Effective Date: April 24, 2024
At Palm Finance, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of Palm Finance, Inc.’s Services is at all times subject to our Terms of Use. As set forth in our Terms of Use, we receive certain rights in Member Data, as defined therein. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Palm Finance website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Categories of Personal Data We Collect
In connection with our Services, we collect Member Personal Data and Consumer Personal Data, as outlined in further detail below.
Member Personal Data: The following chart details the categories of Member Personal Data that we collect and have collected over the past 12 months. Any Personal Data that is not “Consumer Personal Data,” as defined below, constitutes “Member Personal Data.” For example, Member Data includes information about business ownership, employees, and consultants associated with our Members. Member Personal Data also includes Personal Data associated with individuals or businesses we believe may be interested in our Services, have expressed interest in our Services, or that have browsed our website.
Category of Personal Data (and Examples)
Business or Commercial Purpose(s) for Collection
Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data such as first and last name, account name, User ID or name, email, phone number, address, fax number, date of birth, and unique identifiers.
Identifiers such as social security number, driver’s license number, state identification card, passport number, tax ID or other government identifier
Commercial Data such as purchase history
Payment Data such as financial account information, name of financial institution, account name, account type, last four digits of account number, payment card type, full credit card number, last 4 digits of payment card, and billing address, phone number, and email.
Device/IP Data such as IP address, device ID, domain server, and type of device/ operating system/ browser used to access the Services.
Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the Services.
Sensory Data such as photos.
Social Network Data such as email, phone number, user name, IP address, and device ID.
Consumer Demographic Data such as age and/or date of birth, zip code, gender, race, ethnicity, citizenship status, veteran status, and sex life or sexual orientation, disability status.
Professional or Employment-Related Data such as resume, job title, job history, performance evaluations, union membership, current salary or salary range.
Geolocation Data such as IP-address-based location information or self-identified location information.
Inferences Drawn From Other Personal Data Collected such as attributes, user behavior, and predispositions.
Sensitive Data such as inferences reflecting racial or ethnic origin, sexual orientation, veteran status, disability status, citizenship or citizenship status.
Other Information such as emails, letters, texts, contracts and documents, or other communications.
Consumer Personal Data: The following chart details the categories of Consumer Personal Data that we collect and have collected over the past 12 months. “Consumer Personal Data” includes information about Members’ customers. Consumer Personal Data does not include Member Personal Data.
Category of Personal Data (and Examples)
Business or Commercial Purpose(s) for Collection
Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data such as first and last name, email, phone number, address, and unique identifiers.
Commercial Data such as purchase history, and consumer profiles, histories, or tendencies
Payment Data such as financial account information, payment card type, full credit card number, last 4 digits of payment card, and billing address, phone number, and email.
Social Network Data such as email, phone number, user name, IP address, and device ID.
Consumer Demographic Data such as age and/or date of birth, zip code, gender, race, ethnicity, citizenship status, veteran status, and sex life or sexual orientation, disability status.
Geolocation Data such as IP-address-based location information or self-identified location information.
Inferences Drawn From Other Personal Data Collected such as attributes, user behavior, and predispositions.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services:
Marketing the Services
Corresponding with You
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Palm Finance or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Session Replay Technology
We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology.
Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at privacy@getpalm.com.
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@getpalm.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
Effective as of April 24, 2024