Our Privacy Policy

Your privacy is critically important to us. At Thoughtful we have a few fundamental principles

- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.

- We store personal information for only as long as we have a reason to keep it.

- We never sell your personal information to anybody ever.

- We help protect you from overreaching government demands for your personal information.

- We aim for full transparency on how we gather, use, and share your personal information.


Below is our Privacy Policy, which incorporates and clarifies these principles.


Who We Are and What This Policy Covers

Hello! We are Thoughtful, LLC, sometimes abbreviated as just *Thoughtful*. We are the creators of the website, thoughtful.finance, and the mobile app named "Thoughtful Finance".

This Privacy Policy applies to information that we collect about you when you use:

- Our website (thoughtful.finance)

- Our mobile applications (including both iOS and Android)


Throughout this Privacy Policy we'll refer to our website and mobile applications collectively as "Services."


Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect


We only collect information about you if we have a reason to do so - for example, to provide our Services, to communicate with you, or to make our Services better.


We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let's go over the information that we collect.


Information You Provide to Us


It's probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

- Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an account to provide an email address.

- Transaction and Billing Information: If you subscribe to use the paid version of our Service you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.

- Communications with Us: You may also provide us information when you respond to surveys, communicate with us about a support question, or sign up for a newsletter. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications.

- Financial Information: We may make it possible to directly provide financial information to us such as bank transactions or budgets while using our Service. We collect financial information (not including your billing information as listed above) for the purpose of showing this information back to you in an understandable, useful way and managing your personal finances. We also make it possible to edit existing financial data that we may have (such as splitting a transaction or editing the name or category of a transaction). Lastly, you may provide us with bank or financial institution information (for example, your bank name, transaction list, or account balance) when you connect a financial account using our third party provider. When you do this, financial data will be automatically provided to us from the third party at a regular interval until you disconnect that financial institution from the provider. Read Information We Collect Automatically below for more information.


Information We Collect Automatically


We also collect some information automatically:

- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.

- Usage Information: We collect information about your usage of our Services. For example, we might track how many times you log in to the app, how much you actually use the "split transaction" feature, or how long you use the website. We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better. For example, if by analyzing this information, we discover that nobody uses the "split transaction" feature, we can better allocate our engineering resources to develop other features that our users find more useful.

- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.

- Financial Information: If you use our Service to connect a financial institution (such as a bank account or credit card), we use a third party provider to collect information about your account with that institution, such as the account name, balance, and a list of transactions in that account from the provider in order to make this information accessible to you in a useful way. This information is periodically sent to us from the provider automatically. You can always opt out of this functionality in our app by disconnecting your bank account from our Service.


How and Why We Use Information


Purposes for Using Information


We use information about you as mentioned above and for the purposes listed below:

- To provide our Services - for example, to set up and maintain your account, store your encrypted financial data so that you may access them at a later point in time or on a different device, or charge you for any of our paid Services;

- To further develop and improve our Services - for example, by adding new features that we think our users will enjoy or will help them to better understand their personal finances;

- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;

- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Thoughtful, LLC and others, which may result in us declining a transaction or the use of our Services; and

- To communicate with you, for example through an email, about offers and promotions offered by Thoughtful, LLC and others we think will be of interest to you, solicit your feedback, or keep you up to date on Thoughtful, LLC and our products.


Legal Bases for Collecting and Using Information


A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:


1. The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account - for example, in order to enable access to our website on your device or charge you for a paid plan; or

2. The use is necessary for compliance with a legal obligation; or

3. The use is necessary in order to protect your vital interests or those of another person; or

4. We have a legitimate interest in using your information - for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or

5. You have given us your consent.


Sharing Information


How We Share Information


We do not sell our users' private personal information.


We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

- Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

- Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, payment providers you use for your e-commerce operations, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.

- Legal and Regulatory Requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.

- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Thoughtful, LLC, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.

- Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Thoughtful, LLC goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.

- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.

- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you.


How Long We Keep Information


We generally discard information about you when we no longer need the information for the purposes for which we collect and use it - which are described in the section above on How and Why We Use Information - and we are not legally required to continue to keep it.


Security


While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

Encryption



We implement "end to end" encryption where possible. When financial information is provided by you, we encrypt it using AES or RSA encryption in the Thoughtful Finance app or website before sending it to our servers. Financial information that originates, with your permission, from our third party providers, is encrypted upon being delivered to your device (phone or browser) and the encrypted version is uploaded and used to replace the original version. All interactions between your device and Thoughtful, LLC's servers are encrypted with TLS (HTTPS).


Choices


You have several choices available when it comes to information about you:

- Opt-Out of Marketing Communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.

- Close Your Account: While we'd be very sad to see you go, if you no longer want to use our Services , you can close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above - for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.


Your Rights


If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the "GDPR"), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

- Request access to your personal data;

- Request correction or deletion of your personal data;

- Object to our use and processing of your personal data;

- Request that we limit our use and processing of your personal data; and

- Request portability of your personal data.


You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren't able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.


EU individuals also have the right to make a complaint to a government supervisory authority.


Controllers and Responsible Companies


Thoughtful, LLC is the controller of your personal data:


Thoughtful, LLC

1887 Whitney Mesa Dr #1990

Henderson NV 89014

United States


How to Reach Us


If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please send an email to support@thoughtful.finance.


Privacy Policy Changes


Thoughtful, LLC may change its Privacy Policy from time to time. We encourage visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.


Change log

- March 14, 2019: Published version 1 of the Privacy Policy.