Privacy Policy

Last Revised: 10/20/2022


Hi and welcome to HOGO®! HOGO® is a software application (the “App”) owned and provided by ConsumerDirect®, Inc. ("ConsumerDirect®" or "we" or “us”). For purposes of this Privacy Policy, the App means and includes the software application and all features, functions, products, content, information, materials, and services (collectively, “Features”) provided in or through the App.

The App is designed to collect and maintain sensitive personal information, including information about your financial accounts and credit history. We are committed to the responsible stewardship of this information. This Privacy Policy explains how we collect, use, maintain, protect, and share your personal information, as well as your privacy choices.

This Privacy Policy applies to both current and former users of the App, and to prospective users who may provide information on the App’s sign-up pages but who do not complete creating their Account. Prospective and former users may still opt out of our use and sharing of your information by following the instructions below.

This policy does not apply to information collected by any third party, including through any application or content, including advertising or third-party product or service offers, that may link to or be accessible from the App or from third-party applications that we may use to share information and otherwise communicate through. We do not control any third party’s tracking technologies or how they may collect or use your information. You should consult any such third party directly for the terms that govern their collection and use of your information.

Please carefully read this Privacy Policy and our Terms of Use, which govern your use of the App and any dispute arising out of or relating to the App or this Privacy Policy, to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our Terms of Use or this Privacy Policy, your choice is not to use the App. By accessing or using the App, you agree to this Privacy Policy.


The App is not intended for persons under 18 years of age. We do not knowingly collect personal information from persons under the age of 18. If you are under 18, do not use or provide any information on the App or through any of its Features, register for an account with us, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

The App is not intended for use or access by persons who are not located in the United States. You acknowledge that you may not be able to access the App outside of the United States and that access thereto may not be legal in certain countries. If you access the App from outside the United States in violation of this policy, you are responsible for compliance with local laws.


We collect several types of information from and about users of the App, including information:

We collect this information:


The information we collect that you provide directly to us on or through the App may include:


When you download, access, and use the App, it may use technology to automatically collect:

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties.

The technologies we use for this automatic data collection may include, without limitation:


Some Features of the App are served by third parties, including advertisers, ad networks and servers, partners offering financial or other products or services, analytics companies, your device manufacturer, mobile or internet providers, and content and service providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see What Choices Do I Have?


We use information that we collect about you or that you provide to us, including any personal information, to:

The information we collect automatically helps us to improve and to deliver a better and more personalized App, including by enabling us to:

We use location information we collect to verify that you are located in the United States.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you, which may include an email newsletter, direct emails, in-App messages, telephone calls, mail, or other correspondence. We may outsource some or all of these functions to third-party service providers. If you do not want us to use your information in this way, please opt out as described below. For more information, see What Choices Do I Have?

We may use the information we collect to display advertisements or offers to our advertisers’ or partners’ potential target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement or offer, the advertiser or partner may assume that you meet its target criteria, and any information you share in connection with the advertisement or offer, and any information otherwise collected by such advertiser or partner in connection therewith, will be shared with or collected by such third party and will be governed by such third party’s own privacy policy.


We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:


We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personal information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third-party processors, which may include the Google Play Store or the Apple App Store or other third-party services. The use of your personal information by any such third-party processor is governed by such processor’s own privacy policy available on their respective websites.


You have choices with regard to marketing communications and sharing of personal information you provide to us. In particular:

Regardless of how you access our App, you can opt out of receiving marketing communication from us (and our joint marketing partners) or from our sharing your personal information with third parties for their own marketing (including targeted advertisements or offers offered through the App) by contacting us at: [email protected].

You may also opt out of email marketing by following the opt-out instructions included in every commercial email we send. Please note that we may continue to communicate with you regarding your Account and your use of the App, including any Actions you take.

You may opt out of receiving promotional telephone calls from us by asking the operator to place you on our do not call list.

You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, the App may become inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Any personal information you provide to us is voluntary, and you can opt out of providing certain personal information requested by us. However, your refusal to provide certain personal information requested as part of using the App or certain Features thereof may hinder or otherwise restrict your ability to use the App and those Features.


You can review your personal information by logging into the App. To update, modify, correct, or delete any personal information that you have provided to us, you may do so through the applicable App Features or you may contact us through the App or send us an email at [email protected]. Please note, we are not able to update, modify, correct, or delete personal information about you that we do not control. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to update, modify, correct, or delete information if we believe the change would violate any contractual, regulatory, or legal requirement, cause the information to be incorrect, or for any other reason except as prohibited by applicable law.


We have implemented measures designed to safeguard your personal information from unauthorized access, use, alteration, and disclosure. Our security program includes reasonable technical, physical and administrative safeguards. For example, we restrict access to your information only to those employees who need to know that information to provide products or services to you.

Any payment transactions are processed by our third-party payment processor and will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.


We may amend this Privacy Policy from time to time. In such event, we will post the new Privacy Policy on this page with an updated “Last Revised” date, and we will notify you by emailing you, by sending an in-App alert the first time you use the App after we make the change, or by any other means we reasonably determine to give you notice. You are responsible for ensuring we have an up-to-date active and deliverable email address for you. Your continued use of the App after any such amendment will constitute your agreement to this Privacy Policy as amended. If you do not agree to any amendment, you may not continue to use the App and you must deactivate your Account and delete the App from your device(s).


State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

Nevada provides its residents with a limited right to opt-out of certain personal information sales.. However, please know that we do not sell data triggering Nevada’s opt-out requirements.

Under the California Consumer Privacy Act (CCPA), California residents have the following rights if a business is covered by the CCPA:

Right to Access/Disclosure Right

The right to request a disclosure of the personal information collected, sold, and shared about you over the past 12 months and the purpose for doing so. Upon submission of a verifiable consumer request, we will provide you with the following information:

If we provide this information to you electronically, the information will be in a portable format. To the extent that it is technically feasible, we will provide you the information in a readily useable format that you can easily transfer to another entity. If you intend to exercise your rights, please visit the Personal Data section located in the settings tab of your HOGO® App.

Right to Deletion

The right to request the deletion of personal information, subject to certain exceptions. you can request the deletion of your information at any time by selecting the “Forget your Data” option located in the Hogo App under the settings section.

Right to Be Free from Discrimination

The right to be free from discrimination for exercising any of the California consumer privacy rights. If you choose to exercise any of your CCPA rights, we will not:

Right to Opt-Out of the Sale of Personal Information

The right, at any time, to direct a business that sells or will sell your personal information to third parties to not sell your personal information. However, please know that we do not sell data triggering California’s opt-out requirements.

Right to Opt-In to the Sale of Personal Information for Children

We do not provide a right to opt-in because we do not offer this Product to minors nor do we sell personal information.

Right to Know

You have the right to know the categories of personal information we collect and the purpose for the collection.

You have the right to know the categories of personal information that we collected, sold, and disclosed for a business purpose during the prior 12 months. If you intend to exercise your rights, please visit the Personal Data section located in the settings tab of your HOGO® App and click on “Disclose Your Data.”


To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

[email protected]