Privacy Policy

Last Updated: February 9, 2023

BuoyFi respects every user’s concern about their individual privacy. This Privacy Policy will serve as a disclosure of BuoyFi’s privacy practices. This privacy notice applies to information collected by any of BuoyFi’s services offered on technology platforms and website(s) (the “Services”), including, but not limited to, BuoyFi’s mobile Application (the “Application”), and will apply to all Services and products offered by BuoyFi. Specifically, this privacy notice will notify you of the following:

What personally identifiable information (PII) is collected from you through the BouyFi website(s) and technology platforms, how it is used and with whom it may be shared.
What choices are available to you regarding the use of your data.
The security procedures in place to protect the proper use of your information.
How you can correct any inaccuracies in the information.

Information We Collect

We will only have access to and collect information that you voluntarily give us, or voluntarily give us permission to obtain, while using the Services offered by BuoyFi, via email, text, telephone conversations to/from you, registration for the Services, updates to your account, or from other direct contact from you. The information we collect may vary according to the Service we will be providing to you and your use of the Services. The information will include: your name or aliases, physical address, phone number, email address, date of birth, social security number or other tax identification number, debt account information including hospital/clinic name and balance, banking information, income information, and transaction data from credit cards you link to the Services.

How We Use Information

BuoyFi uses information to operate, improve, and protect the Services we provide, as well as to continue to develop new Services to benefit our customers. We may use the customer information we obtain or collect in order to: set up your BuoyFi user account; provide customer support to you to help respond to your inquiries related to our Services or BuoyFi platform or website; validate your information with BuoyFi Partners; conduct income verification; provide recommendations related to any outstanding accounts; submit BuoyFi’s recommendations to your accountholders; submit payments for your accounts linked to your BuoyFi user account; provide information necessary for appropriate BuoyFI Partners to create a bank account provided by our third-party banking partner that can be used for a round-up savings account; verify you, your identity, and that the data provided is credible; prevent fraud; send you technical notices, updates, security alerts and support and administrative messages; and for any other purpose with your consent.

Information Sharing

We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request or after obtaining approval from you to share your information. We will not sell or rent this information to anyone. We will be the sole owners of the information collected by any of BuoyFi’s (or BuoyFi Partners’) Services offered on technology platforms, but to the extent that information is personally identifiable to you, we will only use it subject to the limits set forth in the next paragraph.

We may share, after obtaining your consent, the information we collect with our partners, affiliates, subsidiaries, third-party vendors, and other companies in connection with providing BuoyFi’s Services. We may also disclose your information if we are required to do so by law, legal process, a government agency, to defend our legal rights, to prevent physical harm or financial loss, and in connection with an investigation of alleged improper activity.

Your Access to and Control Over Information

BuoyFi understands your concern about control over your information. Therefore, you can do the following at any time by contacting us via mail, email, or phone using the contact information given below:

See what data we have about you, if any.
Change, correct, or update any data we have about you.
Express any concern you have about our use of your data.

In addition, if you already have a BuoyFi user account, you can log in to your user account in order to see or update your information.

The following information applies to all users of BuoyFi Services regardless of your State of residence. If you are a California resident, the information provides you with the information you need to exercise your rights under the California Consumer Privacy Act (CCPA). If you are resident of Colorado, Connecticut, Utah or Virginia, this information will provide you with the information you need to exercise your rights under your State’s Privacy Laws as they come into effect.

Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal data from consumers within the last twelve (12) months:

Category	Examples	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
Biometric Information	Physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	YES
Internet or other similar activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
Geolocation data	Physical location or movements.	NO
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
Professional or employment-related data	Current or past job history or performance evaluations.	YES
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

If you are a California resident, be aware that Personal Information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the FCRA, the GLBA or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Sharing your Personal Information

In the preceding 12 months, we have disclosed the following categories of information for the business purposes described above:

Identifiers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Protected classification characteristics under California, other States, or federal law.
Commercial Information
Internet or other similar activity
Professional or employment-related data
We disclose these categories of personal information for business purposes to the following categories of third parties:
Our affiliates
Our partners
Our service providers and other third parties that cannot use personal information collected by or on behalf of us for their purposes, including but not limited to advertising networks, business process outsourcing providers, internet service providers, data analytics providers, data processors and storage providers, operating systems and platforms, social networks, and consumer data resellers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or Services we provide to you

Selling your Personal Information

In the preceding 12 months, we have not sold any categories of personal information.

