Spritz Privacy Policy
If you visit any of our websites, download or use our web-hosted user interface located at https://www.spritz.finance (“App”), (together, our “Services”), Spritz Finance, Inc. ("Spritz," "we," "us," and "our") will ask for, collect, and store personal information about you (your “Personal Data”). We would not be able to provide our Services to you without the Personal Data you provide us, which is why we want you to know that we take our responsibility to protect your Personal Data very seriously. We also want to make very clear how we use your Personal Data so that you can make informed choices about your use of our Services.
This document (our “Privacy Policy”) explains how we collect and use your Personal Data, how and with whom we share your Personal Data, and how we protect your Personal Data. This Privacy Policy is subject to the Spritz Terms of Use available at [company terms website]. If you have questions about this Privacy Policy, or have suggestions for how we can improve it, please contact us at support@spritz.finance.
If you do not want us to collect Personal Data from you or share Personal Data with any third parties or otherwise disclose your Personal Data, you should not use the App, visit our website, or apply or use our Services.
Collection of Information
In the table below, we provide the list of categories of Personal Data that Spritz has collected within the last twelve months and some examples for a better understanding. We also have identified the main sources and purposes for collection:
1. Identifiers
Examples: First and last name and middle initial, date of birth, email address, mobile telephone number, mailing address, username,password, or other account access credentials.
Sources of Personal Data:
- Consumer directly (e.g. forms you complete or services you obtain from us)
- Third parties
Purposes for Personal Data Collection:
- Keep track of the Personal Data associated with your Spritz Account
- Help you access and restore access to your Spritz Account
- Prevent others from accessing your Spritz Account
- Send administrative information to you
- Detect and prevent fraud and/or funds loss
- Engage in marketing activities
2. Customer Records
Examples: Unique identifiers associated with your biller accounts including mortgage account information, credit card account numbers, Ethereum and/or Polygon wallet address.
Sources of Personal Data:
- Consumer directly (e.g. forms you complete or services you obtain from us)
- Third parties
Purposes for Personal Data Collection:
- Determine your eligibility for our Services
- Recommend other products and services to you
- Permit our financial partners to verify your identity
- Permit us and our financial partners to comply with applicable consumer protection laws
- Detect and prevent fraud and/or funds loss
- Provide our Services to you and our customers
- Enhance security, monitor and verify identity or service access, combat spam or other malware or security risks
- Enforce our terms in our Terms of Use and other agreements
3. Internet or other electronic network activity information
Examples: Browser type, IP address, computer or mobile device unique ID number, operating system, referring and exit pages, device event information.
Sources of Personal Data:
- Consumer indirectly (e.g. from activity on our websites or App)
Purposes for Personal Data Collection:
- Analytics
- Advertising and marketing
- Keep our websites and App safe and secure
- Improve our services
- Ensure network and information security
4. Geolocation Data
Examples: Approximate location based on IP address
Sources of Personal Data:
- Consumer indirectly (e.g. from activity on our websites or App)
Purposes for Personal Data Collection:
- Analytics
- Determine your eligibility for our Services
Sharing of Information
Except as described in this Privacy Policy and unless otherwise expressly authorized by you in writing, Spritz will never share, sell, or communicate your Personal Data to or with anyone for any reason. We only share and disclose your Personal Data with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection.
1. Service Providers
Why we share your Personal Data?
We may share your Personal Data with service providers including third party vendors, consultants, contractors in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
Specifically, we share your Personal Data with Plaid Financial. For more information on how Plaid deals with personal data, please refer to their privacy policy located at https://plaid.com/legal/#consumers.
Is Personal Data shared for a business purpose?
- Yes
2. Purchasers of Our Business
Why we share your Personal Data?
We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Is Personal Data shared for a business purpose?
- Yes
3. Law Enforcement
Why we share your Personal Data?
We may share your Personal Data in order to comply, as necessary, with applicable laws and regulatory requirements, as well as legal process, respond to mandatory legal or governmental requests or demands for information, enforce our agreements, policies, procedures and terms of use, and protect ourselves, our customers, or the general public from illegal activities.
Is Personal Data shared for a business purpose?
- No
4. Payment Processors and Financial Services Providers
Why we share your Personal Data?
We may share your Personal Data with our payment processors and financial service providers as necessary to enable them to process payments, and for anti-fraud purposes.
For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.
Is Personal Data shared for a business purpose?
- Yes
5. Business Partners and Spritz Affiliates
Why we share your Personal Data?
