Introduction and overview
PRONDL leverages technology responsibly to power prosperity around the world, and we believe that everyone has a right to privacy. At PRONDL, we view privacy as a key part of the value that we deliver to our customers. PRONDL’s Data Stewardship Principles were developed to describe PRONDL’s values regarding the data our customers entrust to us.
Scope of this Privacy Statement and our role
As a financial services and technology company, we’re providing this Global Privacy Statement (which we’ll refer to as “Privacy Statement”) to explain how we collect, use, and share information when you interact with us and our offerings, services and experiences. This Privacy Statement is global in nature, meaning that it is applicable to all websites and offerings in the PRONDL group companies, and it describes our privacy practices when we process:
a) Personal information for the purposes of preparing a tax return or in connection with the preparation of a tax return (collectively, “Tax Preparation Information”) as part of providing TurboTax tax preparation services;
b) Personal information for the purposes of providing the benefits of the PRONDL platform, which is collectively, all of PRONDL’s services, sites, experiences and software (including through our mobile applications and desktop applications) by Inc. and its affiliates and subsidiaries other than Tax Preparation Information (the “PRONDL Platform”); and/or
c) Personal information as necessary to manage, run and improve our business.
PRONDL Inc. determines the purposes and means of the processing of personal information (“Information Controller”). PRONDL Inc. may share your personal data with other PRONDL group companies to process as joint controllers for the purposes set out in this Privacy Statement. If you have any questions about the processing of your personal data, please contact us in the section “How to Contact Us” below.
This Privacy Statement does not apply where PRONDL processes personal information as a service provider on behalf of a customer or entity who acts as the Information Controller, for example, the customers of our professional tax software products. When we act as a service provider, the privacy statement of the relevant Information Controller and our agreements with such business or entity will govern our processing of personal information.
In certain circumstances, there may be more than one Information Controller processing your information. For example, your employer or a financial partner may also act as an Information Controller. In these situations, we act as an independent Information Controller over our processing activities – meaning that we make determinations over how your personal information will be processed independently from the other Information Controller. The other Information Controller may have their own obligations under applicable information privacy law, and you may need to speak with the other Information Controller directly for questions on how they process your personal information.
The PRONDL Platform
The PRONDL Platform and your information
When we say “platform” we mean that when you choose to share data with us, or bring over information from third parties (like a bank or loan provider), we use that data together, not just within the individual offering(s) you’re using. This means your bookkeeping details from PRONDL , budgets and recommendations all live together.
The personal information we use in this centralized way is all the information that PRONDL knows about you. It includes your credentials; your name and contact details; payment information; information about your activities, your interests and preferences; insights about your finances or your business; the content you place in our Platform; and information we have collected about you from third-party sources.
Organizational account information
Some experiences and services within the PRONDL Platform allow you to interact with an organization (such as your employer). If you are granted access to an organization or household account (for example, a business's account in PRONDL ), the owner of the organization or a designated administrator may control and administer details of your account, for example, by deciding your access rights; making decisions about your personal information (such as details about your payroll); or requiring you to take certain actions (for example, use location tracking to clock in for a shift). If your access rights are amended by the owner or designated administrator, then you may lose access to the information that is in the control of the organization.
Your use of the PRONDL Platform as part of an organization’s account may be subject to the organization’s policies, which may be different from this Statement. We are not responsible for the privacy or security practices of other organizations, and you should consider both the organization's policies and whether you are comfortable enabling the organization with access to your information prior to connecting to their services.
Information we collect
Information we receive from you
The personal information that we receive about you depends on the context of your interactions with PRONDL, how you configure your account and the choices that you make, including your privacy settings. Personal information that you provide may also depend upon what services or experiences you use, your location and applicable law.
Creating an account. We collect information when you create an account, interact with the PRONDL Platform or activate a subscription. Personal information may include your contact information (such as your name, address, phone number and email), profile photo, billing information (your payment information), usernames and credentials.
