Privacy Policy

Overview

Thank you for reviewing the following privacy policies from Cachecraft LLC d/b/a Plus Six (Plus Six). We invite you to familiarize yourself with our privacy practices, as well as the policies most relevant to you:

• Our Consumer Privacy Policy explains how we collect, use, and share information provided by end users of our services to operate, improve, develop, and protect software and services provided by us.
• Our Privacy Statement.
• Our Cookie Policy explains how we use cookies, as well as your choices related to those small files.
• Our SMS Terms.
• Our Partner Privacy Policies, where applicable. Plus Six partners have rules and guidelines that govern the privacy practices of their applications, related tools, products, and services provided.

Consumer Privacy Policy

Effective Date July 16, 2020

Our Data Practices

Information We Collect and Categories of Sources

As explained in greater detail below, Plus Six may collect identifiers, commercial information, electronic network activity information, professional information, inferences, and other types of End User Information.

Information you provide. When you connect through a partner application or otherwise connect your mobile device through Plus Six, where applicable, we collect identifiers and login information required by the provider of your account, such as a username and password associated with a given device or user, or a security token. In some cases, we may also collect your phone number, email address, other login details, location, and other data transmitted to the partner application when connected through your mobile device (End User Information). When providing this information, you give the partner and Plus Six the authority to act on your behalf to access and transmit your End User Information from the relevant entity that provides the physical locations that integrate Plus Six technologies (we’ll call them “partner application providers” in this Policy). You may also provide us with identifiers and other information, including your name, email address, and phone number, when you contact us or enter any such information on our websites.

Information we collect from your mobile device. The information we receive from partner application providers that maintain physical locations or other applications that integrate Plus Six technologies varies depending on the specific Plus Six services partners use to power their applications, as well as the information made available by those providers. But, in general, we collect the following types of identifiers, commercial information, and other personal information from the partner application providers:

• Account information, including name, account name, account type, account ownership, and other account-specific information;
• Identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information;
• The data collected from your mobile device includes information from all your accounts accessible through a single set of account credentials.

Information we receive from your devices. When you use your device to connect to our services through a partner’s application, we receive identifiers and electronic network activity information about that device, including IP address, hardware model, operating system, which features within our services you access, and other technical information about the device. We also use cookies or similar tracking technologies to collect usage statistics and to help us provide and improve our services. You can find more information about how we use cookies and your related choices in our Cookie Policy.

Information we receive about you from other sources. We also receive identifiers and commercial information about you directly from the relevant partner or other third parties, including our service providers, partners, and identity verification services. For example, partners may provide information such as your full name, email address, phone number, or information about your mobile device and account transactions.

Inferences we derive from the data we collect. We may use the information we collect about you to derive inferences. For example, we may infer your location or your identity based on information available from other sources.

How We Use Your Information

We use your End User Information for a number of business and commercial purposes, including to operate, improve, and protect the services we provide, and to develop new services. More specifically, we use your End User Information:

• To operate, provide, and maintain our services;
• To improve, enhance, modify, add to, and further develop our services;
• To protect you, our partners, Plus Six, and others from fraud, malicious activity, and other privacy- and security-related concerns;
• To develop new services;
• To provide customer support to you or to partners, including to help respond to your inquiries related to our service or partners’ applications;
• In connection with business transactions;
• To investigate any misuse of our service or partners’ applications, including violations of ours or our partner’s terms of service, criminal activity, or other unauthorized access to our services; and
• For other notified purposes with your consent.

Our Lawful Bases for Processing (EEA and UK End Users Only)

For individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”), or subject to the privacy laws thereof, our legal basis for processing your End User Information will depend on your choice to proceed with the partner’s application. Plus Six (or our partner’s) are not aware of which end users may be subject to European or UK privacy laws and therefore to the extent you object to this privacy policy, we rely on you to withdraw from use of the Plus Six or partner technology, so that we do not collect and process End User Information. You have the right to withdraw your consent at any time per the instructions provided in this Policy, and you may notify us after use so that we can delete your information.

