Privacy Policy

1. About Your Privacy and This Privacy Policy

Your privacy is extremely important to us. We are constantly putting a great deal of thought, effort, tools, resources and procedures in place in order to protect and safeguard your privacy. This document is our “Privacy Policy” and it contains details on issues related to your privacy when using our Site Services. It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Site and Site Services.

The Privacy Policy is part of our Site Terms of Use. The terms in the Privacy Policy (such as, but not limited to, “we”, “our”, “us”, “Site”, “Site Services”, “Coaching Sessions,” “Member,” Member Agreement,” etc.) have the same meaning as in our Site Terms of Use. When you use our Site and Site Services you accept and agree to both the Site Terms of Use and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Site and Site Services immediately and refrain from entering into a Member Agreement. By accessing and using our Site and Site Services you affirm that you have read the Site Terms of Use, the Privacy Policy and Member Agreement, as applicable, that you understand, agree and acknowledge to all the terms contained in each of them.

2.Information Collection, Use, and Disclosure

To let us operate the Site and Site Services effectively and to let you use the Site and Site Services, including the Coaching Sessions, we may have to collect your personally identifiable information (such as, but not limited to, your name, phone number, email address, and address), billing and payment information, profile information, log data (information such as your computer, Internet Protocol address (“IP”), pages that you visit and the amount of time spent on those pages, actions you take and other statistics), information related to the Coaching Sessions or your need for Coaching Sessions, and any information which is exchanged between you and your Divorce Professional (collectively the “Information”). In some cases, some of the Information that you give to us is considered health related data. You may decide which Information, if any, you would like to share with us, but some functions of the Site and Site Services may not be available to you without providing us the necessary Information. By deciding to provide the Information you agree to our methods of collections and use, as well to other terms and provisions of this Privacy Policy.

Protecting this Information is a top priority for us. We will never sell or rent any Information you shared in the Site and Site Services. Other than in the limited ways detailed in this Privacy Policy, we will never use or disclose any Information unless you specifically and explicitly requested or approved us to do so.

The Information may be used or disclosed to third parties for one or more of the following business or marketing purposes:

- To create your Member account on our Site and Site Services and let you log in to your account and use the Site and Site Services.
- To manage your account, provide you with customer support, and ensure you are receiving quality service.
- To contact you or provide you with information, alerts and suggestions that are related to the service.
- For billing-related purposes.
- To reach out to you, either ourselves or using the appropriate authorities, if either we or a Divorce professional Relationship Coach have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
- To match you with a divorce professional.
- To enable and facilitate the Coaching Sessions.
- To supervise, administer and monitor the Site and Site Services.
- To measure and improve the quality, the effectiveness and the delivery of the Site Services.
- Market the Site and Site Services and Coaching Sessions to you.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.
- To provide, support, personalize, and develop our Site and Site Services and Coaching Sessions.
- To personalize your Site experience and to deliver content and product and Site Services relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).

3. Opting out of Marketing Communication

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.

4. Cookies and Web Beacons

Like many websites, we use “cookies” and “web beacons” to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. A “web beacon” is a tiny image, placed on a Web page or email that can report your visit or use. We use cookies and web beacons to enable the technical operation of the Site and Site Services, to administer your log-in to your account and to collect the log data. You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. However, if you do not accept cookies you may not be able to use the Site and Site Services. The Site and Site Services may also include the use of cookies and web beacons of services owned or provided by third parties that are not covered by our Privacy Policy and we do not have access or control over these cookies and web beacons. We may also use third party cookies for the purposes of web analytics, attribution and error management.

5. Social and General Information Tools

We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.6. Phishing

Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

7. Links

The Site and Site Services may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third-party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.

8. Security

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with or exceed all applicable federal laws, state laws, and regulations regarding data privacy.

9. Service Providers

We may employ third party companies and individuals to facilitate our Site and Site Services, to perform certain tasks which are related to the Site and Site Services, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

10. Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Site and Site Services are not directed and not intended to be used by children under the age of 13. If you’re aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.

