Privacy Policy

Hogo - Powered by the ConsumerDirect® Platform - All Rights Reserved

Our software application ('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 notice is designed to explain how we collect, use and disclose personal information of prospective, current, and former customers. This notice also describes your privacy choices.

A special note about our privacy policy: The provisions of this policy apply both to CURRENT AND FORMER Members along with consumers who provide personal information on our sign-up pages but who do not complete their Membership application. If you have provided sign-up information, you may still opt-out of our use and sharing of your information by following the instructions below.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect three types of Personal Information from you:

Contact Information - such as your name, residential, business and/or mailing address, e-mail address, and telephone and or mobile number(s).

Financial Information - such as information on your creditors and accounts and the specific actions you take with regard to those accounts; In the course of providing services to you, we may also receive information about you from your creditors or the credit reporting agencies about your accounts. This information is classified as Financial Information.

Profile/Membership Information - such as demographic information, credit, identity and other personal profile data that you provide about yourself when you visit our App, register, or use our service, as well as, your Membership preferences.

From time to time, we may also collect or ask for additional Personal Information, which will also be expressly included herein as Personal Information. 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 our service may hinder or otherwise restrict your ability to use the App and services offered thereof.

Some of our services involve us acting as your authorized agent to make requests on your behalf. Before we act as your agent, you are required to provide information to us so that we may identify you.

We may also use the Personal Information to contact you to further discuss interests in ConsumerDirect® (including the services that we provide) and to send information regarding ConsumerDirect® or its partners, such as promotions and events. You may be invited to receive an e-mail newsletter or other correspondence by providing an email address. We may outsource all of these tasks to third party service providers.

WHAT NON-PERSONAL INFORMATION DO WE COLLECT?

Besides the Personal Information referenced above, we may also collect other information regarding your use of the App. We collect and use non-personally identifiable information, which is any information other than Personal Information and/or does not identify the specific individual, including, without limitation: Device Identifier (as defined below), IP address, the approximate geographic location, the type of operating system used by the user, any interactions a user may initiate within the App, the App and web pages that users visit or visited, user interactions with features of the App, content preferences users selected within the App and other inferences about the user's interests made based upon the foregoing. This information is not intentionally gathered in a fashion to personally identify any single user. We use this information to help us develop the App, analyze patterns of usage, and to make the App more useful.

A special note about device identifiers: When you use the App, we automatically collect your unique identifier ("Device Identifier") for the computer, mobile device, technology, or other device (collectively, "Device") you use to access the Services. This information will be in the form of a "number that is automatically assigned to your Device when you access our App and we identify your Device by its Device Identifier. We use Device Identifiers to enhance your customer experience. We may also work with third parties to serve ads on our App.

Minors

A special note about minor's information: Our services are designed to help adults manage their financial relationships. Hogo does not knowingly allow any visitors or users under the age of eighteen (18) to use or otherwise access the App. If you are under the age of 18, you may not use the App. Because we do not knowingly collect any information from any children under the age of 18, we also do not knowingly share or disclose such information to third parties.

HOW DO WE USE YOUR PERSONAL INFORMATION?

The primary reasons we collect personal information are to (1) enroll you in our Membership program, (2) provide products and services that you have requested and (3) promote products and services to you. In particular:

We use your Contact Information to provide:

We use your Financial Information to process your instructions, such as our Actions, and provide the services outlined in your Service Agreement and in this Privacy Policy.

We use your Personal Information to verify your identity, provide you with necessary Membership services, determine what other products and services might be of interest to you, and for our internal administrative purposes.

We use the information that we collect to provide and maintain the App as we deem appropriate in our sole discretion and to provide the service through the App, and to provide any other services that you and ConsumerDirect® agree to. ConsumerDirect® may aggregate data that it obtains form users to analyze trends, to gather data to benchmark best practices, and to monitor, improve and refine the functionality of the App and services offered therefrom.

We may contact you by mail, push notification, telephone and/or email to better assist you with completing your enrollment or for other marketing purposes.

WHEN DO WE SHARE YOUR PERSONAL INFORMATION WITH OTHERS?

We may provide your personal information to third parties under the following circumstances:

We may disclose any personal information (including your Contact Information, Financial Information and Personal Information) with any third parties as needed to process your actions and provide the services that you request. For example, to complete an Action, we will disclose your contact information, account information, along with your Action request and Membership information to the creditor on your behalf. If you direct us to disclose your personal information to third-parties, we will do so in accordance with your instructions and the terms applicable to the particular service.

We may disclose any personal information with third parties that are performing services on our behalf. These third parties are required to protect your personal information and are not permitted to use it for any other purpose.

Unless you opt out (as described below), we may share your Contact Information and Personal Information with third parties so they may send you information about their products and services via electronic and conventional postal mail. We may also share your Contact Information and Personal Information with other financial institutions, in order to jointly market financial products and services to you.

We may disclose any personal information as required or as permitted by law. For example, we may disclose your information to prevent fraud or in response to a subpoena. We may also disclose your information as needed to protect our legal rights and enforce our terms.

In the event that ConsumerDirect® is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, ConsumerDirect® reserves the right to sell or transfer user information (including Personal Information) as part of any such transactions. To the maximum extent allowable by law, the Privacy Policy will apply to the user information as transferred to the successor entity. However, user information submitted after a transfer to a successor entity may be subject to a new privacy policy adopted by the successor entity.

