Date of Last Revision: July 15th, 2021
We want to build an indispensable platform to aid people in making smart comparisons and connecting them to companies for their financial needs. Knowing certain things will help us do that better.
We collect Personal Data from you when you voluntarily provide such information, including but not limited to when you access, complete and/or use one of our online forms, tools or content items, contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services.
If you complete one of our online forms, you may be asked to provide Personal Data in order to provide the Services as described:
|Demographic Data||Contact data such as your name, address (including zip code), email, zip code, date of birth, social security number and phone number.|
|Personal Records||Estimated credit score, payment history, employment status, ownership or rental history, income, education level and degrees, and other information.|
|Account Registration||If we have registration and/or a log-on experience, this would include the information we collect when you create an account such as name, email and/or other information to provide account related functionalities to our users.|
|Feedback and Support||If you provide us feedback or contact us for support, we may collect your name and e-mail address, as well as any other content that you send to us. We collect and use this data based upon our business need to receive and act upon your feedback or issues.|
|Surveys||If you voluntarily submit certain information to our services, such as filing out a survey about your user experience, we may collect the information you have provided. We may collect this information to understand your opinions, better market our services and to collect relevant information about our business.|
For clarity, Even/Fiona collects Personal Data from you to, in part, provide you with personalized content and information related to financial products, but Even/Fiona is not a lender, credit card issuer, bank or other similarly situated financial institution. Any loan or related product to which you may become a party is solely transacted between you and the applicable provider and is not a part of the Services.
Whenever you interact with the Services, Even/Fiona may automatically receive and record information from your computer, browser and/or mobile device, which may include the following:
The requests you make to Even/Fiona may contain your IP address (the Internet address of your computer). We may use visitors’ IP addresses for various purposes, including to display customized content and analyze and report upon usage of the Services; to diagnose and prevent service or technology problems affecting the Services; and to monitor and prevent fraud and abuse.
We may collect information on the type of device you are using, operating system, settings, browser and OS information, unique device identifiers, network information and other device-specific information. The information collected may depend on the type of device you use and its settings.
Location Data: We may collect location data based on your IP address and the geolocation of your device. We collect this data to better tailor our services to you and to help provide service offerings available to you in your geographic area.
Usage Information: We collect information about how you use our Services, such as the types and categories of content that you view or engage with, the features you use, the actions you take, the and the time, frequency and duration of your activities on the Site.
A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Cookies help provide additional functionality to the Services, customize users’ experiences with the Services and help us analyze Services usage more accurately for research, advertising and marketing purposes. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’ features.
Please note that we use Google Analytics cookies for data analytics purposes, and you can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. You may choose to opt-out of Google Analytics by installing their opt-out browser add-on https://tools.google.com/dlpage/gaoptout/
Additionally, we may share certain information with companies like Facebook and Taboola, that allow us to create custom or Lookalike Audiences. You may learn more about Facebook Lookalike Audiences click here and about your off-Facebook activity and how to opt out of having such activity sent to Facebook click here. You may find more information about Taboola and their cookie practices here and if you wish to opt-out of such activity sent to Taboola click here.
In an ongoing effort to better understand and serve the users of the Services, Even/Fiona often conducts research on consumer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Even/Fiona may share this aggregate data with our affiliates, agents, service providers and other third parties with whom we do business. This includes, but is not limited to, information such as consumer financial trends, choices and comparisons. This aggregate information does not identify you personally. Even/Fiona may also disclose aggregated user statistics in order to describe our services to current and prospective financial service providers, and to other third parties for other lawful purposes.
To identify and potentially personalize the Services when you visit our Site
To provide products and services
For fraud and information security
To improve the Services
To conduct analytics such as usage trends
To respond to inquiries related to support or other requests
To send marketing and promotional materials about the Services
To manage our relationships
To build aggregated user profiles and segments
For more clarity, if you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email or provide feedback in any way such as to ask a question or report an issue with the Services, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to learn about certain products that may be available to you through third-party providers, we will use your Personal Data to provide you with information on such products and providers, to provide other personalized services, and/or to monitor your use of the Services.
Even/Fiona and our subsidiaries and affiliates (the “Even/Fiona Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services.
Even/Fiona and Even/Fiona’s financial providers with whom we share your information for product pricing may use your Personal Data to communicate with you by email, postal mail or by text message to provide you with:
Information regarding your application status, or transactional information relevant to your account.
Opportunities, surveys and promotions related to your submitted request available through the services or products of our financial providers that we think may be of interest to you.
