At Palm Finance, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of Palm Finance, Inc.’s Services is at all times subject to our Terms of Use. As set forth in our Terms of Use, we receive certain rights in Member Data, as defined therein. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Palm Finance website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
Table of Contents
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Categories of Personal Data We Collect
In connection with our Services, we collect Member Personal Data and Consumer Personal Data, as outlined in further detail below.
Member Personal Data: The following chart details the categories of Member Personal Data that we collect and have collected over the past 12 months. Any Personal Data that is not “Consumer Personal Data,” as defined below, constitutes “Member Personal Data.” For example, Member Data includes information about business ownership, employees, and consultants associated with our Members. Member Personal Data also includes Personal Data associated with individuals or businesses we believe may be interested in our Services, have expressed interest in our Services, or that have browsed our website.
Category of Personal Data (and Examples)
Business or Commercial Purpose(s)
for Collection
Consumer Personal Data: The following chart details the categories of Consumer Personal Data that we collect and have collected over the past 12 months. “Consumer Personal Data” includes information about Members’ customers. Consumer Personal Data does not include Member Personal Data.
Category of Personal Data (and Examples)
Business or Commercial Purpose(s)
for Collection
Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data such as first and last name, email, phone number, address, and unique identifiers.
Providing, Customizing and Improving the Services
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Commercial Data such as purchase history, and consumer profiles, histories, or tendencies
Providing, Customizing and Improving the Services
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Payment Data such as financial account information, payment card type, full credit card number, last 4 digits of payment card, and billing address, phone number, and email.
Providing, Customizing and Improving the Services
Corresponding with You
Sourcing Savings, Growth & Other Business Opportunities
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Social Network Data such as email, phone number, user name, IP address, and device ID.
Providing, Customizing and Improving the Services
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Consumer Demographic Data such as age and/or date of birth, zip code, gender, race, ethnicity, citizenship status, veteran status, and sex life or sexual orientation, disability status.
Providing, Customizing and Improving the Services
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Geolocation Data such as IP-address-based location information or self-identified location information.
Providing, Customizing and Improving the Services
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Inferences Drawn From Other Personal Data Collected such as attributes, user behavior, and predispositions.
Providing, Customizing and Improving the Services
Service Providers
Parties Our Members Authorize, Access, or Authenticate
Business Partners
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services:
Creating and managing Members accounts or other user profiles.
Processing orders or other transactions; billing.
Providing you or our Members with products, services or information. For example, we use and share Personal Data to source proposals or offers from third parties that can help our Members’ businesses. This may include using and disclosing Personal Data - for example, by pre-filling forms - to help our Members obtain quotes or offers for insurance, loans, technology services, or other professional services. We also use data we collect to provide aggregated benchmarking and insights to our Members and Business Partners.
Conducting Know Your Customer (“KYC”) or Know Your Business (“KYB”) checks/reports.
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Doing fraud protection, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
Marketing the Services
Marketing and selling the Services.
Showing you advertisements, including interest-based, online behavioral or targeted advertising.
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Palm Finance or the Services.
Sending emails and other communications according to your preferences.
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Palm Finance or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
When you provide such information directly to us.
When you create an account or use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Public Records
From the government or other sources.
Third Parties
Our Members
We may receive personal data about customers of our Members (for example, purchasers or their products or services) when they use our services.
Vendors
We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles.
Advertising Partners
We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
Third-Party Credentials
If you provide your third-party account credentials, such as your social network account credentials, to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
Security and fraud prevention consultants.
Support and customer service vendors.
Product fulfillment and delivery providers.
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
Ad networks.
Marketing providers
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
Companies that track how users found or were referred to the Services.
Companies that track how users interact with the Services.
Business Partners. Any third party that enters into an agreement with Palm, which may include, but not be limited to, providers of products, services or offers that we believe our Members may be interested in. For example, we may use and share Personal Data provided by Members to source higher value financial or technology products.
Parties Members Authorize, Access or Authenticate
Third parties that our Members access through the services. For example, our Members may authorize us to share Personal Data with their service providers.
Social media services.
Other users.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
Tracking Tools, Advertising, and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Session Replay Technology
We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology.
Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
We retain your profile information and credentials for as long as you have an account with us.
We retain your payment data for as long as we need to process your purchase or subscription.
We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at privacy@getpalm.com.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@getpalm.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
(415)-854-3686
Effective as of April 24, 2024