WHAT CHOICES DO I HAVE?

You have choices with regard to marketing communications and data sharing. 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 by contacting us below:

[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 Membership and 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.

HOW DO I UPDATE OR CORRECT MY PERSONAL INFORMATION?

If you are a Member, please login to your Hogo account. Please note, we are not able to update, modify, or correct personal information about you that we do not control.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have developed a formal information security program to safeguard the personal information that you entrust to us. 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.

We also take special steps to protect your information via transmission over the Internet by using a secure web server, which allows web browser programs (Mozilla/Firefox, Netscape, or Microsoft Internet Explorer) to interact with the web server via an encrypted session. We employ a Secure Sockets Layer (SSL) connection that provides an encrypted connection between your device and Hogo. The 128 bit encrypted connection scrambles ordinary text or data into cyphertext to safeguard sensitive information during its journey across the Internet. The information is decrypted, or put back into a readable format, when it reaches its intended destination. When you visit our App, you will be in a secured area.

WHAT HAPPENS IF WE CHANGE OUR PRIVACY POLICY?

As our business changes, we may need to revise our privacy practices. If we make any material changes to this privacy notice, we will notify all of our Members (and former Members or non-Members, if affected by the change) and provide you with the opportunity to opt-out of having your information handled in accordance with the new policy.

We may make minor or required regulation changes to this notice by posting the revised policy. We encourage you to review this privacy policy from time to time to review any changes in our information handling practices.

FOR USERS OUTSIDE OF THE UNITED STATES:

The Hogo App is exclusively hosted in the United States. If you are a user accessing the App from the European Union, Australia, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please note that you are transferring your personal data to the United States which does not have the same data protection laws as such other regions. User information (including Personal Information or "personal data" as defined by foreign laws) collected through the App may be stored and processed in the United States, and by using the App, you consent to any such transfer of information outside of your home country. You are also consenting to the application of United States laws in all matters concerning the App and use of any services offered from or through the App.

LEGAL DISCLAIMER

The Hogo App operates "AS-IS" and "AS-AVAILABLE," without warranties of any other kind. We are not responsible for the events beyond our direct control.

PRIVACY FEATURE

Our Privacy service is intended to assist you in exercising your privacy rights with various entities that control and process your personal information. When signing up for Hogo, you authorize ConsumerDirect® to act as your agent in order to exercise your rights or privileges under state and federal laws and regulations, private contracts or commitments (including the privacy notices, terms of service, and other representations from companies regarding the processing of your personal information). You grant us the right to exercise such rights and privileges on your behalf, including, without limitation, the right to access and receive the categories and specific pieces of personal information about you (which may or may not be known by you), the right to request deletion of your personal information, the right to opt-out of certain processing activities (like the sale of personal information), the right to restrict the use of your personal information, the right to request rectification of your personal information; and the right to receive personal information from third-parties in fulfillment of your rights and privileges. You may withdraw your permission at any time.

ConsumerDirect® or ConsumerDirect, Inc®., which powers Hogo may solicit engagement of users of the Privacy service within Hogo to submit complaints to governmental agencies, regulators, and other parties with regard to privacy violations. In addition, users of the Privacy service within Hogo may be presented with opportunities to assert privacy violations on a class-wide basis along with others similarly situated. Hogo users are not obligated to participate in any such activities.

By using the App, you grant ConsumerDirect® and our licensees, successors, and assigns a limited, royalty-free, nonexclusive, license to collect, compile, process and display your personal information (in complete and/or redacted form) to provide our Services. This license permits us to make your personal information available third parties to whom we submit requests on your behalf and display this information to you via the Services. Moreover, you grant ConsumerDirect® and our agents the right to communicate with third party organizations, including but not limited to data brokers, businesses, non-profit organizations, and governmental agencies on your behalf regarding your rights in and to your personal information. This includes the right to submit complaints on your (and others') behalf, with your consent, regarding violations of your privacy, consumer protection, confidentiality, data security, or similar laws, regulations, obligations or requirements.

CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act (CCPA), you, as a California resident, have the following rights.

Right to Access/Disclosure Right

You have 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.

The categories of personal information we collected about you.

The categories of sources for the personal information we collected about you.

Our business or commercial purpose for collecting or selling that personal information.

The categories of third parties with whom we share that personal information.

The specific pieces of personal information we collected about you.

A list that includes the personal information that we disclosed for a business purpose, identifying the category of personal information that each category of recipient obtained; and

A separate list that includes the personal information we sold, identifying the personal information categories that each category of recipient purchased.

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, simply log in to your account on the App and go to the Personal Data section of the settings page.

Right to Deletion

If we collected personal information from you, you have the right to request the deletion of this personal information. If you intend to exercise your rights, simply log in to your account on the App and go to the Personal Data section of the settings page.

Right to Be Free from Discrimination

You have 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:

Deny you goods or services;

Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties;

Provide you a different level or quality of good or services; or

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Opt-Out of the Sale of Personal Information

You have 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. If you would like to exercise this right, simply log in to your account on the App and go to the Personal Data section of the settings page.

Right to Opt-In 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.

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, simply log in to your account on the App and go to the Personal Data section of the settings page.