11. International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction. Regardless of where your data is stored, it will be maintained securely as outlined in this policy. Your consent to our Site Terms of Use followed by your submission of such information represents your agreement to such transfers.

12. Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Divorce Professionals may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.

13. Privacy policies of other websites

The Splitfyi Site contains links to other websites. Our privacy policy applies only to our Site, so if you click on a link to another website, you should read their privacy policy.

14. Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to opt out.

15. Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the “Contact” link at the bottom of any page in our website.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the Splitfyi Privacy Policy and applies solely to all Site Visitors, Members, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Notice.

1. Information We Collect

Through your use of our Site and Site Services, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect the following categories of personal information from its consumers within the last twelve (12) months. Additionally, we have disclosed the following categories of information for a business purpose in the past twelve (12) months:

Category	Collected	Disclosed for a business purpose
A. Identifiers.	Yes	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Yes	Yes
C. Protected classification characteristics under California or federal law.	Yes	Yes
D. Commercial information.	No	No
E. Biometric information.	No	No
F. Internet or other similar network activity.	Yes	Yes
G. Geolocation data.	Yes	Yes
H. Sensory data.	No	No
I. Professional or employment-related information.	No	No
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)).	No	No
K. Inferences drawn from other personal information.	Yes	No

Personal information does not include:

- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
  - health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  - personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Splitfyi obtains the categories of personal information listed above from the following categories of sources:

- Directly from you. For example, from information you submit on the Site and in connection with using the Site Services, including Coaching Sessions and paying for Coaching Sessions as well as in connection with registering as a Member and creating a Member account.
- Indirectly from you. For example, from observing your actions on the Site.
- From third-party business partners such as social media sites, ad networks, and analytics providers.

2. Use of Personal Information

First and foremost, Splitfyi does not sell any Personal Information.

We may use or disclose the personal information we collect for one or more of the following business or marketing purposes:

- To create your Member account on our Site and Site Services and let you log in to your Member account and use the Site and Site Services, including Coaching Sessions.
- To manage your Member account, provide you with customer support, and ensure you are receiving quality service.
- To contact you or provide you with information, alerts and suggestions that are related to the Site Services, including Coaching Sessions.
- For billing-related purposes.
- To reach out to you, either ourselves or using the appropriate authorities, if either we or a Divorce Professional have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
- To match you with a Divorce Professional .
- To enable and facilitate the Coaching Sessions.
- To supervise, administer and monitor the Site Services, including Coaching Sessions.
- To measure and improve the quality, the effectiveness and the delivery of the Site Services, including Coaching Sessions.
- Market the Site and Site Services, including Coaching Sessions to you.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To provide, support, personalize, and develop our Site and Site Services, including Coaching Sessions.
- To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).

Splitfyi will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. Disclosure of Personal Information

Splitfyi may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share the minimum necessary personal information with the following categories of third parties:

- Service providers that provide audit, legal, operational, technical or other services for us, such as:
  - Customer service
  - Technical maintenance
  - Monitoring website activity
  - Email management and communication
  - Database management
  - Billing and payment processing
  - Reporting and analytics
  - Marketing and advertising
- Divorce professionals who provide the Coaching Sessions

4. Your Rights and Choices

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.

Right to Request Access to Information

You have the right to request that Splitfyi notifies you of the personal information about you that we have collected and used. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we shared that personal information.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information for a business purpose and identifying the personal information categories that each category of recipient obtained.

Right to Request Deletion of Information

You have the right to request that Splitfyi deletes any of your personal information that we collected about you and retained. Once we receive your request and verify who you are, 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 information is necessary for us or our service provider(s) 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 seq.).
- 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 Your Rights

To exercise the rights listed above, please submit a request in writing to Splitfyi via the contact information listed in the Contact Information section. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

Your 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.

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 request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a request within forty-five (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.

For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We will not:

- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to DPO@splitfyi.com.

