

Non-personal information refers to any information or data that does not disclose your identity, does not individually identify you, and/or pertains to a group of individuals. This includes information that is not personally identifiable, such as general demographic details, publicly available information, derived or inferred insights, or specifically expressed information. We retain the right to utilize, share, and disclose this information to third parties for any purpose.

We also reserve the right to store, access, use, preserve, transfer, or disclose, at any time without notice to you, any information (including personal information) as reasonably necessary to comply with any applicable law, regulation, subpoena, or legal process, or respond to any governmental requests and cooperate with law enforcement.

How We Share Your Information

We may share your personal information, including credit report, credit score, and credit profile information, with third-party vendors, consultants, real estate and loan professionals (including consumer loan providers), and other service providers, partners, third parties, or agents for the purpose of performing any of the activities, on our behalf or their own, that we are permitted to do under this Privacy Policy or our Terms and Conditions, available at/up/esign-agreement. These parties may use your personal information to identify offers or personalized recommendations for you, perform analytics, market our Services or their services, design, operate, or implement features or services and research or test feature and/or service improvements.

We also share your personal information with third parties when we send your information to a credit bureau to retrieve your credit report and/or credit score. We may share your personal information with our employees, independent contractors, consultants, agents, partners, and any parent, subsidiary, or affiliated business entity. We may share aggregated information and reasonably non-identifying information with third parties for advertising, industry research and analysis, demographic profiling, and other similar purposes, including any other reason that we are permitted to do under this Privacy Policy. We may also share your personal information with third parties to deliver relevant advertising and promotional offers to you. This includes advertising that is served by third parties to you on our behalf on other websites. Although we may use third parties to serve advertising to you (including, for example, personalized advertising served to you through Facebook), we do not control or review the technologies that those third parties may use on their websites (for example, cookies or web beacons, including pixel tags) to track and collect personal information about you. We may also share information like the feedback you submit to us if it relates to both our Services and a partner’s products. We may also share your personal information, in any other manner, with your consent.

If you interact with social network services (for example, by "liking" products available through our Services), certain public information, such as your image, name, and other information you choose to provide, may be displayed publicly and/or to your personal connections on social networks (for example, by posting to your feed or your connections’ feeds). Most social networks allow you to control what, if any, of your personal information is shared on those social networks. Please review the privacy policies and customizable settings of the social networks you belong to in order to learn more about controlling how your information is shared on those social networks.

We may also give you opportunities to interact with third-party partners through our Services, such as when we provide you with the opportunity to review and send your personal information to a partner in order to pre-populate your application on the partner’s website, when we send your personal information to partners in order to generate offers for you to review, when we send your application information directly to our partners, or when we send you to the partner’s website for you to provide the information directly to them. In some cases, if you click through to go to a partner’s website, you will automatically be sending your personal information to that partner. When this happens, you will still have to submit your application on the partner’s website. Information you provide to the partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.

We may also share with third parties de-identified or aggregated data we collect, such as de-identified or aggregated credit reports or credit scores, and de-identified demographic information. We share such information to analyze usage, develop shared services, and improve our own products and features.

We, our affiliates, business partners, and third-party providers collect, use, and share information to develop and deliver targeted advertisements online. These are ads that you may see across different websites and devices over time. This marketing information includes information such as your preferences and inferences based on your interactions with the applicable website and/or the Services.

We also use third-party providers to help us perform advertising-related functions such as measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads, and reduce ad fraud.

We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, merger, corporate change, sale or transfer of assets, or other business transaction.

Advertising and Analytics

We may from time-to-time contract with third-party vendors to provide advertisements on our behalf, via the internet or direct mail, to our customers and potential customers whom we think may be interested in our products or services. These third-party vendors may collect personal information about your visits to our Services using cookies or web beacons, such as pixels. These vendors may then pool the personal information that they collect from our Services with other sources of information, which may include your name and mailing address, for purposes of determining whether you might be interested in receiving direct mail.

For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. You may stop direct mailing from us at any time (see the Your Choices section below for details).

Terminating Your Account

You can suspend, deactivate, or terminate your Account by contacting us at up@divvy.com.