Information or content – such as articles or white papers – that we believe would be of interest to you through email, text messages, or postal mail.
You may choose to unsubscribe from marketing emails or mail by emailing email@example.com and/or at firstname.lastname@example.org or at the address below and asking to be removed from any correspondence. Although we will remove you from our marketing lists you may still receive transactional messages related to the Services.
Even/Fiona is not in the business of selling your information to third parties. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Certain Business Partners: When we partner with other businesses to provide content or services to you or to such business partners, we may share relevant Personal Data in connection with such content or services. For example, we will share your contact and other information with a lender and/or service provider if the information you provide in one of our online forms or tools matches certain criteria for loan products offered by such lender and/or loan originator.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. Your Personal Data could also be shared with professional advisors and counterparties during such events.
Business Analytics: When we partner with certain businesses in order to learn and improve user interface, content, site performance, and our offerings. For example, Information may be shared in order to improve your experience on partner sites as well as on our site.
Agents, Consultants and Related Third Parties: Even/Fiona, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and providing marketing assistance. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Even/Fiona may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including responding to a subpoena, warrant, or other legal process, (ii) protect and defend the rights or property of Even/Fiona, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
In general, you can visit the Services without providing Personal Data. If you choose not to provide any Personal Data, however, you may not be able to use certain features of the Services.
If we have registration and/or a log-on experience, this would include the information we collect when you create an account such as name, email and/or other information to provide account related functionalities to our users. If you choose to register and/or provide information, you agree to provide and maintain true, accurate, current and complete information about yourself.
Please note that if you allow others to use your account (including others you permit to set up profiles under your account), they may be able to view information about your account or any of the profiles under your account.
If you no longer what to use our Services, you can deactivate your account by contacting us at email@example.com or at the address below.
Due to regulatory and information retention requirements, we do not delete your information when you deactivate your account. We will, disable your account and cease sending any communications.
Access To Information:
We rely on you to ensure your information is accurate and up-to-date. To keep your Personal Data accurate, current and complete, please contact us as specified at the below address or firstname.lastname@example.org. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
Children’s Privacy Online:
Links To Other Websites:
Through the Site, you can choose to access certain social media websites and services that are owned and/or controlled by third parties (including, without limitation, Facebook, Twitter, Instagram, and others) (such websites and services, collectively, the “Social Media Services”). When you elect to access and use the Social Media Services, you will be sharing your information (which will include personal information if you elect to share such information) with those Social Media Services. As with other Third-Party Sites, the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by the policies and procedures we describe here. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including Even/Fiona. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of the applicable Social Media Services provider.
Even/Fiona takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Even/Fiona via the Internet.
By using the Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or by sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at email@example.com or firstname.lastname@example.org
If you are, or believe you have become, a victim of identity theft, you may visit the website of the Federal Trade Commission at https://www.identitytheft.gov for free information to help guard against identity theft and guidance on the recovery steps you can take.
Other Terms and Conditions:
Your access to and use of the Services is subject to the Terms of Service at
How We Respond to “Do Not Track” Signals:
California Consumer Privacy Act (CCPA)
The CCPA affords California residents certain rights over their personal information (subject to certain exceptions). This section applies only to “personal information” that is subject to the laws of the state of California. Most of our data collection and use practices are governed by our Gramm-Leach-Bliley Privacy Notice. Please review our CCPA Privacy Statement for our privacy disclosures and information on how to exercise your rights.
To exercise your rights click here.
To keep your Personal Data accurate, current and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
You may contact us as follows:
50 West 23rd Street
New York, NY 10010
The following CCPA Notice at Collection and Policy shall not apply to the collection, processing, sale or disclosure of any information (i) that a consumer provides to us to obtain a financial product or service, or (ii) about a consumer resulting from any transaction involving a financial product or service; or (iii) about a consumer resulting from a consumer’s express direction to disclose the consumer’s information; or (iv) we otherwise obtain about a consumer in connection with providing a financial product or service to that consumer.
To better understand your rights in respect of any such information excluded from the following CCPA Notice at Collection and Policy, please instead reference the Even Financial Agreements and Policies Page, which you may access at https://evenfinancial.com/about/legal.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA (“Personal Information”).
In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:
A real name,postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Categories of Personal Information
listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e)).
A name, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history,or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age, citizenship, marital status, medical condition, sex, veteran or military status.
D. Commercial information.
|Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
I. Professional or employment-related information.
Current or past job history or education information
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.
Profile reﬂecting a person's preferences, characteristics, behavior automatically derived from use of our services (e.g. through cookies) or from service providers
Personal Information does not include:
Publicly available information from government records.
