Section 1 — Privacy Policy

1.1   Introduction

1.2   Information We Collect

1.3   How We Use Your Information

1.4   How We Share Your Information

1.5   Data Retention

1.6   Your Rights and Choices

1.7   Data Security

1.8   Children's Privacy

1.9   Third-Party Links and Services

1.10 Changes to This Policy

1.11 Contact Us

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1.1 Introduction

Welcome to CreditWise ("CreditWise," "we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the CreditWise mobile application ("App") and any related services, features, content, or applications we offer (collectively, the "Services").

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

This policy applies to all users of CreditWise, including visitors, registered users, and others who access or use our Services. Where applicable, this policy also addresses requirements under the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), and other applicable state and federal privacy laws.

 

1.2 Information We Collect

We collect information you provide directly to us, information generated through your use of the App, and information obtained from third-party sources such as credit bureaus. The categories of information we collect include:

 

1.2.1 Account Registration Data

• Full legal name — required for identity verification and credit report retrieval

• Email address — required for account communication, alerts, and login

• Date of birth — required for identity verification and credit bureau access

• Last four digits of Social Security Number (SSN) — required for identity verification; we do not collect or store your full SSN

• Residential address — required for fraud prevention

• Phone number — optional; used for two-factor authentication and account security alerts

 

1.2.2 Credit and Financial Information

• Not applicable

 

1.2.3 Device and Technical Data

• Device identifiers — Android device ID, advertising ID (if applicable)

• IP address — collected for security, fraud detection, and general location inference

• Operating system version and device model

• App version

• Crash logs and diagnostic data — collected automatically when the App experiences an error

• Network type and connection information

 

1.2.4 Usage Data

• Features accessed within the App

• Session start and end times, session duration

• In-app navigation paths and interaction patterns

• Notification open rates and alert interaction events

 

1.2.5 Communications Data

• Customer support tickets and correspondence

• In-app feedback and messages you send to us

• Survey responses and ratings you provide

 

1.2.6 Location Data

CreditWise may collect general location data (derived from your IP address) for the purpose of fraud detection and regulatory compliance. We do not collect precise GPS-based location unless you explicitly grant such permission. Precise location, if enabled, is used solely for fraud prevention and is not shared with advertising partners.

 

1.3 How We Use Your Information

We use the information we collect for the following purposes:

• Provide and operate the Services — to create and manage your account, retrieve your credit reports and scores, and deliver the core features of CreditWise.

• Improve and develop the App — to understand how users interact with the App, identify bugs and performance issues, and build new features based on usage patterns.

• Detect fraud and protect account security — to identify suspicious activity, unauthorized access attempts, and potential identity theft.

• Personalize financial recommendations — to provide tailored credit-improvement tips, financial health insights, and relevant educational content based on your credit profile.

• Legal compliance and dispute resolution — to comply with applicable laws, respond to legal process, enforce our Terms of Service, and resolve disputes.

• Marketing and promotional communications — to send you information about CreditWise features, offers, and updates, subject to your communication preferences. You may opt out of marketing emails at any time via the unsubscribe link in any marketing email or through your in-app notification settings.

• Customer support — to respond to your inquiries, resolve issues, and provide technical assistance.

 

1.4 How We Share Your Information

⚠ Important

CreditWise does NOT sell your personal information to third parties for advertising or any other commercial purpose. Data sharing is limited to the categories described below and occurs only as necessary to provide the Services.

 

1.4.1 Credit Bureaus

Not applicable

 

1.4.2 Service Providers and Vendors

We engage trusted third-party vendors who assist us in operating our business and providing the Services, including cloud infrastructure providers, data analytics vendors (who receive anonymized or aggregated data only), customer support platforms, and email delivery providers. All service providers are contractually bound to use your information only as directed by CreditWise and to maintain appropriate security standards.

 

1.4.3 Legal Disclosures

We may disclose your information to government authorities, law enforcement agencies, or other parties when required to do so by law, subpoena, court order, or other legal process, or when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of CreditWise, our users, or the public.

 

1.4.4 Business Transfers

In the event of a merger, acquisition, restructuring, sale of all or a portion of our assets, or other business transaction, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice within the App before your personal information is transferred and becomes subject to a different privacy policy.

 

1.4.5 With Your Consent

We may share your information with third parties for purposes not described in this Privacy Policy when we have obtained your explicit consent to do so.

 

1.5 Data Retention

We retain your personal information for as long as your account is active or as necessary to provide you with the Services. Specifically:

• Active account data — retained for the duration of your account plus 30 days following account closure.

• Account deletion requests — processed within 30 days of a verified deletion request. Following deletion, your personal data will be removed from our active systems.

