Evolution Finance Privacy Policy

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Effective as of November 20, 2023

Last Updated on November 20, 2023

Introduction

At Evolution Finance, Inc. ("Evolution Finance," "we," "us," or "our"), our relationship with you is our most valuable asset. We understand and appreciate that you are entrusting us with your personal information, and as such, we are committed to being transparent about how we collect, use and disclose it.

This Privacy Policy applies to all of the products, services, mobile applications and websites (e.g., CardHub.com and WalletHub.com) offered by Evolution Finance or its subsidiaries or affiliated companies (collectively, the "Site"). This policy describes the personal information Evolution Finance collects when you register for, use, access or otherwise interact with any of our websites, applications, products or services (collectively, the "Services").

In addition to this Privacy Policy, please review our Terms of Service, which governs your use of our Services and includes provisions on arbitration, limitation of damages and choice of law.

This Privacy Policy covers the following topics:

1. Statement of Coverage

This Privacy Policy covers how Evolution Finance uses the personal information we collect in connection with the Services. This Privacy Policy does not apply to the practices of companies not owned or controlled by Evolution Finance. Our Services are intended only for U.S. citizens and residents. If you are visiting our websites from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using our Services or websites, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

2. Information Collection & Use

General: Evolution Finance may collect and store information about you and others when you register with Evolution Finance, when you use the Services, when you visit Evolution Finance pages or the pages of Evolution Finance properties (e.g., CardHub.com and WalletHub.com) or the pages of certain Evolution Finance partners, and when you enter promotions or sweepstakes conducted, endorsed, or advertised by Evolution Finance.

Evolution Finance uses information for the following general purposes: providing, maintaining, optimizing, and improving our services, developing new services, enhancing the user experience, customizing the advertising, offers and content you see, fulfilling your product and service requests, research and development, managing your customer relationship with us, providing you customer support, contacting you, and providing reports for our internal and external clients and partners.

Registration: Upon registering with Evolution Finance, personal information such as your name, email address, birth date, gender, or ZIP code may be requested. Certain products and services may ask you for additional information, such as your address, phone number, income, Social Security number, details about the financial products you use, driver's license number or information about your assets. Some of the personal information we collect when you register, like your Social Security number, is required by the credit bureau to verify your identity so we can fulfill your request for a free credit score and credit report. When requesting your credit report and score on your behalf, we do not do a hard inquiry; rather, we do a soft inquiry of your credit report. We may also collect personal information or other information directly from you through various other forms and places throughout the Services, including "Contact Us" forms, or when you otherwise interact with us to provide or enhance our Services. You are not anonymous to us when you register with Evolution Finance and sign in to our Services.

Premium Subscriptions: If you sign up for a WalletHub premium subscription, you may choose to provide us with personal information in connection with the premium subscription features, such as your email address, birth date, physical address, phone number, credit and/or debit card information, financial account information, Social Security number, passport number, health insurance identification number, and driver's license number.

Transactions: Evolution Finance collects information about your transactions with us and some of our partners. This includes billing and payment information and information about your use of our products and service offerings. We share this information with third parties who perform tasks required to complete purchase transactions (such as fulfilling orders and processing credit card payments).

Special Offers and Updates: We use information we collect in providing the Services, including personal information, to match you with offers for financial products and services. Generally, we will display these offers when you access our Services, but we will occasionally send you information on products, services, special deals, or promotions, by email or other electronic messaging. You can opt out of these types of email or electronic messaging communications within your account or by following the unsubscribe link included in each email.

Automatically Collected Information: Evolution Finance uses cookies, web beacons, and similar technologies to automatically collect and record certain information from the computer, mobile phone, or other device you use to access the Services, including device identifier, technical information about your device, IP address, browser type, browser language, the webpages you request, location information, and the date and time of your request. When we use third-party tools, those third parties may also collect such information. For more information, please see our Cookie Policy.

Universal Opt-Out Mechanisms: The Site recognizes the Global Privacy Control ("GPC") signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs . If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the "Do Not Track" signal, the Site does not currently interpret, respond to or alter its practices when it receives "Do Not Track" signals.