How We Share Your Information

We share your End User Information for a number of business purposes:

• With the partner of the application you are using and as directed by that partner (such as with another third party if directed by you);
• To enforce any contract with you;
• With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or partners;
• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
• In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
• Between and among Plus Six and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;
• As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, partners, our partners, Plus Six, and others; or
• For any other notified purpose with your consent.

We may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

We do not sell End User’s personally identifiable information that we collect.

Our Retention Practices

We retain End User Information for no longer than necessary to fulfill the purposes for which it was collected and used, as described in this Policy, unless a longer retention period is required or permitted under applicable law. As permitted under applicable law, even after you stop using an application or terminate your account with one or more partner, we may still retain your information (for example, if you still have an account with another partner). However, your information will only be processed as required by law or in accordance with this Policy.

Please refer to the “Your Data Protection Rights” section for options that may be available to you, including the right to request deletion of End User Information. You can also contact us about our data retention practices using the contact information below.

Your Data Protection Rights

Under applicable law, and subject to limitations and exceptions provided by law, if you are located in certain jurisdictions, you may have certain rights in relation to the End User Information collected about you and how it is used, including the right to:

• Access End User Information collected about you;
• Request that we rectify or update your End User Information that is inaccurate or incomplete;
• Request, under certain circumstances, that we restrict the processing of or erase your End User Information;
• Object to our processing of your End User Information under certain conditions provided by law;
• Where processing of your End User Information is based on consent, withdraw that consent;
• Request that we provide End User Information collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible; and

Under the California Consumer Privacy Act (“CCPA”), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to End User Information we have collected about you that constitutes personal information under the CCPA:

• To request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes).
• To request deletion of your personal information;
• To opt-out of any “sales” of your personal information, if a business is selling your information; and
• To not be discriminated against for exercising these rights.
• To exercise your data protection rights, where applicable, you can submit a request by contacting us as described in the “Contacting Plus Six” section below. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.
• We will consider all such requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.

Changes To This Policy

We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on Plus Six’s website and update the effective date at the top of this Policy. We will also notify partners of any material changes in accordance with our partner agreements, as they are generally best positioned to notify their end users about such changes to this Policy, as appropriate.

Contacting Plus Six

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at connect@plus-six.com or by mail at:

Cachecraft LLC d/b/a Plus Six
Attn: Legal
2859 Umatilla St
Denver, CO 80211
U.S.A.

Privacy Statement

Effective Date July 16, 2020

Thank you for using Plus Six!

This Privacy Statement explains the ways Plus Six (collectively, “Plus Six”, “we”, “our”, and “us”) collect, use, and share information about you in connection with your access to or use of Plus Six’s websites and our products and services (collectively, “Services”), and in connection with any other information we collect when you interact with us, except as outlined in the paragraph below. We hope you will take some time to read this Privacy Statement carefully.

Please note that this Privacy Statement does not apply to the information we collect about the end users of our partners’ software applications or when you otherwise connect your financial accounts through Plus Six, except as otherwise provided herein.

Our Data Practices

Information We Collect and Categories of Sources

As explained in greater detail below, Plus Six may collect identifiers, electronic network activity information, professional information, location information, and other types of information.

Information you provide to Plus Six directly. We collect the information you provide directly to us, such as the information you provide when you create a partner account, update your profile, fill out our “contact us” form, sign up for our emails, request customer support, enroll in billing, execute a services agreement, complete a compliance questionnaire, or otherwise communicate with us. The types of information we collect include identifiers (such as full name, email address, postal address, phone number, driver’s license, and taxpayer identification number), professional information (such as company name and title), and any other information you choose to provide (such as date of birth or personal information you may disclose to us in support messages).

Information we receive when you test our technology. You may provide us with login information for your account with a financial institution to test and evaluate how our technology will appear and operate in your application. If you test our technology in this way, we collect information as described in our End User Privacy Policy.

