Privacy Policy

We collect:

• First and last name
• Phone number
• Email address
• Payment information in certain instances, such as when you may pay for a subscription or premium program
• Contact information from your device's phonebook (with your explicit permission)
• Activity and engagement data, including your category interests, saved places, event interactions, poll responses, and other preferences you express through use of the Service

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), we collect the following categories of personal information:

• Identifiers - name, phone number, email address
• Commercial information - subscription and payment history
• Internet or other electronic network activity - browsing and interaction data within our service, including saves, poll responses, and engagement activity
• Geolocation data - city and neighborhood, and precise location if you enable it when viewing our map
• Inferences - preferences and interests derived from your activity to personalize recommendations

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• To personalize your experience (your information helps us to respond to your individual needs)
• To improve our website and product (we continually strive to improve The Nudge texts and the website based on your feedback)
• We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided
• We will share your Billing Information with a third party service provider as necessary to process your payments. The third party service provider stores your Billing Information; we do not store this information. Storage by the third party service provider of your Billing Information is subject to the privacy policies and practices of the third party service provider and is not subject to the terms of this privacy policy. By providing your Billing Information, you acknowledge and agree to use of such information by the third party service provider for purposes of processing your payment to us.
• With your explicit permission, we may collect and store contact information from your device's phonebook, such as names, phone numbers, and additional contact details. This information is used to provide features such as helping you connect with others who are also using our service. You can change or revoke this permission at any time in your device settings. Please note that disabling access to your contacts may impact certain features, such as finding and connecting with friends.

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

A cookie is a small file of information placed on your computer. Cookies can help track which websites you visit and what you do on the site.

The Nudge uses cookies for the following purposes:

• To understand site analytics to improve site features, tailor content, and enhance user experience

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

We will not sell, distribute, or lease your personal information to unrelated third parties unless we have your permission or are required by law to do so. We may need to send your personal information to our third-party vendors, who are under contractual obligations to keep this information confidential. We may also use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. Finally, if we ever sell The Nudge, or participate in a merger or consolidation, and our User data is one of the assets involved in the sale, your personal information will be part of this sale or transfer.

Sharing for Advertising Purposes

We share certain personal information (specifically, identifiers such as name, phone number, and email address) with Meta (Facebook/Instagram) to create lookalike audiences for advertising purposes. Under the CCPA/CPRA, this constitutes "sharing" of personal information for cross-context behavioral advertising. You have the right to opt out of this sharing - see "Your California Privacy Rights" below.

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 Use 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 The Nudge, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction

By creating an account or signing up for The Nudge, you affirmatively consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

For California Residents: Your use of the Service does not constitute consent to the sale or sharing of your personal information for advertising purposes. You have the right to opt out of such sharing at any time. See "Your California Privacy Rights" above for details.

For Canadian Users: We will obtain your express consent before collecting, using, or disclosing your personal information, unless an exception under PIPEDA applies. We will clearly explain the purposes for which your information is being collected at or before the time of collection. You may withdraw your consent at any time by contacting us at support@nudgetext.com or by adjusting your account settings. Withdrawal of consent may limit our ability to provide certain features of the Service to you.

For sensitive personal information (such as financial or payment information), we will always obtain your explicit consent before collection.

Our Website is not intended for children under 13 years of age. No one under the age of 13 may provide any personal information to, or on, 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/functionality, make any purchases through the Website, use any of the interactive or public comment features that may be available on this Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use.

If we learn that 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 at support@nudgetext.com.

Do Not Track (DNT) is a preference you can set in your browser to let websites know that you do not want them collecting certain information about you. We do not currently respond to DNT signals.

However, we do honor Global Privacy Control (GPC) signals. If your browser or device transmits a GPC signal, we will treat it as a valid request to opt out of the sharing of your personal information for advertising purposes, as required by the California Consumer Privacy Act.

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 regarding your personal information:

Right to Know. You may request that we disclose what personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting or sharing it, and the categories of third parties with whom we share it.

Right to Delete. You may request that we delete the personal information we have collected from you, subject to certain exceptions.

Right to Correct. You may request that we correct inaccurate personal information that we maintain about you.

Right to Opt Out of Sale or Sharing. You may opt out of the sharing of your personal information for cross-context behavioral advertising purposes. We share identifiers (name, phone number, email) with Meta for lookalike audience advertising. You may opt out at any time (see below).

Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.

How to Exercise Your Rights

You may submit a request by emailing us at support@nudgetext.com with the subject line "California Privacy Request", or by visiting the "Do Not Share My Personal Info" link on our website and logging into your account.

To opt out of the sharing of your personal information for advertising:

• Visit the "Do Not Share My Personal Info" link on our website, log in, and follow the instructions to opt out
• Enable Global Privacy Control (GPC) in your browser - we will treat GPC signals as a valid opt-out request

We will process your request within 45 days of receiving it. If we need additional time, we will notify you of the extension and the reason for it.

You may designate an authorized agent to make a request on your behalf. We may require the authorized agent to provide proof of your written permission and may need to verify your identity directly.

You can review and change your personal information by logging into your profile through the website or App and visiting your account profile page or settings page.

You may also send us an e-mail at support@nudgetext.com to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We also may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause the information to be incorrect.

If you are visiting and using the Services from the European Economic Area ("EEA"), please be aware that you are sending information (including personal data) to the United States where our partner platform's servers are located. Our staff operating outside the EEA may process this information. The information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how we store it. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal data will at all times continue to be governed by this Privacy Policy.

By supplying your personal information to us you expressly agree to the transfer of your personal information out of the EEA, and to the processing of your information in the U.S., subject to this Privacy Policy.

If you are using the Service from Canada, please be aware that your personal information will be transferred to and processed in the United States, where our servers are located. By using the Service, you consent to this transfer.

The Nudge complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL) with respect to the collection, use, and disclosure of personal information of Canadian Users.

Under PIPEDA, you have the right to:

• Know what personal information we hold about you and why we collect it;
• Access your personal information and request corrections if it is inaccurate or incomplete;
• Withdraw your consent to the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions (note that withdrawing consent may affect your ability to use the Service);
• File a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

To exercise any of these rights, please contact us at support@nudgetext.com.

We will respond to access and correction requests within 30 days. If we cannot grant your request, we will explain why.

In the event of a breach of security safeguards involving your personal information that creates a real risk of significant harm to you, The Nudge will:

• Notify you as soon as feasible, providing details about the breach and steps you can take to reduce the risk of harm;
• Notify the Office of the Privacy Commissioner of Canada (for Canadian Users) and any other applicable regulatory authorities as required by law;
• Keep a record of all breaches of security safeguards, regardless of whether notification was required.

Significant harm includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, financial loss, identity theft, and damage to or loss of property.