Location: We may collect and store information about your device's precise location if you enable your computer or mobile device to share it with us. Evolution Finance will not collect your precise location information without your consent. However, we may ask for your consent to use location-enabled services on your device so that we can collect, share and process information about your device's location to enhance our Services and provide better offers to you, using information like GPS or Wi-Fi access point information. You may change the settings on your computer or mobile device to prevent it from providing us with such information. We may also use information like your IP address or other device identifiers for approximate location information, like your city or state.

Public Content: Your reviews, comments, questions and answers, posts, followers, groups, financial products in your Wallet, businesses and professionals that you have done business with, topics and users you follow, profile information (including your name), and any other information that you post to the Service are meant for public consumption. We may display this content on the Service, collect and store it, and further distribute it to a wider audience through third party sites and services. Please also keep in mind that whenever you voluntarily make other personal information (e.g., your home address) available online for viewing by third parties by posting it on the Service, that information is public and can be seen, collected and used by others besides us. We are not responsible for any unauthorized third-party use of such information.

Other Users: We receive information about you from other users through their use of the Service, such as when they follow you, comment on your posts, ask you questions, mention you, or send you messages.

Contacts: When you invite your friends to join the Service by providing their contact information or allowing us to use your address book from your computer, mobile device, or other sites, we may use and store your friends' contact information long enough to process your requests.

Messages: If you exchange messages with others through the Service, we may store these messages in order to deliver them and allow you to manage them. If you send information from the Service to your phone via SMS text message, we may log your phone number, phone carrier, and the date and time that the message was processed. Carriers may charge recipients for texts that they receive. When you send email or other communications to Evolution Finance, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. As part of our credit monitoring service, you may also receive SMS text messages, push alerts on your phone, and emails when there is a credit or savings alert. These alert messages will also be logged.

Please also note that the messages you send or receive using the Service are only private to the extent that you and the sender/recipient keep them private. For example, we do not have any control over whether a recipient of one of your personal messages publicly posts it or its contents.

Other Sites: We offer some of our services on or through other web sites. Personal information that you provide to those sites may be sent to Evolution Finance in order to deliver the service. We process such information according to this Privacy Policy.

The Service includes links to other web sites and provides access to products and services (for example, widgets and applications) offered by third parties, whose privacy policies we do not control. When you access another web site, access the Service with a third-party account (like Facebook or Twitter), or purchase third-party products or services through the Service, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services. We do not exercise control over these third-party sites and they may place their own cookies or other files on your device, collect data, web site usage information and your device identifier, or solicit personal information from you. We are not responsible for the privacy practices of any third party. We encourage you to note when you leave our Service and to read the privacy policies and terms of service of all third-party web sites or applications before submitting any personal information to third parties.

You can also connect your Evolution Finance account to your accounts on third party services like Facebook or Twitter, in which case we may collect and store information identifying your account with the third-party service as well as other information from these third-party services that you have given us permission to access (e.g., name, date of birth, profile picture and friends' birthdays). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing the feature. We use the information to help you connect and share public content with your friends and followers. You can always disconnect your accounts on these third-party services from your Evolution Finance account by visiting those services directly.

Information Provided by Third Parties about You: Evolution Finance may supplement the information we collect about you with information from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to consider financial products or services that we believe may be of interest to you. This includes, for example, the free credit report and free credit score we may obtain on your behalf when you register for the Service from a credit bureau (e.g., TransUnion). Examples of other sources from which we may collect personal information include our business partners, publicly available sources, data providers, other users, and social media platforms that you use to log into the Services. We treat all information about you, whether received from you or from a third party, as described in this Privacy Policy and our Terms of Service.

Referrals: If you choose to use our referral program to tell a friend about our Services, we will ask you for your friend's name and email address. We will email your friend an invitation to visit the site. Evolution Finance stores the information you provide for the sole purpose of sending this email and tracking the success of our referral program. Please be aware that when you use any referral functionality through our Services, your name and email address may be included in the communication sent to your friend.

Service-Related Announcements: We may send you service-related announcements. For instance, if we update our privacy practices or if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt out of these non-promotional communications. If you do not wish to receive them, you have the option to terminate your account.

Push Notifications: If you use our Mobile Applications, we may send you push notifications from time-to-time via our Mobile Application in order to provide or alert you to service-related announcements or information on products, services, special deals, or promotions. If you do not wish to receive these types of communications, you may turn them off in your mobile Device settings.

Customer Service: When you first register for our WalletHub service, we may send you an introductory email welcoming you to WalletHub. We may also communicate with you via email or other means in response to your inquiries and to manage your account.

Children: At Evolution Finance we are committed to protecting the privacy of children. We will not knowingly or intentionally collect any personal information online from children under the age of 16. If a child under the age of 16 has provided us with personal information, please let us know by filling out our contact form. Once received, we will remove that information from our Services.

Evolution Finance may share information you have provided during use of our Services under the following circumstances:

When you use our Services to obtain offers for financial products and services, you direct us to provide our partners with your credit data and other relevant information you provide as a way to match you with offers for financial products and services from those partners. Generally, we will display these offers when you access our web or mobile Services, but we will occasionally send you information on products, services, special deals, or promotions, by email or other electronic messaging. It is always your choice whether or not to apply for an offered product or service and we will never submit an application for a financial product or service on your behalf without your consent.
If you are interested in pursuing an offer for a financial product or service or a co-branded service, you will need to submit information directly to the partner that provides such product or service. For example, if you are interested in a credit card offer, you will be taken to a third-party site to apply for that credit card. When you are asked to provide information to a third party in connection with such offers or co-branded services, you may be providing your information to both us and our partner. We will treat information we collect in connection with a particular offer or co-branded service in accordance with this Privacy Policy but we are not responsible for the privacy practices of such third parties. For more information, see Other Sites.
When Evolution Finance shares information about you with partners, some of those partners may also perform a soft inquiry or promotional inquiry on your credit file based on the information Evolution Finance shares with them. These inquiries will not affect your credit. However, if you apply for a line of credit or a loan directly with one or more of our lending partners, those lenders may make a hard credit inquiry of your credit file before approving your application.
The Services may permit you to submit ideas, questions, comments, suggestions, or other content, including personal information (collectively, "User Content"), that is publicly viewable (such as the public portions of your user profile or comments you post on our publicly accessible blog). We or others may reproduce, publish, distribute, or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed). Third parties may have access to this User Content and may have the ability to share it further with third parties across the Internet. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Evolution Finance does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. This Privacy Policy does not apply to any information that you disclose publicly or share with others, whether through the Service or otherwise.
We may use third-party service providers or vendors to support or perform certain aspects of the Service or our business on our or your behalf, such as hosting the Service, designing or operating the Service's features (including, where applicable, facilitating the WalletHub premium subscription features), tracking the Service's analytics, providing data used, directly or indirectly, in connection with the Service, marketing or advertising the Service, enabling Evolution Finance to contact you with offers or performing other administrative services. We may provide these third-party service providers or vendors with access to user information, including personal information, in connection with the services they are performing for you or for us. In connection with our Services, these third-party service providers or vendors may also set and access their own cookies, web beacons and embedded scripts on your device, and they may otherwise collect or have access to information about you.
We may offer sweepstakes, contests, and other promotions (each a "Promotion") through the Services or through social media or other channels. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.
While responding to subpoenas, court orders, legal processes, establishing or exercising our legal rights, or defending against legal claims if in our good faith opinion such action is required or permitted by law.
When we believe it is necessary to share information with law enforcement, government authorities or private parties to (a) protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; or (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
After we have removed your name or any other personally identifying information from it, or have combined it with other people's data in a way that it is no longer associated with you.
We may share and transfer personal information with acquirers and other relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Evolution Finance or our affiliates (including, in connection with a bankruptcy or similar proceedings).

4. Advertisements

Evolution Finance and its service providers and advertising partners display targeted advertisements, which are based upon personal information. We may allow others to "sponsor" some of your account activities, such as reviews, recommendations, status updates, and posts regarding "deals," in order to increase the likelihood that others see them. For example, if you apply for a new credit card, the respective credit card company may want to make sure that people who follow you see it so they can apply for it too. If content is sponsored, it will appear accompanied by the word "Sponsored" or something similar. Only people that could originally see the information can see the sponsored post, and no personal information about you (or your friends) is shared with the sponsor.

We may work with third-party advertising networks, marketing partners, publishers, and other entities ("Advertising Partners") to perform analytics and advertise our products and services on other online services not affiliated with us. In connection with these advertising services, we or our Advertising Partners, like Google, may use cookies, web beacons, and similar technologies to collect behavioral information about how you use our site or other online services over time in order to perform tracking and marketing analytics or serve advertisements that are more likely to be of interest to you ("Interest-Based Advertisements").

5. Editing Your Information

You can edit your Evolution Finance Account Information. This includes your marketing preferences.

New categories of marketing communications might be added to the Marketing Preferences page from time to time. Users who visit this page can opt-out of receiving future marketing communications from these new categories, or they can unsubscribe by following the instructions contained in the messages they receive.

We reserve the right to send you certain administrative communications relating to the services of Evolution Finance that are considered part of your Evolution Finance account without offering you the opportunity to opt-out of receiving them.

Other users may be able to identify you, or associate you with your user account if you include personal information in content that you post on the Service.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You can access and make changes to some of the personal information you submit at any time by logging in with your registered email address and password and making the change on the site.

When you use Evolution Finance services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and where permitted by law we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. After you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Evolution Finance is not responsible for and cannot amend the information in your credit report, which is produced by one or more credit reporting agencies. If you believe that some of the information in your credit report is inaccurate, you must contact the applicable credit reporting agency directly. Information on how to contact the credit reporting agency is contained on the "Credit Report" page for each account.

6. Security

Evolution Finance takes a number of physical, electronic, and procedural safeguards designed to protect personal information about you. However, no data transmission over the Internet, mobile device or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. If you believe your Evolution Finance account has been compromised, please report the incident using our contact form.

If you have been contacted by someone about your Evolution Finance account asking for a password, birth date or other personal information, please do NOT respond and forward the email to [email protected].

In the event that you believe that your personal safety is at risk or if you believe that you may be the victim of identity theft or other illegal conduct, please contact the appropriate federal, state or local law enforcement agencies directly.

7. Safeguarding Communications

Evolution Finance may through its Services send you email, text messages or mobile device push notifications from time to time. These communications may contain sensitive credit information, such as your credit score, creditor names, personalized savings offers, or other information about your credit. Safeguarding the information contained in any communications sent to you by Evolution Finance is solely your responsibility. Evolution Finance is not responsible for safeguarding the communications once sent to you. You may change your notification preferences on the settings page at any time.

8. Biometric Information We Collect

Policy Statement: Evolution Finance collects certain biometric data from individuals. This section of our Privacy Policy explains what biometric data we collect, how this data is used, how it is stored, safeguarded, retained, and disposed of. Evolution Finance utilizes software with biometric technology ("Biometric Software") for identity verification and prevention of identity fraud. Pursuant to the use of the biometric technology, we have instituted the following biometric information privacy policy:

Biometric Data Defined: For purposes of this section of our Privacy Policy, "biometric data" means personal information stored by us regarding an individual's physical characteristics that can be used to identify a person, such as fingerprints, voiceprints, facial shape, or scan of hand or face geometry. Biometric data includes "biometric identifiers" and "biometric information."

"Biometric identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996.

"Biometric information" means any information, regardless of how it is captured, converted, stored, or shared based on an individual's biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.

Purpose for Collection of Biometric Data: Evolution Finance, our vendors, and/or the licensor of Evolution Finance's Biometric Software collect, store, and uses biometric data for individual identification, and fraud prevention. An individual's biometric data is collected, stored, and used while the individual is an account holder of Evolution Finance, pursuant to the retention schedule provided below. Evolution Finance, our vendors, and/or the licensor of Evolution Finance's software will not sell, lease, trade, or otherwise profit from an individuals' biometric data; provided, however, the Company's vendors and the licensor of the Company's software may be paid for products or services used by the Company that utilize such biometric data.

Authorization: To the extent that Evolution Finance, our vendors, and/or the licensor of the Company's software collect, capture, or otherwise obtain biometric data relating to an individual, we must first:

Inform the individual in writing that we, our vendors, and/or the licensor of the Company's software are collecting, capturing, or otherwise obtaining the individual's biometric data, and that we are providing such biometric data to our vendors and the licensor of the Company's softwares;
Inform the individual in writing of the specific purpose and length of time for which the individual's biometric data is being collected, stored, and used; and
Receive a written release signed by the individual (or their legally authorized representative) authorizing us, our vendors, and/or the licensor of the Company's software to collect, store, and use the individual's biometric data for the specific purposes disclosed by us, and for us to provide such biometric data to our vendors and the licensor of the Company's software.

Disclosure: Evolution Finance stores all biometric data in accordance with applicable standards and laws. We will not sell, lease, trade, or otherwise profit from an individual's biometric data. We will not disclose or disseminate any biometric data to anyone other than our vendors and the licensor of the Company's software providing products and services using biometric data without/unless:

First obtaining written individual consent to such disclosure or dissemination (see Attached Acknowledgment Form);
The disclosed data completes a financial transaction requested or authorized by the individual;
Disclosure is required by state or federal law or municipal ordinance; or
Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Retention Schedule: Evolution Finance shall retain individual biometric data only until, and shall request that our vendors and the licensor of the Company's software permanently destroy such data when, the first of the following occurs:

The initial purpose for collecting or obtaining such biometric data has been satisfied; or
Within 3 years of the individual's last interaction as an account holder with us.

In no situation will biometric data be retained for more than three years after an individual's last interaction with us, unless otherwise required by law.

Data Storage: Biometric data will be stored, transmitted, and protected using a reasonable standard of care for our industry, in a manner that is the same as or that exceeds the standards of care used to protect other confidential information held by us. This includes, among other things, restricting access to biometric data to authorized Evolution Finance individuals or vendors who have a business need to access the information, and using reasonable technological means to prevent unauthorized access to the information. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which the Evolution Finance stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual's account or property, such as genetic markers, genetic testing information, account numbers, PINs, driver's license numbers, and social security numbers.

Policy Distribution and Updates: A copy of this policy will be made publicly available on this webpage.

9. Changes to this Privacy Policy

Evolution Finance may update this policy at any time without notice to you. Changes or additions to this Privacy Policy will be available in this section of the website. You can always come to this section to learn what information we gather, how we might use that information and whether we will disclose it to anyone. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page and update the date at the top of this Privacy Policy.

10. Your California Privacy Rights

If you are a California resident, please see our California Privacy Notice here for important information about our practices and your rights under California law with respect to your personal information.

11. Your State Privacy Rights

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our California Privacy Notice. For other state residents, your privacy rights may include (if applicable):

The right to confirm whether or not we are processing your personal data and to access such personal data;
The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the "sale" of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

Although we do not "sell" personal data in the conventional sense, i.e., for money, we use interest-based advertising cookies and tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is "targeted advertising" under applicable privacy laws. When we engage in those activities, we "sell" personal data (i.e., information from cookies) to third-party advertisers and analytics companies.

To exercise your rights, please click here. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision by emailing us at [email protected].

12. Questions & Suggestions

Because we want to demonstrate our commitment to your privacy, we have agreed to disclose our information practices. If you have questions or suggestions, please complete a feedback form. You may also contact us by sending postal mail to:

Attn: Customer Care - Privacy
Evolution Finance, Inc.
150 SE 2nd Ave, Suite 300, Miami, FL 33131 U.S.A.