Information we collect when you use our Services. When you use our Services, we automatically collect information about you as follows:

• Log Information: We collect log files when you use our Services, which includes identifiers and electronic network activity information, such as the type of browser you use, access times, pages viewed, and your IP address.
• Approximate Location: We derive the approximate location of the device you use to access our Services from your IP address.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect identifiers and electronic network activity information when you use our Services, including cookies and web beacons. Cookies are small data files stored by your web browser, on your hard drive, or in device memory that help us improve our Services and your experience, determine usage of parts and features of our Services, and monitor for and detect potential harmful conduct. Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. You can find more information about how we use cookies and your related choices in our Cookie Policy.

Information we collect from other sources. We also collect information about you from other sources. For example, we may collect information from other members of your company and from vendors that help us identify new customers, including identifiers, such as your name, email address, and social media profile URL.

How We Use Your Information

We use the information we collect for the following business and commercial purposes:

• To operate, improve, and develop our Services;
• To verify your identity and the identities of other members of your company;
• To bill partners for our Services and to transmit payment;
• To comply with law, such as for tax reporting purposes;
• To send you technical notices, updates, security alerts, and administrative messages;
• To respond to your comments, questions, inquiries, and customer service requests;
• To help personalize the Services experience for you;
• To communicate with you about products, services, offers, and events offered or sponsored by Plus Six, and to provide news and other information we think may be of interest to you;
• To monitor and analyze trends, usage, and activities in connection with our Services;
• To detect and prevent fraud, malicious activity, and other illegal activities;
• To protect the rights, privacy, safety, or property of Plus Six and others; and
• For any other purpose described to you when the information was collected.

Our Lawful Bases for Processing (EEA and UK Only)

Our legal basis for processing the information we collect related to individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”) will depend on the information concerned and the context in which we collected or processed it. Generally, however, we will normally only collect and process information where:

• we need to fulfill our responsibilities and obligations in any contract or agreement with you;
• to comply with our legal obligations under applicable law;
• the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to provide or update our services); and
• you have given your consent to do so.

How We Share Your Information

We share information about you as follows, or as otherwise described in this Privacy Statement:

• With our data processors and other service providers, partners, contractors, or vendors in connection with the services they perform for us, including collection agencies in the event of delinquent payments from our partners;
• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena), including in connection with requests from law enforcement or other governmental authorities;
• If we believe your actions are inconsistent with our agreements or policies, or to protect the rights, privacy, safety, or property of Plus Six or others;
• In connection with a change in ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
• Between and among Plus Six and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership; and
• With your consent or at your direction.

We also collect, use, and share aggregated, de-identified, or anonymized information for any purpose permitted under applicable law.

We do not sell or rent personal information that we collect.

Other Details

Advertising and Analytics Services Provided by Others

We allow third parties to provide analytics services and serve advertisements on our behalf across the internet, including Google Analytics. These entities use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information is used by Plus Six and these third parties to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and to better understand your online activity.

For more information about interest-based ads, including to learn how you may be able to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices; the European Interactive Digital Advertising Alliance (for European users); or the Digital Advertising Alliance of Canada (for Canadian users). And for more information about how Google uses your data, please visit www.google.com/policies/privacy/partners/.

International Data Transfers and Data Retention

We may transfer the information we collect about you across international borders, including from the EEA or UK to the United States, for processing and storage. To the extent that the information we collect about you is transferred from the EEA to territories/countries for which the EU Commission has not made a finding that the legal framework in that territory/country provides adequate protection for individuals' rights and freedoms for their personal data, we will transfer such data consistent with applicable data protection laws, including through the use of the EU Commission-approved standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below.

If you are in the EEA or UK, we retain your personal data for no longer than necessary to achieve the purposes for which it was collected, unless a longer retention period is required under applicable law.

Your Choices

• Partner Account Information. You may update information you provide to us as part of your online partner account by logging into your account or by contacting us.
• Cookies. You can find more information about how we use cookies and your related choices in our Cookie Policy.
• Marketing Communications. You may opt out of receiving marketing emails from Plus Six by following the instructions in those emails. If you opt out and are one of our partners, subject to limitations and exceptions provided by law, we may still send you other types of emails, such as those about your account or our ongoing business relations.

