This policy describes the types of information SEVENTY THREE LLC (“Chokinbako”, “Company” or “We”) may collect from you or that you may provide when you visit and utilize the budgeting software available through our apps, software, and the website chokinbako.app (collectively, our “Website“). This includes our practices for collecting, using, maintaining, protecting, and disclosing that information and the basis for doing so.
This policy applies to information we collect on the Website, in e-mail, text and other electronic messages between you and this Website and, through mobile and desktop applications you download from this Website or other services (such as the iOS App Store or Google Play Store), which provide dedicated non-browser-based interaction between you and this Website.
Collection and Use of Personal Data
We process data:
- in order to provide the services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide our services without an email address to sign into your account, conduct customer support, or send educational materials; we cannot provide the service without users providing financial information on which a budget is based;
- where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- to protect your vital interests, or those of others, such as in the case of emergencies;
- where you have made the information public;
- where necessary in the public interest;
- where necessary for the purposes of Chokinbako’s or a third party’s legitimate interests, such as those of visitors, members or partners;
- where you provide consent (for example, to join email mailing lists).
We also process your data based on our legitimate interest in:
- providing a quality service and in improving that service;
- ensuring the services are secure;
- protection against fraud, spam and abuse, etc.;
- understanding how clients and visitors interact with our websites and services, so that we can continuously improve the experience and effectiveness of doing so.
Categories of data we collect
We collect information about you, including information that directly or indirectly identifies you, through your use of Chokinbako. We do so:
- when you provide the information, through filling out forms or otherwise providing information on our websites and apps;
- when we connect to your financial institutions in order to retrieve transaction data on your behalf;
- when you use location services to record transactions in our mobile apps;
- when you correspond with us to receive customer support via email or chat.
- Your email address that you provide to us as a username, or that is provided to us by your social media account(s) if you use those for sign-in.
- Your IP address when you interact with our website and apps.
- When you chose to directly link financial accounts to Chokinbako, your login credentials (including usernames and passwords) for the accounts you link to our services, account security and/or challenge questions for those accounts, and other information from the financial accounts that you link to our service (including account balances, transactions and holdings).
- Your location when you record a transaction in our mobile applications and have previously activated location services.
- Records and copies of your correspondence (including e-mail addresses different than that used to establish your account), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
Cookies & technical data
Chokinbako collects information as visitors and clients browse and interact with the website and/or apps.
When you visit our website, we may place a cookie on your browser so that our system can recognize you when you make a return visit. Third parties may also place cookies on your browser for targeted advertising purposes. That cookie allows us to recognize your browser on a return visit. We do not otherwise collect or process data when you are a Visitor.
Opting out of Cookies
There are a number ways to limit the cookies that your browser accepts or limit the way in which they’re used.
One way to limit cookies is by opting out of third party cookies/advertising networks, like Google Analytics and the Digital Advertising Alliance. If you are in Canada or the EU you can use the DAAC’s youradchoices.ca, or EDAA’s youronlinechoices.eu respectively. Some people use what are called “Ad Blockers” to limit advertising/tracking. We don’t endorse any particular Ad Blocker, but want you to know that it’s an option since you’re reading this and are likely quite privacy-minded.
Opting out of cookies using the above methods likely won’t cause problems with our services per se, but it makes it harder for us to spend our advertising budget effectively because we won’t know how you discovered Chokinbako and sometimes won’t even know if you’re already a customer of ours. Among other things, that means we might embarrass ourselves by showing you the same advertisement even if you are already a fan. Depending on the services you block, it might also make it harder for us to know how you’re using our apps, or know if you’re running into problems.
Another way of limiting cookies is by controlling cookies in your web browser’s settings. (Disabling cookies in this way is more likely to actually break or worsen the experience when using some of our services).
Here are instructions for the most common browsers:
- Google Chrome
- Internet Explorer
- Microsoft Edge
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
Recipients of personal data
We do not sell users’ data. (And we never have!)
- To contractors, service providers, and other third parties we use to support our business, in particular providing infrastructure and analytics services, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- In aggregated form, and/or information that does not identify any individual.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service or terms of sale and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SEVENTY THREE LLC, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Categories of third-party providers
Categories of services used to process data include:
Infrastructure & Fulfillment
Chokinbako partners with third-parties to provide storage and server access that acts as infrastructure for our website and apps. In addition, we partner with third-parties to fulfill payments and transactions in fulfillment of our terms.
Chokinbako partners with third-parties to help us monitor and analyze website traffic and can be used to keep track of User behavior, helping us to improve the services and experience of using them.
Chokinbako partners with third-parties to help us receive, process, and respond to customer support requests, as customer support and education are a core part of the services offered.
Performance and Logging
Chokinbako partners with third-parties that assist us in monitoring the stability of the website and applications and resolving issues or errors with the service.
Chokinbako partners with third-parties to manage receipt of consent to send marketing emails and sending those same emails.
We retain account data for a period of time after an account expires, whether through trial expiration or subscription expiration, unless you delete your account as described below.
Once an account has become inactive beyond the period of time described below, we will delete its budget data – if you don’t need Chokinbako, we don’t need your account data, and you probably don’t want us to have it. (Keep in mind that if you cancel your account, it remains active until the end of your subscription. The timeline below doesn’t start until that subscription expires.)
We will delete accounts and their data:
- For an expired trial, a minimum of one hundred-twenty (120) days after the expiration of the trial;
- For an expired subscription, a minimum of three years after the expiration of the subscription.
After deletion, we retain your email address in order to be able to confirm deletion of associated data.
Automated data processing
In conjunction with a third-party payment processor, we use automated analysis to screen for suspicious or fraudulent transactions.
When we make solely automated decisions that affect you in a legal or a significant way, you have the right to provide your point of view and have those decisions reviewed by a member of our staff.
Third-party applications and integrations
When you choose to use third party apps (such as the Chokinbako Toolkit or other OAuth apps based on our API), plug-ins, or websites that integrate with the Services, they may receive your information and content, including your personal information, photos, and your activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Chokinbako is not responsible for the terms or policies of third parties.
Children under the age of 13
Our Website is not intended for children under 13 years of age (or 16 years of age for those who habitually reside in the EU, which applies to the remainder of the paragraph that follows). No one under these ages may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.
We have established a number of procedures to help you manage your personal data.
You may delete your account by visiting your account settings. This will delete all personal data with the exception of email correspondence. Note that the process to delete all data associated with your account will take up to thirty (30) days, with log files retained for up to eighteen (18) months.
Adjust Notification and Email Preferences
Updating Account Information
You may correct, amend, or update your email and/or password at any time by adjusting that information in your account settings.
Object, Restrict, or Withdraw Consent
You may withdraw consent for processing in the situations described above. Other data processing we conduct is necessary for the fulfillment of our Terms of Service and/or our legitimate interest and/or legal reasons, and deletion of your account and data is required to cease processing.
California privacy rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
Chokinbako has not and does not transfer information to third parties for direct marketing purposes. In the event we decided to do so in the future, we would provide affirmative consent and opt-out procedures.
EU Visitors and Clients’ Rights
Rights to access, deletion, portability, and restriction are described above. In addition, if you habitually reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.
The Services offered by Chokinbako are operated from the United States. If you are located outside of the United States and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed, and stored in the United States, as it is necessary to provide the Services and perform the Terms of Service.