Rights of California Residents

The following terms are written to comply with the CCPA, but you may avail yourself the benefit of these terms no matter your State of residence:

Pursuant to the CCPA, California residents have the right to submit the following requests to BuoyFi. To submit these requests, please visit support@buoyfi.com or call our Customer Care team at 888-308-6004 (our regular business hours of 8:00AM-4:30PM, five days a week). BuoyFi is prohibited from discriminating against in any way in response to your exercise of any of these rights. This means we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Offer a product enhancement or financial incentive that is contingent on you sharing personal information, unless that incentive is reasonably related to the value provided to us by that collection.

To ensure personal information security and prevent fraudulent requests, we may need to collect personal information and other information such as your name, email, or transaction history to verify your identity. Any authorized agents making requests on your behalf need to provide similar information for verification.

Access

You have a right to request BuoyFi provide you with the following information, covering the 12 months preceding the date your request is submitted:

The categories and specific pieces of personal information collected about you
The categories of sources of the personal information collected about you
The business or commercial purposes for collecting or selling your personal information
The categories of third parties to whom we sold your personal information
The categories of third parties to whom we disclosed your personal information for a business purpose

Deletion

You have the right to request BuoyFi to delete the personal information collected from you, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Opt-Out

Even though we do not sell your personal information, you have the right to request that BuoyFi not sell your personal information. To exercise that right, please click here or call 888-308-6004 during our regular business hours of 8:00AM-4:30PM Central Time, Monday through Friday.

Security

We take precautions to protect your information. When you submit sensitive information via the Services, your information is protected both online and offline.

Wherever we collect sensitive information, that information is encrypted and transmitted to us in a secure way. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment.

BuoyFi takes commercially reasonable measures to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we implement policies designed to protect the confidentiality and security of your nonpublic personal information.

Unless otherwise specified in this Policy, BuoyFi limits access to your information to employees that have a business reason to know such information, and further implements security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.

Third-Party Analytics Services

BuoyFi may use third-party analytics service providers on the website(s) and electronic platforms used for BuoyFi’s Services. BuoyFi may use analytics regarding your data and personal information as follows:

to deliver alerts and other notices, including promotional or similar material and information;
to improve the Services;
to analyze usage and trends;
to analyze demand for additional services;
for market analysis, troubleshooting, and project planning;
for identification of potential fraud and criminal activity;
to assist third party vendors and BuoyFi Partners with the services they offer through the BuoyFi Services; and
for other purposes with your consent.

Advertising

While using BuoyFi Services you may receive advertisements on the electronic platform providing the Service. In addition, you may see BuoyFi advertised on other websites and applications not affiliated with BuoyFi. These advertisements are provided by third-party advertising agencies. The advertising services track your online activities while using multiple websites and applications. After an extended period of time, the advertising services will be able to target specific audiences and demographics based on users’ activity. This may cause you to see targeted advertisements while using BuoyFi’s Services or see BuoyFi as a targeted advertisement while using a third-party’s service.

Links to Third-Party Services

As part of BuoyFi’s Services, we may use additional third-party services, such as plug-ins, additional applications, tools, and widgets. These services are provided by third parties who operate independently of BuoyFi. It is important to know that each of these third parties have their own policies surrounding your privacy and data. We strongly encourage you to review those policies. BuoyFi will not be responsible for any actions of the third parties.

