Privacy Policy

Date Last Revised: April 1, 2021

Overview

Nickels, Inc. (“Nickels”, “we” or “us”) knows that your privacy and protecting your personal information is important to you. It’s also important to us. This Privacy Policy describes how we protect your personal information when you visit the website and use the credit card and loan monitoring and guidance service located at asknickels.com (the “Service”), and forms part of our Terms of Service.

The Information We Collect at Your Request

We may collect and process the following personal data from you in order to provide the Service:

• When you first create an Account to use our Services, we will collect your email address, and password. If you want us to send you text message reminders, we will need your phone number.
• For student loans specifically, if you want us to access your “MyStudentLoan.csv” file from your Federal Student Aid (“FSA”) account, we will collect your FSA login information for that account, and of course, all of the information in your MyStudentLoan.csv file, which includes your student loan information, the status of your loans, the amount of your loans, and the education institutions you have attended.
• If you want us to collect information on the status of your credit cards or loans through your credit card provider(s) or loan servicer(s) (“your creditor(s)”), you will have to connect us to that account by providing us with login information or your account number at your creditor(s). By connecting us to your creditor account you authorize us to retrieve information from your creditor when you connect us into that account. The information we may retrieve from your creditor(s) includes information such as when your next bill is due, what the bill amount due is, and what payments you have already made.
• We may use Plaid Technologies, Inc. ("Plaid") to verify and retrieve your creditor(s) account information. We only share your information with Plaid in accordance with this Privacy Policy. Information shared with Plaid is treated by Plaid in accordance with its privacy policy, available at https://plaid.com/legal/.
• We also collect personal information from you when you answer questions in our System that helps us to guide you on your credit cards and loans.
• In order to better support you, if you make an inquiry through our website, or contact us in any other way, we will keep a copy of your communications with us.

Nickels’ Day-to-Day Use and Disclosure of Data Identifying You

Simply put, we do not and will not sell or rent your personal information to anyone, for any reason, at any time.

Specifically with respect to the login information for your FSA account in connection with student loans, we use that information only to periodically download your “MyStudentLoan.csv” file from your Federal Student Aid account to your Account on our Service.

With respect to the login information for your creditor accounts, we will use that information only to retrieve your credit card and loan information to load into your Account on our Service.

Except in extraordinary cases, as we discuss below, Nickels uses and discloses your personal information in a form that identifies you only for these purposes:

• to provide the Service to you, including running the Service and providing technical support to you, and making the Service more secure;
• to analyze the use of the Service so that we can improve it;
• to send you any emails, texts, or other communications relevant to your use of the Service, including sending reminders, customer surveys, or other communications you have requested that we send;
• unless you have opted out, to deliver communications about products and services that we or our partners can offer to you;
• to fulfill your request that we refer you to a particular financial service provider or vice versa, in order to apply for a financial made available by that service provider.
• for research, planning, and troubleshooting problems;
• to Plaid in order to retrieve your loan service account information, as described above;
• to other third-party contractors that provide services (e.g. email notifications) to Nickels and are bound by these same privacy restrictions;
• tto enforce Nickels’ Terms of Service;
• to inform the educational institution or financial services organization (if any) which referred you to Nickels that you have signed up for the Service; and
• as otherwise set forth in this Privacy Policy.

Nickels’ Use of Aggregated Personal Data That Doesn’t Identify You

Nickels may use and disclose anonymous or aggregate personal information, which does not identify you individually, to:

• Users of the Service for purposes of comparison to the broader community (for example, how much you owe in credit card debt or loans compared to an average credit card user or borrower);
• Organizations approved by Nickels for research about how to better support people with credit card debt, federal student loans and similar issues; and

How We Collect and Use Traffic and Log Data

Just like any website, Nickels may also collect certain technical information (collectively “Log Data”), that is naturally available when you use our Services. Log Data includes data like IP addresses, the kind of device uses to access the Services, browser type and operating system, referring URLs, and website usage patterns.

