Privacy Policy
This Privacy Policy ("Policy") describes how Flip My Debt, LLC and its affiliates, successors, and assigns (collectively, "Flip My Debt," "we," "us," or "our") collect, use, disclose, retain, and otherwise process personal information about users ("you" or "your") who access or use the website located at flipmydebt.com and any related subdomains, mobile-optimized pages, microsites, landing pages, widgets, APIs, and interactive tools operated by us (collectively, the "Site" or the "Services"). By accessing or using the Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy. If you do not agree, please do not use the Services.
1. Scope and Applicability
This Policy applies only to personal information collected by Flip My Debt through the Services. It does not apply to information collected by any third party, including through any application, service, or content (including advertising) that may link to or be accessible from or on the Services. By submitting information through the Services, you consent to the collection, use, disclosure, processing, storage, and transfer of your personal information as described in this Policy, in accordance with the laws of the United States of America, which may differ from the laws of your country or state of residence.
2. Information We Collect
We collect the following categories of personal information, consistent with the definitions of the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA") and similar state privacy laws:
- Identifiers. Including first and last name, mailing address, email address, telephone number (including mobile number), state of residence, unique personal identifier, online identifier, internet protocol ("IP") address, account name, and similar identifiers.
- Customer records. Including any information voluntarily submitted through our questionnaires, intake forms, or lead-capture tools, such as estimated debt amount, debt type (credit card, medical, student, personal loan, tax, or other), monthly payment status, credit score range, and financial goals.
- Commercial information. Including records of products or services considered, solicited, or obtained through us or our partners.
- Internet or other electronic network activity. Including browsing history, search history, referring URLs, pages visited, time spent, click patterns, information regarding interactions with the Services, and information about your interactions with advertisements.
- Geolocation data. General location data derived from IP address (approximate city or state), not precise GPS coordinates.
- Inferences. Drawn from any of the categories above to create a profile reflecting your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes insofar as relevant to consumer debt-relief services.
- Professional or employment-related information. Only if you apply to become a partner through our partner intake form (e.g., company name, title, professional licensure, accreditation).
We do not knowingly collect "sensitive personal information" as defined under the CPRA (such as Social Security number, driver's license number, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, genetic or biometric data, or contents of mail, email, or text messages not directed to us). Please do not submit such information through the Services.
3. Sources of Information
We collect personal information from the following categories of sources: (a) directly from you when you voluntarily provide it through our forms, questionnaires, or communications; (b) automatically, through your device, browser, or use of the Services, including through cookies, web beacons, pixel tags, software development kits ("SDKs"), and similar technologies; (c) from our service providers, analytics partners, and advertising partners; (d) from publicly available sources; and (e) from third-party data providers consistent with applicable law.
4. How We Use Your Information
We use personal information for the following purposes, each of which constitutes a legitimate business purpose under applicable law:
- To operate, maintain, administer, and improve the Services;
- To respond to your inquiries, process your submissions, and match you with one or more independently owned and operated debt-relief partners who may be able to provide services that fit your stated needs;
- To contact you by telephone, SMS text message, email, or other means regarding your inquiry, including by prerecorded or artificial voice and by automatic telephone dialing system, where you have provided prior express written consent as set forth in our Terms of Service;
- To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity;
- To perform accounting, audit, compliance, and internal research functions;
- To comply with applicable law, legal process, regulatory requirements, or lawful requests from public authorities;
- To enforce our Terms of Service and any other agreement;
- To measure performance of advertising campaigns and to tailor content to users;
- For any other purpose disclosed to you at the time of collection or for which you have provided consent.
5. How We Disclose Your Information
We may disclose each of the categories of personal information identified in Section 2 to the following categories of recipients:
- Debt-relief partners. Independently owned and operated debt consolidation, debt settlement, bankruptcy attorney, credit counseling, lending, and tax resolution companies with whom we have entered a written partnership agreement. These partners are contractually required to use your information solely to evaluate, contact, and serve you in accordance with applicable law. Once disclosed, these partners are independent controllers of your personal information and their use of your information is subject to their own privacy policies.
- Service providers. Companies that provide services to us, including hosting, analytics, form processing, email delivery, telephony, customer support, and professional services (such as lawyers and accountants). These service providers are contractually restricted from using your information for their own purposes.
- Affiliates. Our parent, subsidiaries, and commonly owned affiliates for the purposes described in this Policy.
- Corporate transactions. In connection with a merger, acquisition, reorganization, bankruptcy, receivership, sale of some or all of our assets, or transition of service to another provider, your personal information may be transferred as a business asset.
- Legal compliance and protection. To comply with applicable law, regulation, legal process, or governmental request; to enforce our Terms of Service; to protect our rights, property, or safety, or the rights, property, or safety of our users or others; and to detect, prevent, or otherwise address fraud or security issues.
- With your consent. For any other purpose disclosed to you with your consent.
6. Sale, Sharing, and Targeted Advertising
Under the CCPA, a "sale" means the exchange of personal information for monetary or other valuable consideration. Under the CPRA, "sharing" means disclosure of personal information to a third party for cross-context behavioral advertising. In the preceding twelve (12) months, we have disclosed the following categories of personal information to our debt-relief partners in exchange for lead-purchase fees or revenue share arrangements, which may constitute a "sale" or "sharing" as defined above: identifiers; customer records; commercial information; internet or other electronic network activity; general geolocation data; and inferences. Our disclosures to partners are made solely for the purpose of matching you with a service provider you have requested to hear from, and are not made to brokers or unrelated third parties. You have the right to opt out of such disclosures at any time by following the process described in Section 9 or by emailing privacy@flipmydebt.com.