BuoyFi uses Plaid, Inc. (“Plaid”) to collect your information from your financial institution. By using BuoyFi’s Services, you acknowledge and agree to your information being collected, used, and stored according to Plaids Privacy Policy, which can be found here: https://plaid.com/legal/#end-user-privacy-policy.

BuoyFi uses BillGO, Inc. (“BillGo”) to allow users to pay any bill. By using BuoyFi’s Services, you acknowledge and agree to your information being collected, used, and stored according to BillGo’s Privacy Policy, which can be found here: https://www.billgo.com/privacy-policy.

BuoyFi uses Synapse Financial Technologies, Inc. (“Synapse”) to transfer funds and establish bank accounts for users. Funds are held by Synapse’s banking partners, Members FDIC. These funds are held in a custodial account, for your benefit. Synapse is our backend software provider, and partners with financial institutions to provide FDIC insurance. Synapse’s API, and their relationship with financial institutions, enables us to offer banking services and products. By agreeing to BuoyFi’s User Agreement and Privacy Policy, you also agree to Synapse’s terms and policies below:

Terms and Conditions: https://synapsefi.com/tos

By using BuoyFi’s services, you acknowledge and agree to your information being collected, used, and stored according to Synapse’s Privacy Policy, which can be found here: https://synapsefi.com/privacy.

Banking services are offered through BuoyFi and its partner Synapse Financial Technologies and our partner banks.

Children’s Privacy

BuoyFi’s Services are not designed for nor are to be used by children. We do not knowingly obtain, collect, or solicit personal information from children under the age of thirteen (13). If you have reason to believe that a child under the age of thirteen (13) has provided us with personal information, please contact us using the contact information below.

Automatically Collected Data; Cookies

When you interact with BuoyFi through our web site or by use of our products or Services, we receive and store certain information, which is collected using cookies and log data as described below:

In operating the web site, we use “cookies.” A cookie is a piece of information that the computer that hosts our web site gives to your browser when you access the web site. These cookies help provide additional functionality to the web site and help us analyze web site usage more accurately. In particular:

Our web site may set a cookie on your browser that allows you to access the web site without needing enter a password more than once during a visit to the web site;
We use cookies on our website from Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the web site, compiling reports on the web site activity and providing further services to us relating to the web site usage. You can learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631 You can prevent your data from being collected by Google Analytics on our web site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
We use cookies on our Application from Amplitude Analytics, a web analytics service provided by Amplitude, Inc. (“Amplitude”). The information collected by Amplitude (including your internet protocol (IP) address) will be transmitted to and stored by Amplitude on servers in the United States. Amplitude will use this information on our behalf for the purpose of evaluating your use of the Application, compiling reports on the Application activity and providing further services to us relating to the Application usage. You can learn more about Amplitude Analytics’ privacy practices, and see a copy of Amplitude’s privacy policy, at the following link: https://amplitude.com/privacy.

When you first visit the web site, you will be asked to consent to the use of cookies on the web site in accordance with this Privacy Policy, and if you accept we will store cookies on your computer.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

While we recommend that you leave cookies turned on, because they allow you to take advantage of some of the web site’s features, on most web browsers you may refuse the use of cookies by selecting the appropriate settings. Be aware, though, that if you do this you may not be able to use the full functionality of the web site.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Usage of a cookie is in no way linked to any personally identifiable information on our site.

Updates to this Privacy Policy

BuoyFi reserves the right to update this Privacy Policy at any time without prior notice to you. We will notify you after the changes become effective, and the date of the change will be reflected at the top of this privacy notice.

Contact Us

If you feel that we are not abiding by this privacy policy, have any questions, or would like to update your information, please contact us by email, telephone, or postal mail.

Email: support@buoyfi.com

Telephone: 888-308-6004

Hours: Concierge Team Members are available to answer your calls: Monday through Friday 8:00 AM- 4:30 PM Central Time

Postal Mail: 4250 Drinkwater Blvd, Suite 300, Scottsdale, AZ 85252

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