Effective Date: December 1, 2018

Welcome to the MoneyThumb’s privacy policy (Privacy Policy).

MoneyThumb LLC (referred to in this Privacy Policy as MoneyThumb, we, us or our) respects your privacy and is committed to protecting your personal data. This Privacy Policy describes how we look after your personal data when you use our products or services and visit our website and tells you about your privacy rights and how the law protects you.

1. HOW THIS PRIVACY POLICY APPLIES AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR DATA COLLECTED?

4. HOW WE USE YOUR DATA

5. DISCLOSURES OF YOUR DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

1. HOW THIS PRIVACY POLICY APPLIES AND WHO WE ARE

HOW THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to MoneyThumb’s downloadable and online financial file conversion software (Products or Services) and www.moneythumb.com website (Website) and other interactions (e.g., customer service inquiries, etc.) you may have with MoneyThumb. If you do not agree with the terms, do not download, access or use the Products, Services, Website, or any other aspect of MoneyThumb’s business.

This Privacy Policy does not apply to any third-party links or third-party applications or software that integrate with our Products or Services, or any other third-party products, services or businesses.

In addition, a separate agreement governs delivery, access and use of the Products and Services (License Agreement), including the processing of any files or other content submitted through the Products or Services (collectively Licensee Information). You or the organization (e.g., your financial services provider or another entity or person) that entered into the License Agreement (Licensee) controls your or its instance of the Products or Services (their Account) and any associated Licensee Information. Licensee may use the Products or Services to convert financial files and transactions from one file format to another, extract transactions from financial statements, configure settings, access, modify, export, share and remove Licensee Information, and otherwise apply its policies to the Products or Services. If you have any questions about specific Account settings and privacy practices, please contact the Licensee.

MoneyThumb’s Products, Services, and Website are not intended for children and we do not knowingly collect data relating to children.

CONTACT DETAILS

If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: MoneyThumb LLC

Email address: info@moneythumb.com

Postal address:

533 2nd Street, Suite 227
Encinitas, CA 92024-3558

Telephone number: +1 (858) 461-9766‬

CHANGES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may change it from time to time. Laws, regulations, and industry standards, or our business, may evolve, which may make those changes necessary. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide you with additional notice, for example through an email, our Products or Services, or our Website. If you disagree with the changes to this Privacy Policy, you should stop using our Products, Services, Website, or any other aspect of MoneyThumb’s business.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your name, username or similar identifier.

• Contact Data includes billing address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of Products or Services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our Website, Products or Services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Products or Services). In this case, we may have to cancel a Product or Service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You or the Licensee may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise when you or the Licensee creates an Account account, downloads or subscribes to our Products, Services or publications, requests marketing to be sent to you, enters a competition, promotion or survey, or gives us feedback or contacts us. Also, you or the Lciensee that purchases a paid version of the Products or Services provides us (or our payment processors) with Financial Data.

• Automated technologies or interactions. As you or the Licensee interacts with our Products or Services and Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

4. HOW WE USE YOUR DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, including the License Agreement, we are about to enter into or have entered into with you.

• In accordance with the Licensee’s instructions about Licensee Information.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you, for example, to decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you or the Customer has requested information from us or purchased roducts or services from us and you have opted in to receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting-Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy [LINK].

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR DATA

We may share your personal data with the third-parties set out below for the purposes set out in the Purposes for Which We Will Use Your Personal Data table above.

• Service providers based in the United States or other approved countries under the Customer Agreement who provide IT and system administration services.

• Professional advisers including lawyers, bankers, auditors and insurers based in the United States who provide consultancy, banking, legal, insurance and accounting services.

• Third-parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

• Specific third-parties, such as:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

We will retain your personal data only for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For example, individuals located in certain countries, including those in the European Union, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal data, as well as to request correction or erasure of your personal data. You or the Customer can do this using the settings or tools provided in your of the Licensee’s Account. To the extent that our processing of your personal data is subject to the General Data Protection Regulation, we rely on our legitimate interests to process your data. Where we are relying on a legitimate interest (or those of a third party) you may have the right to object to the processing of your personal data if you feel your fundamental rights and freedoms are impacted. You also have the right to object where we are processing your personal data for direct marketing purposes. If you withdraw your consent, we may not be able to provide certain Products or Services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at our Contact Details above.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.