7. Changes to Our Privacy Notice

Splitfyi reserves the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Websites and update the Notice’s effective date. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to opt out. Your continued use of our Site and the Site Services following the posting of changes constitutes your acceptance of such changes.

8. Contact Information

If you have any questions or comments about this Notice, the ways in which Splitfyi collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Splitfyi
Data Protection Officer
323 San Vicente Blvd. Unit 1
Santa Monica, CA 90402, USA
info@splitfyi.com

General Data Protection Regulation (GDPR)

Privacy Notice for European Union and UK Residents

This General Data Protection Regulation (GDPR) Notice provides additional information about our Privacy Policy relevant to users from the European Union and the United Kingdom.

1.Controller

Splitfyi is responsible for the collection and processing of your personal data in connection with the provision of our Site Services:

Splitfyi
Controller
323 San Vicente Blvd. Unit 1
Santa Monica, CA 90402, USA

2. Data protection officer and contact

We have appointed a data protection officer to oversee the protection of your personal data. If you have any questions about this Privacy Notice or about data protection in general, or if you have any complaints regarding this Privacy Notice, our data protection principles or our handling of personal data, you can contact the data protection officer:

Splitfyi

Data Protection Officer
323 San Vicente Blvd. Unit 1
Santa Monica, CA 90402, USA
info@splitfyi.com

3. What personal data we process and collect

3.1 Personal data you provide when using the Site Services, including Coaching Sessions or creating a Member account:

Data that identifies you, such as your name, address, telephone numbers, email addresses, and your user name that you provide when setting up your Member account or at a later date.
Content that you share with other Members through our message boards, chat rooms, comments sections.
Financial information (e.g. credit card and account numbers, transaction details, and form of payment) when purchasing Coaching Sessions.
In some cases: age, gender, country of birth, nationality, employment status, family status, interests and preferences.
You may provide us with additional information through a web form or by updating or adding information to your Member account, by participating in community discussions, Member chats, inquiries, dispute resolution, customer service calls recorded with your consent, or if you contact us for any other reason regarding the Site Services.
Other data that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the data we collect.

3.2 Personal data we collect automatically when you visit our Site and use our Site Services or create a Member account

Data that is linked to your Member account as a result of a transaction in which you are involved, such as transaction amounts, time and location of transactions and form of payment or payout method.
Data that is generated through your other actions when you use our Site Services and which is linked to your Member account, e.g. searches or interests.
Data regarding all other interactions with our Site and Site Services, your advertising preferences, and your communications with us.
Location data, including your general location data (e.g., IP address) and the precise location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device.
Computer and connection information, such as statistics regarding your use of Site Services, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times, your browser history data, your language settings and your weblog information.

3.4 Personal data we collect in connection with the use of cookies and similar technologies

We use cookies, web beacons and similar technologies to collect data while you use our Site Services. We collect this data from the devices (including mobile devices) with which you access and use our Site Services. The data collected includes the following usage- and device-related information:

Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Site Services and in advertising and email content.
Data about your activities and interactions with our advertising partners including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase.
The user segment or category into which you as a user fall, for example: male, 20-49 years old, interested in cars.
Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).
The IP address from which your device accesses the Site Services.
Location data, including your general location data (e.g., IP address) and the precise location data of your mobile device. Please note that most mobile devices allow you to manage or disable the use of location services for all applications in the settings menu.

For more information about our use of these technologies and your choices, see our Cookies Policy.

4.Purposes and legal basis for data processing and categories of recipients

We process your personal data for various purposes and based on several different legal bases that allow this processing. For example, we process your personal data to provide and improve our Services, to provide you with a personalized user experience on our Site, to contact you about your Member account and our Site Services, to provide customer service, to provide you with personalized advertising and marketing communications, and to detect, prevent, mitigate and investigate fraudulent or illegal activity. We also share your information with third parties, including service providers acting on our behalf, for these purposes.

Below you will find a summary of the purposes for which we process your personal data, including the categories of recipients to whom we transmit personal data for the purposes stated, sorted by our legal basis for this processing or sharing: