End User Consent and Privacy Policy

Spinwheel’s Mission

Our mission at Spinwheel is to empower Americans by delivering access to, insights and tools for their financial accounts, including loans in repayment with loan service providers. Our technology provides an easy way for you to connect your financial accounts to software applications that can help you do things that can get out of debt sooner, save money, transfer funds, initiate donations, and create wealth. These applications are built and provided by our business customers (known as “developers” here), and powered by Spinwheel. By delivering access to high-quality, usable loan service account data that we’ve translated and standardized, and tools to transact, we enable developers to focus on building experiences that benefit you.

This Policy

Our goal with this Policy is to provide a simple and straightforward explanation of what information Spinwheel collects from and about end users (“End User Information”), 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 End User Information.

Please note that this Policy only covers the information that Spinwheel collects, uses, and shares. It does not explain what developers do with any End User Information we provide to them (or any other information they may collect about you separately from Spinwheel). This Policy also does not cover any websites, products, or services provided by others. We encourage you to review the privacy policies or notices of developers or those third parties for information about their practices.

Consent

Our services are associated with a program provided to you by a Developer and a separate agreement between you and the Developer. We have no responsibility for products and services offered by the Developer and are not liable to you for any harm, damage or loss arising from your use of the products and services provided through the Developer’s program.

BY CLICKING “CONTINUE” AND ENTERING YOUR FINANCIAL ACCOUNT CREDENTIALS YOU

• ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS CONSENT AND PRIVACY POLICY;

• GRANT SPINWHEEL A LIMITED POWER OF ATTORNEY FOR THE FOLLOWING EXPRESS PURPOSES:

  • CONSENT AND DIRECT SPINWHEEL TO ACT ON YOUR BEHALF AS YOUR AGENT TO COMPLETE PAYMENTS ON YOUR LOAN SERVICE PROVIDER ACCOUNT, INCLUDING THROUGH ADDITION OF THE DEVELOPER AS AN AUTHORIZED PAYOR ON YOUR LOAN SERVICE PROVIDER ACCOUNT, AND USING YOUR FINANCIAL ACCOUNT IN ACCORDANCE WITH YOUR INSTRUCTIONS;

  • CONSENT AND AUTHORIZE SPINWHEEL TO ACT ON YOUR BEHALF AS YOUR AGENT TO INSTRUCT YOUR LOAN SERVICE PROVIDER TO PROCESS AND ORIGINATE ELECTRONIC ACH DEBITS AND CREDITS IN ACCORD WITH YOUR INSTRUCTIONS TO A DEVELOPER;

  • CONSENT AND AUTHORIZE SPINWHEEL TO RETRIEVE ON YOUR BEHALF AS YOUR AGENT YOUR ACCOUNT TRANSACTION HISTORY, BALANCE INFORMATION AND/OR INFORMATION MAINTAINED BY YOUR LOAN SERVICE PROVIDER OR FINANCIAL ACCOUNT PROVIDER (FINANCIAL PRODUCT AND SERVICE PROVIDERS) IN ACCORDANCE WITH YOUR DEVELOPER’S OFFERINGS. IN CONNECTION WITH THIS RETRIEVAL YOU EXPRESSLY AUTHORIZE YOUR FINANCIAL PRODUCT AND SERVICE PROVIDERS TO DISCLOSE YOUR INFORMATION TO US.

THIS LIMITED POWER OF ATTORNEY SHALL REMAIN IN EFFECT UNTIL THE EARLIER OF: (1) YOUR WITHDRAWAL OF CONSENT, OR (2) FOR AS LONG AS NECESSARY FOR SPINWHEEL TO PROVIDE ITS SERVICES TO DEVELOPER.

• YOU ACKNOWLEDGE THAT SPINWHEEL DOES NOT REVIEW AND IS NOT RESPONSIBLE FOR THE INFORMATION FROM YOUR FINANCIAL PRODUCT AND SERVICES PROVIDERS, RATHER, YOU ACKNOWLEDGE THAT SUCH INFORMATION SPINWHEEL MOST RECENTLY ACCESSED AND MAY NOT REFLECT PENDING TRANSACTION OR OTHER RECENT ACTIVITY.

• REPRESENT AND WARRANT THAT YOU HAVE THE RIGHT, POWER, AND AUTHORITY TO ENTER INTO THIS CONSENT AND PRIVACY POLICY;

• ACCEPT THIS CONSENT AND PRIVACY POLICY AND AGREE THAT YOU ARE LEGALLY BOUND BY ITS TERMS.

Our Data Practices

Information We Collect and Categories of Sources

As explained in greater detail below, Spinwheel has collected identifiers, commercial information, electronic network activity information, professional information, inferences, and other types of End User Information.  The information we collect automatically or through other mechanism other than your provision of information to us, may include personal information, or we may maintain or associate it with personal information we collect.  End User Information that identifies you personally is treated as personal information.

