Effective Date: November 14th, 2016
Welcome to Credit Karma!
We're here to provide you with tools and services that are designed to help you make financial progress. Before you get started, we'd like to tell you more about what we do with information we collect about you.
In other words, as legalese-y as they are, please read these documents carefully.
What This Policy Covers
That said, you should know that we may provide third party content or links to third-party web sites or applications, or include features that allow you to connect your Credit Karma account with your accounts with third parties, such as financial institutions or social media platforms like Facebook. When you leave our Services or interact with a third-party feature, you should also read the applicable third party's privacy policies and terms of service to make sure you understand how they might collect and share information about you (everybody is different).
What Information We Collect
To put it simply, there are three main ways we collect information about you: when you give it to us, with automatic technologies and when we ask others for it. Allow us to explain.
Information You Provide to Us
We may ask you to provide certain information to us through various forms, features or other means throughout our Services. These means include, for example, our registration form for new members, data collection forms for personalized features, and feedback forms where you send us comments, questions or other feedback.
The types of information we may collect from you include your name, address, email address, Social Insurance number and phone number. We may also collect information about you or your household, like your gender, income, assets (such as home or vehicle), and what types of financial products you're interested in.
Information We Automatically Collect
In addition to information you provide to us, we automatically collect certain information about how you access and interact with our Services ("Usage Information"). This Usage Information is a key part of how we improve your Credit Karma experience and provide more personalized insights and recommendations. We and service providers may use various technologies to collect, use and store Usage Information in connection with our Services. These may include things like cookies, browser web storage (e.g., HTML5), web beacons and similar technologies. There are three types of Usage Information we may collect:
- Device Information This is information about how you access our Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device. We may also integrate with built-in device features (e.g., when you turn on fingerprint access for your Credit Karma account).
- Log Information There are certain pieces of information we automatically collect in system logs or similar files about how you interact with our Services, such as which features you visit or click on. This Log Information may also include things like your IP address, browser or device configuration, date and time of access and cookie information.
- Location Information We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or province). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent, though.
Information Third Parties Provide About You
Many of our features rely on information about you that we collect from third parties with your consent or where otherwise permitted or required by law. This information includes, for example, the free credit reports and credit scores we request on your behalf from TransUnion. We may also work with third party data partners to supplement the Usage Information and other information we collect directly from you. These data partners may provide additional information about your household and financial profile beyond what we have collected from you, such as income, demographic, asset and public record information. In addition, our business partners may provide us with information about special offers available based on your credit profile so that we can give you more personalized recommendations. We might also collect information from other users like you through things like a member referral program.
How We Use the Information We Collect
We use the information we collect from you (including automatically) and third parties to operate our Services, communicate with you, conduct research and development to improve or enhance our Services and our users' experience, and promote our Services. These are a few specific examples of how we use the information we collect for these purposes:
- Providing features like your free credit reports and scores. When you register for a member account, we use the personal information you provide in order to create and maintain your Member Profile and provide you free credit reports and scores from our credit bureau partner. Credit Karma offers much more than free credit reports and scores though, and the information we collect as you use our Services may also go into developing and bringing you various other features like free credit monitoring and personalized offer recommendations.
- Improving our recommendations and insights. The information we collect also helps us tailor our content and improve the way we match you to recommended offers or insights about your credit health. We're constantly working on ways to better identify and present the information that's most relevant to you.
- Communicating with you. We may use information we collect to provide you with member support or to send you things like service-related announcements, credit monitoring alerts, recommendations, offers from our business partners and other updates or promotions. Most of the time we'll communicate with you by email, but we may also send you push notifications or even snail mail. For information on how to adjust your communications preferences, check out our aptly named "Communications Preferences" section below.
- Legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including personal information) as reasonably necessary to:
- Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted bylaw;
- Enforce our Terms of Service, including investigating any potential violations;
- Protect the safety, integrity, rights or security of our members, our Services or equipment, or any third party; or
- Detect, prevent or otherwise address fraud, security or technical issues related to our Services or our business partners.
When We Share the Information We Collect
First, we want to be clear about how we do not share information about you (what we call the "No-Nos"):
- We do not share your credit reports or scores with third parties (except agents acting on our behalf; we explain that below).
- We do not sell or rent personal information to third parties for their advertising or marketing lists.