We do not knowingly sell or share personal information of consumers under 16 years of age.
7. Cookies, Pixels, and Tracking Technologies
The Services use cookies, local storage, web beacons, pixel tags, session replay tools, and similar technologies to operate the Services, remember your preferences, measure usage, deliver relevant advertising, and improve performance. You may control cookies through your browser settings; however, disabling cookies may impair functionality. The Services may be used in connection with third-party analytics and advertising platforms, each of which has its own privacy and cookie practices. We do not control third-party cookies. We do not currently respond to browser Do Not Track signals, because no uniform standard has been adopted; however, we honor Global Privacy Control ("GPC") signals as an opt-out of sale and sharing to the extent required by law.
8. Your California Privacy Rights (CCPA/CPRA)
Subject to certain exceptions, California residents have the following rights under the CCPA as amended by the CPRA:
- Right to know. The right to request that we disclose the categories and specific pieces of personal information we have collected about you in the preceding twelve months, the categories of sources, the business or commercial purpose, and the categories of third parties with whom we disclosed or sold the information.
- Right to delete. The right to request that we delete any personal information we have collected from you, subject to statutory exceptions.
- Right to correct. The right to request that we correct inaccurate personal information we maintain about you.
- Right to opt out of sale or sharing. The right to direct us not to sell or share your personal information.
- Right to limit use of sensitive personal information. To the extent we collect sensitive personal information, the right to direct us to limit its use.
- Right to non-discrimination. The right not to receive discriminatory treatment for exercising any of these rights.
To exercise any of these rights, email privacy@flipmydebt.com with the subject line "California Privacy Request" and a description of your request. We will verify your identity before responding, which may require you to confirm information you previously provided. You may designate an authorized agent to make a request on your behalf by submitting written authorization signed by you. We will respond within forty-five (45) days, subject to a one-time extension of up to forty-five (45) additional days as permitted by law.
9. Other State Privacy Rights
Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), Delaware (DPDPA), Iowa (ICDPA), and other states with comprehensive consumer privacy laws may have rights to access, correct, delete, or obtain a portable copy of their personal information, and to opt out of targeted advertising, sale of personal information, or profiling that produces legal or similarly significant effects. To exercise your rights, email privacy@flipmydebt.com. If we deny your request, you may appeal our decision by replying to our response with the word "APPEAL" in the subject line; we will respond to your appeal within sixty (60) days or as required by applicable law.
10. Notice to Nevada Residents
Under Nevada Revised Statutes Chapter 603A, Nevada residents may submit a verified request to opt out of the future sale of certain categories of personal information. If you wish to submit such a request, email privacy@flipmydebt.com.
11. Notice to EU/UK Residents (GDPR)
If you are in the European Economic Area, United Kingdom, or Switzerland, our lawful bases for processing your personal data include: (a) your consent; (b) performance of a contract with you or to take steps at your request prior to entering a contract; (c) compliance with a legal obligation; and (d) our legitimate interests (or those of our partners) in operating and improving the Services, where not overridden by your fundamental rights. You have rights of access, rectification, erasure, restriction of processing, objection to processing, data portability, and the right to withdraw consent at any time. You also have the right to lodge a complaint with a supervisory authority. To exercise these rights, email privacy@flipmydebt.com. The Services are directed at users in the United States, and we do not intentionally market to residents of the European Economic Area or United Kingdom.
12. Children's Privacy
The Services are not directed to children under thirteen (13) years of age, and we do not knowingly collect personal information from children under thirteen. If we learn we have collected personal information from a child under thirteen without verifiable parental consent, we will delete that information promptly. If you believe a child has provided us with personal information, please contact privacy@flipmydebt.com.
13. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, to match you with partners, to respond to your inquiries, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Retention periods vary based on the nature and sensitivity of the information and applicable legal requirements. Lead data is typically retained for no longer than seven (7) years from the date of collection, after which it is deleted or irreversibly de-identified.
14. Data Security
We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information against unauthorized access, use, alteration, disclosure, or loss. These safeguards include encryption in transit via Transport Layer Security ("TLS"), access controls, logging and monitoring, and vendor-diligence procedures. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you as required by applicable law.
15. International Data Transfers
Flip My Debt is headquartered in the United States. If you access or use the Services from outside the United States, your personal information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your country of residence. By using the Services, you consent to this transfer.
16. Third-Party Links and Services
The Services may contain links to third-party websites or services, including those of our debt-relief partners. Once you click a partner link or are transferred to a partner, you are subject to that third party's privacy policy and terms, not this Policy. We are not responsible for the content, privacy practices, or security of any third party.
17. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will post the updated Policy on this page and revise the "Last Updated" date at the top. We encourage you to review this Policy periodically. Your continued use of the Services after we post any update constitutes your acceptance of the updated Policy.
18. How to Contact Us
For questions about this Policy or to exercise your privacy rights, please contact us at:
Flip My Debt, LLC
Attn: Privacy Officer
Email: privacy@flipmydebt.com
Note: This Policy is provided as a template. Before launching in production, have a qualified attorney review it for accuracy, completeness, and compliance with all applicable laws in the jurisdictions where you operate.