Log Data is primarily used to improve the design and functionality of the Service, and for security and similar purposes. We collect Log Data in a variety of ways

“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. Nickels may set and access cookies on your computer to track and store information about your preferences. Nickels may gather information about you through cookie technology. For example, Nickels may assign a cookie to you, to limit the amount of times you see a particular notification, or to keep you logged into the Service for a period of time. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Service may be impaired for you.

Some of our Service’s pages may contain electronic images known as Web beacons, which are also called single-pixel gifs. These images allow us to count users who have visited those pages. We also may include Web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal information but they are a technique we use to compile aggregated statistics. You may disable Web beacons in your emails by disabling HTML images in your email program, which may also affect other images in emails you receive.

Third Parties

We use third party service providers to help us analyze certain online activities. For example, these service providers may help us analyze visitor activity in the Service. We may permit these service providers to use cookies and other technologies to perform these services for Nickels. We do not share any personal information about our users with these third party service providers, and these service providers do not collect such information on our behalf. These services include:

• Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You may also download the Google Analytics opt-out browser add on, available here.

When we interact with you on social media services, the information you share with us which can be seen by anyone other than you, us and the relevant social media service is not covered by this Privacy Policy. Only information you share with us privately (i.e., through direct messages, private chat, etc.) is covered by this Privacy Policy.

Do Not Track

We do not respond to the Do Not Track setting in your browser. While we do not use cookies to collect personally identifiable information or track users’ online activities over time or across different web sites, certain of the third party tracking providers we use (e.g., Google) may be able to do so, though we do not have access to that information. For information regarding Do Not Track mechanisms, see http://allaboutdnt.com.

Disclosure to Protect Legal Rights or if Required by Law

Nickels reserves the right (and you authorize Nickels) to share or disclose your personal information when Nickels determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

• To prevent prohibited or illegal activities or harm to another person;
• When required by any applicable law, rule regulation, subpoena or other legal process; or
• To enforce our rights under this Privacy Policy or our Terms of Service

Change of Control or Selling Our Business

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control. If we sell, merge or transfer any part of our business, part of the sale may include your personal information.

Opting Out; Terminating Your Account; Deleting Data

You can opt out of most communications from us by so indicating in the relevant part of your Account profile, by clicking the opt-out link in emails, by emailing us at support@asknickels.com or by other methods that we may provide which match the communication method (e.g., texting STOP in reply to a text message from us). As long as you have an Account with us, we will need to send you certain administrative communications, so you can’t opt out of receiving those communications.

To terminate your relationship with us and delete your Account for the Service, you can email us at support@asknickels.com.

When you request us to delete your Account, your data will be permanently expunged from our primary production servers and further access to your Account will not be possible. However, portions of your data, consisting of aggregate data derived in part from your Account information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media until we overwrite it or deleted according to our standard practices. Nickels keeps these backups to ensure our continued ability to provide the Service in the event of malfunction or damage to our primary production servers. We may also retain Account information as required of us or our partners by applicable law or regulations or to comply with law enforcement.

Our Security Practices

We use a combination of authentication procedures, firewall barriers, and encryption techniques (for example, we always encrypt your data when it’s at rest in our servers, and we use “https” for secured web browsing), among others, to maintain the security of your online session and to protect Service accounts and systems from unauthorized access.

Your Login ID and Password

You are responsible for maintaining the security of your Login ID and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at support@asknickels.com and you should change your password immediately via the Service. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Policy or the Terms of Service.

No Users Under 16

We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at support@asknickels.com.

Information for Persons Outside the US

If you use our Service from outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law.

Updates

We update this Privacy & Security Policy periodically. The date last revised appears at the top of the Policy. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, a notice will be posted on the Service, a notification of the change will be posted in the Account login screen, and if we have your email address, we will attempt to reach you at that email address to inform you that the Privacy Policy has been changed. You are deemed to accept and agree to be bound by any changes to the Privacy Policy when you use the Service after those changes are posted.

Contact Us

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send us an e-mail at support@asknickels.com.