Information you provide. 

When you connect your loan service provider account and/or financial accounts with a developer application or otherwise connect your financial accounts through Spinwheel, where applicable, we collect identifiers and login information required by the provider of your account, such as your username and password, or a security token. In some cases, we also collect your phone number, email address, security questions and answers, and one-time password (OTP) to help verify your identity before connecting your financial accounts. When providing this information, you give the developer and Spinwheel the authority to act on your behalf to access and transmit your End User Information from the financial product and service providers. You may also provide us with identifiers and other information, including your name, email address, and phone number, when you contact us or enter any such information on our websites.

Information we collect from your financial accounts.

The information we receive from the financial product and service providers that maintain your accounts varies depending on the specific Spinwheel services developers use to power their applications, as well as the information made available by those providers. But, in general, we may collect the following types of identifiers, commercial information, and other personal information from your financial product and service providers:

• Account information, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, and account and routing number;

• Information about an account balance, including current and available balance;

• Information about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;

• Information about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;

• Identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information;

• Information about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and

• Professional information, including information about your employer, in limited cases where you’ve connected your payroll accounts.

The data collected from your financial accounts includes information from all your accounts (e.g., checking, savings, and credit card) accessible through a single set of account credentials.

Information we receive from your devices.

When you use your device to connect to our services through a developer’s application, we receive identifiers and electronic network activity information about that device, including IP address, hardware model, operating system, which features within our services you access, and other technical information about the device. We may also use cookies or similar tracking technologies to collect usage statistics and to help us provide and improve our services. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.  This website does not respond to do not track signals.

Information we receive about you from other sources. 

We also receive identifiers and commercial information about you directly from the relevant developer or other third parties, including our service providers, bank partners, and identity verification services. For example, developers may provide information such as your full name, email address, phone number, or information about your financial accounts and account transactions.

Inferences we derive from the data we collect. 

We may use the information we collect about you to derive inferences. For example, we may infer your location or your projected income based on the information we have collected about you from other sources.

How We Use Your Information

We use your End User Information that consists of your personal information for a number of business and commercial purposes, including to operate, improve, and protect the services we provide, and to develop new services. More specifically, we use your personal information:

• To operate, provide, and maintain our services;

• To improve, enhance, modify, add to, and further develop our services;

• To protect you, developers, our partners, Spinwheel, and others from fraud, malicious activity, and other privacy and security-related concerns;

• To develop new services;

• To provide customer support to you or to developers, including to help respond to your inquiries related to our service or developers’ applications;

• To investigate any misuse of our service or developers’ applications, including violations of our Developer Policy, criminal activity, or other unauthorized access to our services; and

• For other notified purposes with your consent.

How We Share Your Information

We share your End User Information that consists of personal information for a number of business purposes:

• With the developer of the application you are using and as directed by that developer (such as with another third party if directed by you);

• To enforce any contract with you;

• With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or developers;

• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);

• In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);

• Between and among Spinwheel and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;

• As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, developers, our partners, Spinwheel, and others; or

• For any other notified purpose with your consent.

We may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

We do not sell or rent personal information that we collect.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: 490 43rd Street Unit 24 Oakland, CA 94609 / legal@spinwheel.io. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Our Retention Practices

We retain End User Information that is personal information for no longer than necessary to fulfill the purposes for which it was collected and used, as described in this Policy, unless a longer retention period is required or permitted under applicable law. As permitted under applicable law, even after you stop using an application or terminate your account with one or more developer, we may still retain your information (for example, if you still have an account with another developer). However, your information will only be processed as required by law or in accordance with this Policy.

Please refer to the “Your Data Protection Rights” section for options that may be available to you, including the right to request deletion of End User Information. You can also contact us about our data retention practices using the contact information below.

Choices About How We Use and Disclose Your Information

Accessing and Correcting Your Information

You can review and change your personal information through the mechanisms provided by the Developer in connection with the services offered through the Developer.

You may also send us an email at legal@spinwheel.io to request access to, correct or delete any personal information that you have provided to us. Our ability to modify your personal information or delete your personal information will be dependent on the services offered through your Developer and the financial product and service providers.  We may direct you to contact the Developer or financial product and services providers directly.

Withdrawal of Consent

You may withdraw your consent authorizing us to carry out previously authorized activities by clicking here, or by contacting the Developer directly.

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 Spinwheel’s website at https://www.spinwheel.io/legal and update the effective date at the top of this Policy. We will also notify developers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify their end users about such changes to this Policy, as appropriate.

Contacting Spinwheel

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at hello@spinwheel.io or by mail at 490 43rd Street, Unit 24 Oakland, California 94609.