Onward Privacy Policy
Last Updated August 29, 2022
Onward Solutions, Inc. (doing business as “Onward,” “we,” “us,” and/or “our”) values the privacy of individuals who use our expense-tracking software-as-a-service mobile application, website (the “Site”), and related services (collectively, the “Service”).
This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices.
Before using the Service or submitting any Personal Data to Onward, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the collection, use, disclosure, and procedures described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not access or otherwise use the Service. Beyond the Privacy Policy, your use of the Service is also subject to our Terms of Service (https://onwardapp.com/tos/) and this Privacy Policy is incorporated into those Terms.
- PERSONAL DATA WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
A. Personal Data You Provide to Us
Registration and Profile Information: We collect Personal Data when you register for an account, sign up for notifications or updates, or participate in our surveys. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include first and last name, email address, child and co-parent names, co-parent phone number, shared expense details, such as expense descriptions, amounts, expense dates, associated receipts, notes, and photos, and other information entered during use of the Service.
Communications: If you contact us directly, we may receive additional Personal Data. For example, when you contact our Customer Support Team, we will receive your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your name and email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Service.
Payment Information: If you make a purchase through our Services, your payment-related information, such as credit card or other financial information, is collected by our third party payment processor on our behalf.
B. Personal Data We Receive from Third Parties
Personal Data From App Stores: You will access the Service by first downloading the mobile application from the Apple App Store or Google Play Store. We will receive Personal Data about you from the app store when you download the mobile application and sign up for the Service to include your email address.
Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Instagram, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your profile information and your photo, contact details, and your use of the third party account. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
C. Personal Data We Receive Automatically From Your Use of the Service
When you visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), which browsers people use to access the Service (e.g., Chrome, Firefox, Internet Explorer, etc.), broad geographical information, and how people navigate the Service. In particular, the following information is created and automatically logged in our systems:
● Log data: Information that your browser automatically sends whenever you visit the Service (“log data”). Log data includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, and how you interacted with the Service.
● Cookies: Please see the “Cookies and Similar Technologies” section below to learn more about how we use cookies.
● Location Information: When you use the Service, we may infer your general location information, for example, by using your IP address.
● Device Information: We receive information about the device and software you use to access the Service, including IP address, operating system version, browser type, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens. Information collected may depend on the type of device you use and its settings.
● Usage Information: To help us understand how you use the Service, and to help us improve it, we automatically collect information about your interactions with our Service, such as the pages or types of content that you view or engage with, the features you use, the actions you take, purchases you make, your comments, any content you post, and the date, time, frequency and duration of your activities.
Cookies and Similar Technologies: We and third party partners collect information using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, including Facebook, may use these technologies to collect information about your online activities over time and across different services. We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). We may use both session cookies and persistent cookies.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
● Internet Explorer: https://support.microsoft.com/en-us/windows/internet-explorer-help-23360e49-9cd3-4dda-ba52-705336cc0de2
● Mozilla Firefox: https://support.mozilla.org/en-US/products/firefox
● Google Chrome: https://support.google.com/chrome#topic=9796470
● Apple Safari: https://support.apple.com/safari
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Service and you may not be able to benefit from the full functionality of the Site and Service.
Analytics: We use analytics services, including Google Analytics and others, to collect and process certain analytics data that helps us analyze how users use the Service and enhance your experience when you use the Service. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting www.google.com/policies/privacy/partners/. about your interactions with our Service, like the pages or types of content that you view or engage with, the features you use, the actions you take, purchases you make, your comments, any content you post, and the date, time, frequency and duration of your activities.
Do Not Track Signals:
There is no accepted standard on how to respond to respond to “Do Not Track” (“DNT”) signals and we do not respond to such signals. Our Service operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
- HOW WE USE PERSONAL DATA
We may use Personal Data for the following purposes:
● To provide the Service, including our expense tracking functionality and data, related tools and reporting capabilities, and to customize and personalize your experience with the Onward app;
● To communicate with you, provide information you request, respond to your inquiries, comments, feedback or questions and otherwise provide customer support;
● To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
● To provide you with updates and other information relating to our Service, including marketing materials about services and products available on our Service, as discussed further below;
● To analyze how you interact with our Service;
● To maintain and improve the content and functionality of the Service;
● To develop new products and services;
● To send you and your co-parent text messages, emails, and push notifications;
● To find and prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks;
● To train our team members;
● To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties; and
● For other purposes for which we provide specific notice at the time the information is collected.
Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you or by opting out of or cancelling your subscription to the Service. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. We do not rent, sell, or share your Personal Data with nonaffiliated companies for their direct marketing purposes, unless we have your permission
- SHARING AND DISCLOSURE OF PERSONAL DATA
We may share your Personal Data with third parties as set forth below:
● Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, order fulfillment services, customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies and Similar Technologies” section above).
● Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Onward. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.
● Analytics Partners: We use analytics services, such as Google and Amplitude, to collect and process certain analytics data (for more information, including information on how to opt out, please see the “Analytics” section above).
● Advertising Partners: We work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
● Business Transfers: We may transfer your Personal Data to service providers, advisors, potential transaction partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction including a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, or sale, liquidation, or transfer of all or a portion of our assets, or the transition of service to another provider. The use of your Personal Data following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Data was collected.
● Legal Requirements: We may access, preserve, and disclose your information if we believe doing so is required by law or appropriate to (i) comply with a legal obligation, including to meet national security or law enforcement requirements; (ii) comply with law enforcement requests and legal process, such as a court order or subpoena; (iii) respond to your requests; (iv) protect and defend your, our, or others’ rights, property, or safety; (v) prevent fraud; or (vi) protect against legal liability.
● Consent. We may also disclose your Personal Data with your permission.
- DATA RETENTION
We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is longer.
- UPDATE YOUR INFORMATION
Please log in to your account or contact us if you need to change or correct your Personal Data.
- CHILDREN
Our Service is not directed to children who are under the age of 13. Onward does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided us with Personal Data, in violation of this Privacy Policy, you may alert us at privacy@onwardapp.com.
- LINKS TO OTHER WEBSITES
The Service may contain links to other websites, products, or services not operated or controlled by Onward, including social media services (“Third Party Sites”). Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. We encourage you to read their privacy policies before providing any information to them. By providing links to Third Party Sites, we do not imply that we endorse or have reviewed these sites.
- SECURITY
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, as no electronic transmission or storage of information can be entirely secure or error free, we can make no guarantees as to the security or privacy of your information. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Onward via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
- INTERNATIONAL USERS
The Service is hosted in the United States and intended for and marketed to users located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including Personal Data, on or to the Service, you consent to such transfer, storage, and processing.
- YOUR CHOICES
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features.
Update Your Information. You can contact us to ask us to update or correct your Personal Data. You may also delete your account by contacting us or directly from within the mobile application. Please note that we will need to verify that you have the authority to delete the account, and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
- CHANGES TO THE PRIVACY POLICY
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Data previously collected from you through the Service, we will notify you through the Service, by email, or other communication. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
- CALIFORNIA CONSUMER PRIVACY ACT
A. Categories of Personal Information We Collect
Along with the information in the Privacy Policy as a whole, the CCPA requires us to describe the information we collect in certain “categories.” The categories we collect may include:
● Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
● Commercial information (such as transaction data);
● Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);
● Geolocation data (at an IP-based or city/state/zip level);
● Inference data about you drawn from the data in this section (based on user profile information);
● Legally protected classifications (such as age and gender);
● Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the Services, such as additional profile information or user-generated content).
B. The Sources From Which the Categories of Personal Information Are Collected
We collect personal data directly from information you provide to us; indirectly from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements
C. Business Purposes for Our Collection of Personal Information
The following is a list of the business purposes for our collection of information
● Provide the Services you have requested, including invoicing and accounting;
● Respond to your requests for information and provide you with more effective and efficient customer service;
● Provide you with updates and information about the Services;
● Contact you by email, postal mail, or phone regarding our Services and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you;
● Customize the advertising and content you see via the Services;
● Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;
● Secure our websites and applications, and resolve technical issues being reported;
● Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
● Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
D. Sharing of Categories of Personal Information
We may share categories of personal information to accomplish the various business purposes above and as described throughout this Privacy Policy.
E. CCPA Rights Disclosure
If you are a California resident, the CCPA may allow you to make certain requests about your personal information. Specifically, the CCPA may allow you to request us to:
● Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;
● Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this Privacy Policy);
● Provide you with the specific pieces of personal information we collect about you; and
● Delete personal information we have about you.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.
To make a CCPA request, please contact us at privacy@onwardapp.com. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances.
The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.
If you would like further information regarding your legal rights under California law, please contact us at privacy@onwardapp.com.
F. California Do Not Sell Notice and Information Request
If you are a California resident, the CCPA provides you with the right to opt out of the "sale" of your "personal information." We may allow some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a "sale" under the CCPA. If you want to opt out of these activities, please contact us at privacy@onwardapp.com. Please note that some or all of the Services may not function if you choose to opt out of such activities.
If you are a California resident, California Civil Code Section 1798.83 allows you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for the third parties’ direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding twelve calendar months. If you are a California resident and would like to make such a request, please submit your request in writing to:
Onward Solutions, Inc.
2219 Main Street
Unit #156
Santa Monica CA 90405
- CONTACT US
If you have any questions, comments, or concerns about our Privacy Policy or information practices, please feel free to email us at privacy@onwardapp.com or write to us at:
Onward Solutions, Inc.
2219 Main St
Unit #156
Santa Monica, CA 90405
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