• Audit and compliance logs — certain transactional and audit logs may be retained for up to 7 years to comply with legal, regulatory, and financial recordkeeping obligations. Such records are anonymized upon account deletion wherever technically feasible.

• Backup systems — data may persist in encrypted backup storage for up to 90 days after deletion from active systems, after which it is permanently purged.

 

1.6 Your Rights and Choices

Depending on your state of residence, you may have certain rights with respect to your personal information. We honor these rights as described below.

 

1.6.1 General Rights (All Users)

• Access — You may request a copy of the personal information we hold about you.

• Correction — You may request that we correct inaccurate or incomplete personal information.

• Deletion — You may request deletion of your personal information, subject to certain legal exceptions.

• Opt-Out of Marketing — You may opt out of receiving marketing communications at any time via in-app settings or by clicking "Unsubscribe" in any marketing email.

• Data Portability — You may request a copy of your data in a portable, machine-readable format.

 

1.6.2 California Residents — CCPA Rights

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following rights:

• Right to Know — the categories and specific pieces of personal information we collect, use, and share.

• Right to Delete — to request deletion of personal information we have collected from you, subject to certain exceptions.

• Right to Correct — to request correction of inaccurate personal information.

• Right to Opt-Out of Sale or Sharing — CreditWise does not sell or share personal information for cross-context behavioral advertising. No opt-out action is required.

• Right to Non-Discrimination — we will not discriminate against you for exercising your CCPA rights.

 

1.6.3 EU/EEA and UK Residents — GDPR Rights

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) or UK GDPR:

• Right of Access (Article 15)

• Right to Rectification (Article 16)

• Right to Erasure / Right to be Forgotten (Article 17)

• Right to Restriction of Processing (Article 18)

• Right to Data Portability (Article 20)

• Right to Object (Article 21)

• Right to Lodge a Complaint with your local supervisory authority

 

1.6.4 Virginia, Colorado, and Connecticut Residents

Residents of Virginia (VCDPA), Colorado (CPA), and Connecticut (CTDPA) have rights to access, correct, delete, and obtain a portable copy of their personal data, as well as the right to opt out of targeted advertising and profiling. To exercise these rights, please contact us using the information in Section 1.11.

To exercise any of the above rights, submit a request to [email protected] or use the "Account Settings" section within the App. We will respond to verified requests within 45 days (or as otherwise required by applicable law).

 

1.7 Data Security

We implement industry-standard technical and organizational measures to protect your personal information against unauthorized access, loss, destruction, or alteration:

• Encryption in Transit — All data transmitted between the App and our servers is encrypted using TLS 1.2 or higher.

• Encryption at Rest — All stored personal data is encrypted using AES-256 encryption.

• Access Controls — Access to personal information is restricted to authorized personnel on a need-to-know basis. Multi-factor authentication is required for all administrative access.

• SOC 2 Compliance — CreditWise is pursuing SOC 2 Type II certification, demonstrating our commitment to security, availability, and confidentiality.

• Vulnerability Management — We conduct regular security assessments, penetration testing, and code reviews.

• Breach Notification — In the event of a data breach that may affect your rights or freedoms, we will notify affected users within the timeframe required by applicable law (no later than 72 hours where required by GDPR; as required by applicable state law in the United States).

Despite our best efforts, no security system is impenetrable. We cannot guarantee the absolute security of your data. You are responsible for keeping your account credentials confidential and for notifying us promptly of any suspected unauthorized access.

 

1.8 Children's Privacy

CreditWise is not intended for use by individuals under the age of 13. We do not knowingly collect, solicit, or use personal information from children under 13. In compliance with the Children's Online Privacy Protection Act (COPPA), if we discover that we have inadvertently collected personal information from a child under 13, we will delete such information promptly.

If you believe a minor has provided us with personal information, please contact us immediately at webheadcase@webheadcase.com.

 

1.9 Third-Party Links and Services

The App may contain links to third-party websites, services, or resources. These third-party sites have their own privacy policies, and we are not responsible for their content, privacy practices, or data handling. We encourage you to review the privacy policies of any third-party services you access through the App. Our Privacy Policy applies solely to information collected by CreditWise through our App and Services.

 

1.10 Changes to This Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes, we will:

• Update the "Effective Date" at the top of this policy;

• Send you an email notification to the address associated with your account; and

• Display a prominent notice within the App prior to the changes taking effect.

For non-material changes (such as grammatical corrections or clarifications), we may update the policy without specific notice. Your continued use of CreditWise following notification of changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

 

1.11 Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: webheadcase@webheadc

• Mailing Address:
  CreditWise — Privacy Office
  PO Box 4164
  Greenville NC 27836-2164
  United States

• In-App: Contact Us

For GDPR-related inquiries, you may also contact our Data Protection Officer at webheadcase@webheadcase.com.