This California Privacy Notice (“Notice”) applies only to California residents, and it deals only with information that is subject to the California Consumer Privacy Act (“CCPA”). Data about individuals who live outside California may be handled differently.
During the 12 months leading up to the effective date of this California Privacy Notice, we collected all of the types of personal information listed below (as further described in our Privacy Policy). During that period, we made the following disclosures of that information for the purposes described in the “HOW WE DISCLOSE YOUR INFORMATION” section of the Privacy Policy.
Category
Recipients of Personal Information
Purposes for Processing Personal Information
Identifiers
Examples: first and last name; email address.
Service providers
Advertising vendors who assist us with our marketing
Entities for legal purposes
To provide the Services and account access
To respond to customer support requests
To provide marketing materials to you from Copilot
To fulfill our Terms of Service
To communicate with you
To analyze use of and improve the Services
To comply with law or defend our legal rights
Security/fraud prevention
To fulfill purposes you consent to
Commercial information
Examples: bank account information; recent transaction data; payment card type; last 4 digits of payment card; billing address including postal code; phone number and email address.
Service providers
Bank data aggregators
Payment processors
Fraud prevention service providers
Entities for legal purposes.
To collect payment from Copilot users and process orders
To comply with law or defend our legal rights
Security/fraud prevention
To fulfill our Terms of Service
Professional or employment-related information
Examples: work email address.
Copilot partners
Service providers
Entities for legal purposes
To provide the Services (including those that you have requested)
To provide account access
To fulfill purposes you consent to
Internet or other electronic network activity information
Examples: IP address; device ID; type of device/operating system/browser used to access Copilot; statistics associated with the interaction between device or browser and Copilot’s services.
Service providers
Analytics service providers
Advertising partnersEntities for legal purposes
To provide the Services (including those that you have requested)
To understand adoption of our products
To market and advertise our Services
To personalize your experience and customize the Services
To comply with law or defend our legal rights
Security/fraud prevention
To fulfill our Terms of Service
Customer service interaction information
Examples: interactions with customer support.
Service providers
Entities for legal purposes
To provide the Services
To communicate with you
To analyze use of and improve the Services
To comply with law or defend our legal rights
Security/fraud prevention
To fulfill purposes you consent to
Geolocation information
Examples: IP address.
Service Providers
Analytics Partners
Entities for legal purposes
To provide a secure service
To protect Copilot and our customers against harmful acts
To understand usage of our Services
Other identifying information that You voluntarily choose to provide
Service providers
Customer support service Providers
Entities for legal purposes
To respond to customer support requests
To fulfill purposes you consent to
Sale and Sharing of Personal Information. As described in the Privacy Policy, Copilot does not “sell” Financial Information that you provide in your use of our money-tracking platform. We have incorporated cookies and similar technology from certain third parties into certain portions of our Services (i.e., our marketing website) to provide more relevant and tailored ads regarding our Services and to analyze the performance of our ads and the types of consumers who see and interact with them. We may also provide certain non-Financial Information, including identifiers, like IP address and hashed email address, to third-party platforms so that those platforms can display Copilot ads to interested audiences on other services and websites. These technologies allow us and our partners to serve tailored Copilot ads on other platforms, and to limit how often we show ads to consumers who have already subscribed to Copilot.
Although these advertising activities are a common way for companies like Copilot to promote their products and services, California law categorizes these activities as “selling” personal information or “sharing” personal information for targeted advertising purposes—even though we never provide such information in exchange for money—and requires us to make certain disclosures about these activities, which we provide below. To reiterate, these activities do not apply to your Financial Information as that term is defined in this Notice; rather, these are activities we undertake in relation to our marketing website and registration data in an effort to spread the word about the benefits of Copilot.
Over the last 12 months we have “shared” or “sold” Internet or other electronic activity information (e.g., web analytics data, device/IP data, and hashed email addresses) with advertising networks and marketing providers, solely for the purposes of marketing and selling of the Services and showing you advertisements, including interest-based or online behavioral advertising (i.e., a practice known as “retargeting”).
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please follow this link or select “Your Privacy Choices” on our website, and follow the instructions. You must make this choice on each browser/device you use to access the Services. You must also renew this choice if you clear your cookies or your browser is set to do that. You may designate an authorized agent to submit such requests on your behalf. If you want to opt out of us selling or sharing/processing your personal information, such as your hashed email address, and other associated personal information for targeted advertising activities through means other than cookie technology as described in the Privacy Policy, please please follow this link to complete the form.
We do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
Please note that if you have a legally-recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Processing of Sensitive Personal Information. In certain circumstances, the CCPA allows consumers to request that businesses limit their use of certain sensitive personal information. However, we do not engage in uses of sensitive information for which there is a right to limit under the CCPA.
Other CCPA Rights and Information. Please see the “Your Rights and Choices” section of the Privacy Policy for information about the additional rights you have with respect to your personal information under California law and how to exercise them. Please also see the “Retention of Information” section of the Privacy Policy.
“Shine the Light” Disclosure. California’s “Shine the Light” law gives California residents the right under certain circumstances to request information from us regarding the manner in which we share certain categories of “personal information” (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your “personal information” with third parties for their own direct marketing purposes.