De-identified or aggregate consumer information.
Other information to the extent excluded from the CCPA's scope, like:
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CalFIPA), and the Driver's Privacy Protection Act of 1994;
Health or medical information that constitutes clinical trial data or that is otherwise covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH), or the California Confidentiality of Medical Information Act (CMIA);
Personal Information we may collect from a natural person (including, without limitation, emergency contact information for that natural person and such other Personal Information we may need in order to administer benefits for such natural person) in the course of the natural person applying for a job with us or otherwise in connection that natural person acting as our employee, owner, director, officer, medical staff member, or contractor; and
Personal Information we may collect from a natural person who is acting as an employee, owner, director, officer, or contractor of another company with which company we are communicating or for which company we are otherwise evaluating or actually providing a product or service.
Sources of Personal Information
With respect to each of the categories of Personal Information listed in the table above, we obtain such Personal Information from a variety of sources, including from:
our customers and consumers, with respect to both online and ofﬂine interactions they may have with us or our service providers and other entities with whom you transact;
others with whom you maintain relationships who may deal with us on your behalf; credit bureaus;
identify verification and fraud prevention services;
marketing and analytics providers;
social media platforms;
internet service providers and the devices you use to access our websites, mobile applications, and online services;
operating systems and platforms;
third party through the use of an application program interface (API), such as Facebook or Plaid;
With respect to each of the categories of Personal Information listed in the table above, we may use or disclose such Personal Information for any one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided.
To provide you with information, products or services that you request from us;
To provide you with email alerts, event registrations and other statements concerning our products or services;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
To detect and protect against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecute the same;
To debug to identify and repair errors in our systems;
As otherwise necessary or appropriate to protect the rights, property or safety of us, our customers, consumers, or others;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
For such purposes as may be necessary or appropriate in connection with audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
To improve our website and apps and present their content to you;
For testing, research, analysis and product development;
For short-term, transient use including contextual customization of ads; and/or
As otherwise described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
With respect to each of the categories of Personal Information listed immediately below, we may disclose such Personal Information to a third party for any of the business purposes identified above.
In the preceding twelve (12) months, we have disclosed the above categories of Personal Information for each of the business purposes identified above.
With respect to each of the categories of Personal Information listed immediately above, we may disclose such Personal Information for a business purpose to the following categories of third parties:
Marketing partners, such as those partners who you interact with that maintain a link to our services on their site, embeddable widget or our API
Providers, such as third parties as our customers or consumers may direct us to disclose their personal information
We do not, and will not, sell (as that term is defined by the CCPA) any Personal Information that we collect.
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
The categories of personal information we have collected about you.
The categories of sources from which we collected your personal information.
The business or commercial purposes for our collecting or selling your personal information.
The categories of third parties to whom we have shared your personal information.
The specific pieces of personal information we have collected about you.
A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain: • The categories of your personal information we have sold. • The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the Personal Information is necessary for us or our service providers to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 sec.)
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To make a request according to your rights under CCPA, click here or mail your request for the attention of the Privacy / Legal Department to Even Financial., 50 West 23rd Street, Suite 700, New York, NY 10001. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process
The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Verifying Your Request
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. We may otherwise limit our response to your request as permitted under applicable law.
Whenever feasible, we will match the identifying information provided by you to the Personal Information we maintain. Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular consumer's personal information (e.g., data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to verifiable consumer requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
With respect to requests submitted on your behalf by your authorized agent, please note that we may deny a request from an authorized agent if the agent cannot provide your signed permission demonstrating that they have been authorized by you to act on your behalf.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account.
We will not discriminate against you for exercising any of your CCPA rights.
If third-party information collection on our sites constitutes the sale of personal information, such as the collection of certain information, including cookies and similar information stored on your browsers, advertising identifiers on your mobile devices, and/or the IP address of your devices when you visit our sites, you can exercise your right to opt out of thes sales by:
Visit privacyrights.info to opt out from sales of this type of personal information by third-party businesses that participate in the DAA’s CCPA Opt-Out Tool, and
Visit myaccount.google.com/data-and-personalization, scroll down to the “Ad personalization” section, click “Go to ad settings” and toggle “Ad personalization” to OFF, and
California “Shine the Light” law
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. We do not currently engage in the type of sharing covered by that law and so no such list exists. We do not make any representations concerning third parties that do not collect personal information directly through our Services.
Changes to Our Privacy Statement
If you have any questions or comments about this statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
50 West 23rd Street
New York, NY 10010