Your Data Protection Rights

Depending on your jurisdiction, you have certain rights under applicable law regarding the personal data we process, which may include the right to request access or deletion.

In certain jurisdictions, including the EEA and UK, and subject to certain limitations and exceptions, you may have the right to: (i) know how we process your personal data; (ii) request access to or rectification of your personal data; (iii) object to, or request that we restrict, the processing of your personal data; (iv) request that we delete your personal data; (v) request that we provide the personal data you provided to us in a structured, commonly used and machine-readable format, for transmission to another controller; (vi) revoke consent at any time where our processing is based on your consent; and (vii) lodge a complaint with your local supervisory authority (if you’re in the EEA or UK, please see this page for contact details).

If you are a resident of California, subject to limitations and exceptions provided by law, you have the right to: (i) request access to the categories and specific pieces of personal information collected about you in the last twelve months (including personal information disclosed for business purposes); (ii) request deletion of your personal information; (iii) opt-out of any sales of your personal information if a business is engaged in selling your information; and (iv) not be discriminated against for exercising these rights.

As described above in “Your Choices,” if you are one of our partners, you can conveniently access your online account information by logging into your account or by contacting us. To otherwise exercise your data protection rights, where applicable, please submit a request using our online form (available here), or contact us at the contact information provided below. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

Changes to this Statement

We may update or change this Privacy Statement periodically. If we make any updates or changes, we will notify you by updating the effective date at the top of this Statement. We may also provide notice of any changes through other means, such as placing a notice on our homepage at plus-six.com or sending you an email. We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our data practices and the choices available to you.

Cookie Policy

Effective Date July 16, 2020

What Are Cookies

Cookies are small data files stored on your browser or device, which can be in the form of session cookies (which expire once you close your web browser) or persistent cookies (which stay on your browser for a set period of time or until you delete them). They generally contain information such as website preferences, user settings, and browsing history. This information helps us recognize you as you interact with or revisit our Services.

Cookies may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). For example, we use first-party cookies to remember your settings and preferences, such as language and location. We also integrate third-party analytics cookies, like Google Analytics, onto our websites to help us understand how you are using our websites so that we can improve them.

We also use other technologies that function similarly to cookies. For instance, we use web beacons (also called pixels), which are small images on a web page or in an email. Web beacons collect information about your browser or device and can set cookies. In addition, we use local storage, which allows data to be stored locally on your browser or device.

How We Use Cookies

We use cookies for a number of reasons, like helping us determine the popularity of certain content, improving our Services and your experience, and to better understand your online activity. The cookies we use generally fall into one or more of the following categories:

Your Choices

You have the right to choose whether or not to accept cookies. However, since cookies can be an important part of how our Services work, if you remove or reject cookies, this could affect the availability and functionality of our Services.

Changes to This Policy

We may update or change the cookies (or similar technologies) we use from time to time. The most up-to-date version of this Policy will be posted on our website, and if we make any changes, we will update the effective date at the top of the Policy. We recommend that you check back periodically for any changes.

Contacting Us

If you have any questions about our use of cookies or this Policy, you can contact us at connect@plus-six.com.

Our SMS Terms

Effective Date July 16, 2020

By agreeing to these Short Message Service Terms (SMS Terms), you consent to receive automated SMS messages from Cachecraft LLC d/b/a Plus Six (Plus Six), and any of its SMS-related service providers (or through our partners), including through the use of an automatic telephone dialing system, at the telephone number you have selected. Message and data rates may apply.

By agreeing to these SMS Terms, you also authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber and device details, if available, to Plus Six and its partners for the duration of the business relationship, solely for identity verification and fraud avoidance.

If you do not wish to receive communications from Plus Six or its partners, or if you no longer want your wireless operator to share information about you with Plus Six or its partners, you agree to reply STOP to any SMS message from Plus Six or sent on behalf of Plus Six in order to opt out of the SMS message notifications. You may receive an additional SMS message confirming your decision to opt out.