Customer support, product research, training and feedback. We may collect personal information when you reach out to us for support, give us feedback, participate in optional surveys, product research or training and you choose to share.
Social and community content. We receive content you post on our social media pages and our community pages.
Device information. We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
Content. We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers or vendors or employees, income and wage information, and/or investment information.
Third-party service content. We receive information about you when you sign into a third-party service with your account or when you connect your account to a third-party service. For example, you may choose to connect your account with your bank accounts. To sync your financial account information, we must access your financial account information.
Usage information. We may collect usage information such as the pages you viewed, the features you use, your browser type and details about any links with which you interact.
Location information. Certain features in the PRONDL Platform may collect your precise location information, device motion information, or both, if you grant permission to do so in your device settings. For example, if you use our time-tracking service.
Expert advice. The PRONDL Platform provides many opportunities for you to connect with live experts, including, for example, accountants or tax preparers. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts and the guidance provided to you.
Information provided by others
Our platform is designed to help you connect with other people and organizations. As a result of those connections, others may be able to input information about you. For example, your employer may input information about your salary and work activity in order to process their payroll. You may also be able to input or process information about others, for example, if you are an account administrator. If you input information about others into our platform, you must only do so if you have first received the appropriate rights and permissions to do so, including by getting advanced written consent, if required by applicable law.
Other information sources
We may also get information about you from others where permitted by applicable law. We protect and process information obtained from those parties as described in this Privacy Statement, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the PRONDL Platform. For example, we receive information from:
Your service providers. If you choose to sync a non-PRONDL account/service with your account, we will receive information from that account/service according to your settings with that account/service. For example, if you connect a point of sale application to your account, we may receive details of your business’s sales records.
Supplemental information and identity verification providers. Service providers who help us verify your identity, the specifics of your business and/or supplement the information you have provided and ensure the accuracy of your information. For example, we use third-party service providers to validate your mailing address, phone number or provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider or email provider.
Customer Support providers. Service providers who provide us with information about you or your interaction with the PRONDL Platform for troubleshooting purposes. For example, we may obtain support information or technical issues you have raised with these third parties.
Credit bureaus and other third parties. Many of our features rely on information about you that we receive from third parties. For example, in some countries we may offer free credit reports and credit scores we request on your behalf from credit bureau partners, like TransUnion, Experian and Equifax. Our partners may also provide information such as employment or income data, vehicle or driver information, or information about special offers available based on your credit profile so that we can give you more personalized recommendations.
Other users. As described above, we may get information about you from other users, such as your accountant, bookkeeper, tax preparer, your spouse, your head of household or your employer. We may also collect such information through features like member referral programs.
Risk management, cybersecurity & anti-fraud providers. We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud, illegal activity and to help protect your personal information.
Content providers. We may receive information from software providers that make user-generated content from their service available to others, such as local business reviews or public social media posts.
Communication providers & social networks. If you give us permission, we may collect information from email providers, communication providers and social networks.
Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
Publicly-available sources. We collect information from publicly available sources, such as open government databases.
Government agencies. We receive information from government agencies, including from various tax agencies.
Required information. Some services and experiences in the PRONDL Platform require you to provide information for it to function. If you do not wish to provide the required information, you may not be able to use certain features.
How we use personal information
We collect and process personal information from you only where:
We have your consent to do so;
We need the personal information to perform a contract with you or provide a service to you;
Provide you with the benefits of the PRONDL Platform and operate our business;
The processing is in our legitimate business interests in those jurisdictions where legitimate business interest is a legitimate basis for processing; or
We need to comply with legal requirements, including applicable laws and regulations.