Now that we've covered the No-Nos, let us explain how we could share with third parties. We may share information about you, including personal information, with third parties in the following circumstances:
- When we collaborate with third parties to provide and improve our Services We may sometimes share information about you with our business partners or other third parties we collaborate with (including our affiliates) in connection with providing or improving our Services. This can occur, for example, when we're providing an integrated or co-branded feature with a business partner (e.g., our Credit Score Simulator) or doing a joint research project with another organization to help improve our Services. We may also share information like the feedback you submit to us if it relates to both our Services and a business partner's products. When we share information with third-party collaborators, our collaborators are obligated to follow the No-Nos above, but may also use the information in connection with their own activities to the extent allowed under their own privacy practices (e.g., respond to your feedback, conduct additional research, or improve a feature of theirs). We will not share any sensitive personal information in a collaboration with a third party without asking for your express consent first.
- Our business partners when you ask for their services. We may also give you opportunities to interact with third party business partners through our Services (for instance, when you submit a loan application that we pre-populate with your information). In these situations, we will either tell you we'll be sending your information before we do so or we will send you to the business partner's site or platform for you to provide the information directly to them. Remember that any information you provide to the third-party business partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
- When you publicly post the information As part of our Services, we may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information and portions of your Member Profile designated as public profile information, like your name or user name. Anything you share in a public forum is, obviously, public, so think carefully about what you decide to share. You should also read any applicable Community Rules for more information on what is appropriate to post. If you would like us to remove personal information included in Community Content, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, but we will try to respond to let you know why.
- As Part of a Corporate Change We may disclose and transfer information about you to a third party or an affiliate as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets. If such a business transfer results in a material change in the treatment of your personal information, you will be notified by e-mail (using the primary email address on your account) or by a prominent notice on our site.
- For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes. (You can read more about these in the "How We Use the Information We Collect" section above.)
- With Your Consent We may also share your personal information in other circumstances with your consent or where permitted or required by law.
How to Access, Update or Deactivate Your Account
Accessing and Updating Your Account Information
You are responsible for maintaining the accuracy of the information you provide to us, such as your Member Profile information. You can access and make changes to certain personal information at any time by logging in to your account through our website and updating your "Personal Information" page. If you would like to request access to or correction of your personal information, you may also submit a written request to our Privacy Officer using the contact information provided in the "More Information" section below. [Please note that all of the credit report information we display comes straight from TransUnion. If you notice inaccuracies or errors in your credit report, you may need to file a dispute with TransUnion to correct them.]
You can manage your communications preferences by visiting your account profile. For example, you can choose which types of monitoring alerts you want to receive. We'll also include "unsubscribe" instructions in any marketing emails. Technology moves fast, so the types of communications and communication preference options might change from time to time.
Canceling Your Membership and Deactivating Your Account
We hope this never happens, but if you decide you no longer want to use our Services, you can cancel and deactivate your account on our help page.
One more thing to note: Due to our record keeping and information retention requirements, we do not delete information about you upon deactivation. We will, however, disable your account and stop sending you further communications.
Furthermore, except to the extent necessary for legal or regulatory recordkeeping purposes, we anonymize the data in your Member Profile two years after you deactivate your account. It may take a little more time for our automated backup systems to fully process the anonymized account, though.
Our Interest-Based Advertisement Practices
Advertising Service Providers
Disclosure Regarding Google Analytics Advertising Features
In addition to services from other Advertising Service Providers, we use the following Google Analytics Advertising Features as part of our marketing analytics and advertising: Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time. Google provides users an opportunity to opt-out of the Google Analytics Features through Google's Ads Settings and their web browser opt-out plugin. For additional information on opting out of interest-based ads by Google, visit here.
Do Not Track Signals
At this time, we do not respond to automated signals regarding tracking mechanisms, including "do not track" instructions from your browser. Please note that blocking cookies may affect your browsing experience on many sites and may limit your ability to use certain features of our Services, including many of the personalized features we provide for our members.
Our Security Practices
Credit Karma maintains physical, electronic, administrative and procedural safeguards intended to protect the confidentiality of personal information that we collect about you. Read more about our Security Practices.
If you have any questions about security on our Services, you can send an email to us at email@example.com.
Want More Information?
Thanks for taking the time to read through all this. If you have questions regarding this policy or privacy practices at Credit Karma, you can email us at firstname.lastname@example.org or write to us at: Credit Karma, Inc. Attention: Privacy Officer, P.O. Box 520, San Francisco, CA 94104-0520 USA.