We may share your Personal Data with our Business Partners as necessary to provide you with our Services.
Is Personal Data shared for a business purpose?
- Yes
Third-Party Links
The Spritz website and App may contain links to other websites or apps. Your access to and use of such linked sites is not governed by this Privacy Policy but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the Personal Data practices of such third-party websites. Please review the privacy policies of such sites before you disclose your Personal Data to them.
Children's Privacy
The Spritz website and App are not intended for children. We do not knowingly collect, use, sell, or share any Personal Data from anyone under the age of 18. If we become aware that a child under the age 18 has provide Personal Data to us, we will delete it.
Cookies, Advertising and Analytics Services
We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information.
These tools allow us to:
- Provide you Services that allow you to email or chat with our customer service team
- Perform website analytics
- Improve the advertisements you see
- Prevent fraud and prevent attacks against our websites and Services
- Advertise Spritz products and services, and additional products and services from our partner companies
We use cookies and trackers to assign you a unique identifier so we can record:
- Websites you visit
- Length of time the advertisement was visible
- IP Address
You can block cookies at any time using your web browser settings or App settings, but doing so may limit your browsing experience and your ability to use certain features of the App.
We do not currently respond to “Do Not Track” or DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. 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.
Spritz also uses Google Analytics. The following link explains how Google uses data when you use its partners’ websites and applications: www.google.com/policies/privacy/partners/. Your use of Spritz’s website is evidence of your consent to Spritz storing and accessing cookies and other information on your computer or phone and Spritz’s use of Google Analytics in connection with such activities. Please read the information at the link provided so you understand what you are consenting to.
Security
We are committed to protecting the privacy and confidentiality of your Personal Data. We limit access to your Personal Data to our authorized employees or agents and we contractually require our business partners and service providers to limit their use of your Personal Data. We also maintain physical, technical, and administrative safeguards to protect your Personal Data against loss, misuse, damage or modification, and unauthorized access or disclosure.
Your Choices
1. Account Information
You may update, correct or delete information about you at any time by logging into your online account, emailing us at support@spritz.finance or logging into the App. If you wish to delete or deactivate your account, please email us at support@spritz.finance, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
2. Promotional Communications
You may opt out of receiving promotional emails or text messages or app notifications from Spritz by following the instructions in those emails or text messages or notifications or by emailing us at support@spritz.finance. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
3. Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
California Privacy Rights
As a California consumer, you have the following choices regarding our use and disclosure of your Personal Data subject to certain limitations under the California Consumer Privacy Act (“CCPA”):
- Right to know. You may request, up to twice in a 12-month period, the following information about the Personal Data we have collected, used, disclosed or sold about you during the past 12 months:
- the categories and specific pieces of Personal Data we have collected about you;
- the categories of sources from which we collected the Personal Data;
- the business or commercial purpose for which we collected the Personal Data;
- the categories of third parties with whom we shared the Personal Data; and
- the categories of Personal Data about you that we disclosed for a business purpose and sold to third parties, and the categories of third parties to whom the information was disclosed or sold.
- Right to delete. You may request that we delete the Personal Data we have collected from you, subject to certain limitations under the CCPA.
- Right to opt-out from sale of Personal Data. You have the right to opt-out of the sale of your Personal Data. We do not sell your Personal Data.
- Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
To submit a request to exercise any of the rights described above, you may email us at support@spritz.finance. We will verify your identity before responding to your request by either verifying that the email address from which you send the request matches your email address that we have on file, or by requiring you to log into your account.
Consumer Request by an Authorized Agent
If any authorized agent submits a consumer request under the CCPA on your behalf, we require the authorized agent to submit the following information so that we can confirm their authority to act on your behalf:
- Evidence of authorization to act on behalf of the California consumer: (1) California Secretary of State authorization, (2) notarized written permission from the California consumer, or (3) power of attorney.
- Evidence of identity of the California consumer: (1) first and last name, (2) email address, and (3) password.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL DATA TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING SUPPORT@SPRITZ.FINANCE. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
Changes to this Privacy Policy
We may change this Privacy Policy from time to time to reflect changes in our practices concerning the collection, use, and sharing of Personal Data. The revised Privacy Policy will be effective immediately upon posting to the Spritz website, by notification through the App or through email. If you continue to use the Spritz website and the App after we make changes then you will be deemed to have agreed to the changes, so please check this Privacy Policy periodically for updates.
Contact Us
If you have any questions about this Privacy Policy, please contact us at support@spritz.finance.