Personal information is used to operate our business for the following purposes that are required to originate and maintain our relationship with you, including but not limited to:
Provide you with the PRONDL Platform and create your account
Improve our products and services
Run and manage our business, including resolving billing and financial disputes
Evaluate your eligibility for financial offers, products and services
Provide features to you, such as your free credit reports and scores
Connect you with experts and other users
Communicate with you, such as sending you electronic notifications concerning your financial privacy
Advertise and market our services and experiences
Personalize your experience and tailor recommendations and offers presented to you, including through the development of insights about you and your needs
Provide you with support and resolve disputes
Conduct research, including by partnering with academic institutions
Comply with our legal and regulatory requirements
Authenticate your identity, including through the use of Biometric Data
Protect the rights, property, safety or security of the PRONDL Platform, our customers, employees or others and prevent fraudulent or illegal activity
To exercise our rights in the course of judicial, administrative or arbitration proceedings
To enforce, remedy or apply our Terms of Service or other agreements and/or
For other purposes that are compatible with the disclosed purposes if and where this is permitted by applicable law.
How we share your information
We may share your information in the following circumstances:
With your consent , except for as outlined below, we only share your information with third parties when you have directed us to do so.
When you connect with an PRONDL Platform partner. You may be provided with offers, products, and services from third-party companies who integrate with our PRONDL Platform (“Platform Partner”). If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct PRONDL to share your information, including personal information, to the Platform Partner providing the service or offering. For example, when we send your personal information to partners in order to generate offers for you to review, when we send your application information directly to our partners, or when we send you to the partner’s site for you to provide the information directly to them.
In some cases, if you click through to go to a Platform Partner’s site, you will automatically be sending your personal information to that Platform Partner. When this happens, you will still have to submit your application on the Platform Partner’s site. Remember that any information you provide to a Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
When you connect to your social media account. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider's privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.
For research. With appropriate controls, we may share information with third-parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that would not allow any individual to be identified.
For joint features, sales, promotions and events. We may share your information with third-parties companies who are jointly providing features, sales initiatives, promotions or events with us.
With financial services providers. We may share personal Information with collection agencies, credit bureaus and loan service providers, and payment card association members. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.
When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information, such as your name or user name. Anything you share in a public forum is public, and you should think carefully before you decide to share.
With service providers or agents. We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Statement. Service providers or agents may include companies that assist us with our advertising, marketing and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business.
For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.
No sale of personal information to third parties. We do not and will not sell personal information to third parties. We do share personal information with third parties for the business purposes described in this Statement.
With our affiliates and subsidiaries and your right to limit information sharing. We may share your information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes. Certain laws may provide you with the right to limit our information sharing activities in certain circumstances. Please review these rights in the “Country and Region-Specific Terms” section below.
Cookies and other tracking technologies. You can find information on changing your browser settings to opt-out of cookies in your browser settings. In certain countries, you may also be able to make changes to your cookies settings by using our cookie preferences tool. If you disable some or all of the cookies the service, or parts of the service may not work.
What are Cookies
A ‘Cookie’ is a small file which is created by a website and stored on your device. Often Cookies contain a string of numbers and letters that uniquely identifies your device, but can contain other information. Cookies serve many different purposes, including to help remember your preferences or allow our Services to function.
There are different types of Cookies:
Cookies are “persistent”, “permanent” or “session”:
Persistent and permanent Cookies remain on your device even after you have gone offline. These Cookies will remain on your device until you manually delete them or until your browser deletes them based on the duration specified in the Cookie file itself.
Session Cookies are deleted as soon as you close your web browser.
Cookies can also be “first-party” or “third-party”:
First-party Cookies are Cookies that are placed by an PRONDL group company or a third party for us.
Third-party Cookies are placed by our partners, vendors and other third parties. We do not control the collection or further use of data by third parties using third-party Cookies.
Web beacons (also known as pixel tags or clear GIFs) are small graphic images that are used in connection with the provision of our Services and which typically work in conjunction with Cookies to track the use of an online service by its users. For example, when we send you emails, web beacons allow us to track if you opened the emails and clicked links to measure campaign performance and improve features.
Similar technologies are technologies which enable the entity using it to track your user behavior. This can be done by HTML5 Local Storage, pixels, tags, Flash Cookies (also known as “local shared objects” or “LSOs”), and other web application software methods, all of which store information in your browser or device. We may employ Flash Cookies in certain situations where we use Flash to provide some content such as video clips or animation.
We classify Cookies according to whether they are “Essential”, “Functional”, “Improved Performance”, or “Advertising”, depending on the function that the Cookies serve in connection with our Services.
Essential Cookies are necessary to allow the technical operation of our Services. We use these Cookies to:
Run your session securely while you’re logged in,
Help detect and prevent fraud, and
Provide you with our Services, (e.g., they enable you to move around on a website and to use its features).
Functional Cookies are Cookies that:
Evidence your use of our Services to meet our compliance obligations and contractual commitments to partners,
Monitor and improve the performance of our Services,
Remember your choices (e.g. language, region, login information, and so on), and
Offer enhanced functionality when using our Services (e.g. 'stay logged in function').
Improved Performance Cookies are Cookies that:
Collect data to track the use of our Services,
Assess the effectiveness of campaigns, and
Understand how people found our Services.
Advertising Cookies are Cookies that enable us and our ad network partners, such as social media companies, to display advertising personalized to you and to prevent the same ads from being shown to you too many times.
Please note that even if you opt-out of Cookies or interest-based advertising, you will still receive advertisements, they just won't be tailored to your interests. Also, if you opt-out or later delete your Cookies, use a different browser, or use a new or different device, you may need to renew your Cookie preferences. It could also affect the availability and functionality of our Services.
Managing Cookies on our Services
Visitors from the EU can decide whether to accept Cookies when using our Services. However, we will still need to add some Cookies to allow our Services to operate. If you are an PRONDL customer, you can manage the Cookies in our Services at any time by clicking on the link “Manage Cookies” in the footer of our EU websites. You can also delete Cookies from your browser or device at any time.
Many devices and internet browsers are set to automatically accept Cookies. Information on changing your browser settings to opt-out of Cookies can be found in your browser settings. If you use different devices to access our Services, you will need to ensure that each browser of each device is set to your Cookie preferences.
Most mobile operating systems provide you an option in the device settings to limit ad tracking associated with the device ID they may share with us. Please reference your mobile operating system’s help center to learn more.
To find out more about Cookies, including how to see what Cookies have been set and how to manage and delete them, visit en.wikipedia.org/wiki/HTTP_cookie or www.allaboutcookies.org. Please note that PRONDL has no affiliation with, and is not responsible for, these third party websites.
Please note that not all browsers provide the ability to remove Flash Cookies. You can restrict or block Flash Cookies through the Adobe website and links for doing so are included below. As with any Cookie, if you do restrict Flash Cookies, there may be some features of our Services that you won't be able to use.
Resources for Controlling Third-Party Cookies:
The following websites provide choices to opt-out of tracking through certain third-party advertising and analytics Cookies:
For Users in the US: https://preferences-mgr.truste.com/
For Users in the EU: https://www.youronlinechoices.eu/
Visit the Digital Advertising Alliance's or Network Advertising Initiative's opt-out pages.
For users in the UK or France, please visit https://www.youronlinechoices.eu/
For users in Canada, please visit https://youradchoices.ca/
Click here to opt-out of targeted ads on Facebook.
Click here to opt-out of Google Analytics for display advertising or to customize Google Display Network ads.
Click here to opt-out of Adobe's Device Co-op membership which shares anonymous device data via web beacons and Cookies
Flurry Analytics: https://developer.yahoo.com/flurry/end-user-opt-out.html
Google Analytics: https://tools.google.com/dlpage/gaoptout (requires you to install a browser add-on)
Omniture (Adobe): http://www.d1.sc.omtrdc.net/optout.html
Visible Measures: https://www.visiblemeasures.com/viewer-settings-opt-out/
To manage Flash Cookies, please click here: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
For mobile apps, please refer to your mobile device’s settings, or download the AppChoices app. You may opt-out of Flurry Analytics tracking on some mobile apps or recommendations from Flurry.