If you want to change your subscription options, as applicable, you can do so through account settings .

Your Choices

Cookies

If you do not wish for cookies to be placed on your computer, most web browsers permit you to prevent that from taking place. Additionally, information about opting out of cookie-based internet advertising can be found via the following link: http://optout.networkadvertising.org/. Please keep in mind, however, that these technologies are an important part of how our website works, so removing, rejecting, or limiting the use of cookies or other similar technologies might affect the availability and functionality of the Services.

Communications Preferences

To opt-out of receiving our direct mail, you may send us an email at up@divvy.com.

Text

We may communicate with you via text (SMS) messages at the phone number you provide. You may later opt-out of receiving SMS messages by responding to any SMS with one of the following single-word commands: “STOP” and “UNSUBSCRIBE.”

Push

We may send push notifications or alerts to your mobile or other handheld devices. You can deactivate push notifications and alerts at any time by unsubscribing from the app, changing your device settings, or changing the push notification settings within the app.

Email

We may send you promotional or marketing e-mail communications containing information about other products and services offered by us or other third parties. If you no longer wish to receive marketing or promotional e-mails from us, you may opt-out of receiving them by following the instructions included in the e-mails that we send you. If you opt-out, we will continue to send you account information and other transaction alerts via e-mail, and information related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions.

Google Analytics

We may use the Google Analytics Advertising Features as part of our marketing analytics and advertising. These features include remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations, and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time. Google provides users an opportunity to opt-out of the Google Analytics Features through Google’s Ads Settings and their web browser opt-out plugin, available at https://tools.google.com/dlpage/gaoptout. We do not control these opt-outs, which may be updated or removed by Google in accordance with its own policies.

Security

We take reasonable measures to protect the information that we collect from or about you (including your personal information) from unauthorized access, use, or disclosure. No method of transmitting information over the internet or storing information, however, is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Do Not Track Signals

Many web browsers and devices allow you to transmit "do not track" signals that express your preference not to be tracked across different websites and over time. We currently do not take action in response to "do not track" signals or other similar mechanisms.

Your California Privacy Rights

If you are a resident of California, your data privacy rights are protected under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”). The CCPA allows you to:

• opt out of marketing communications;
• request a copy of any information we have on file about you;
• request that we delete any information we have on file about you, including tracking and cookie data;
• opt out of having your data sold to third parties;
• opt out of sharing your information for cross-contextual advertising;
• limit the disclosure of your sensitive personal information; and
• opt out of automated decision-making/profiling when handling your information.

Please note that due to certain regulations, some data related to your account cannot be deleted.

If you are a California resident, we will provide you, upon your request, with a list of your personal information that has been shared with third parties for direct marketing purposes during the preceding calendar year and the identity of those third parties. To make such a request, contact us at the email or mailing address below in the Contact section. For more information, please review our California Consumer Privacy Notice, which is incorporated by reference into this Policy. Please note that these requests are only available to residents of California. If you are not a resident of California, we will not process your request.

Your Vermont Privacy Rights

If you are a resident of Vermont, we will not share your non-public personal information with non-affiliated third parties without your consent, other than as permitted by law. We will not share credit reports with our affiliates without your consent.

Our Policy Toward Children

While we may collect information about the children of our customers over the age of 18 years old, our Services are not directed to persons under 13 years old, and we do not knowingly collect personal information from persons under 13 years old. If we learn that we have collected personal information from a person under 13 years old, we will take steps to delete such information as soon as possible. If you are under 18 years old, you may not provide personal information to us.

Changes to this Privacy Policy

We may change this Privacy from time to time. If we change this Privacy, we will post the updated version on /up/privacy-policy and update the "Last Updated" date above.

Right to request deletion of information

You have the right to request in certain circumstances that we delete any personal information that we have collected directly from you. To protect our customers’ personal information, we are required to verify your identity before we can act on your request. We may, however, retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We require certain types of information so that we can provide our Services. If you ask us to delete it, you may no longer be able to access or use our Services. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

You may email us at up@divvy.com to request the deletion of your personal information.

Contact

To contact us about this Privacy, please email us at up@divvy.com or send us your information at: