Privacy Policy
EFFECTIVE DATE: July 1, 2025
Introduction
Hamiltonian Inc. and Hamiltonian International LLC (“Credit Convey”, “VANSi”, “VAN$i”, or “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this privacy notice. This Privacy Notice (our “Privacy Notice”) describes the information we collect, how we collect information, and the reasons we collect information. This Privacy Notice also describes the choices you have regarding the information we collect, including how you can manage, update, or request to delete information.
This Privacy Notice applies to information we collect when you visit our websites, www.creditconvey.com, www.vansi.com, and www.hamiltonian.inc or any website of ours that links to this Privacy Notice (our “Websites”), install and use our mobile applications (our “App”), or use our products and services (our “Services”) (our Websites, App, and Services collectively referred to in this Privacy Notice as the “Platform”), and our practices for collecting, using, maintaining, and disclosing information through the Platform.
This Privacy Notice applies to information we collect:
on or through our Platform;
in email, text, and other electronic messages between you and our Platform through any medium;
when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy; and
any other information we may collect about you offline when you use our Platform.
It does not apply to information collected by:
us through any other means, including on any other website operated by us or any third-party (including our affiliates and subsidiaries) that does not link to this Privacy Notice;
us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Platform.
Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using the Platform, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.
Information We Collect About You and How We Collect It.
Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information.
Generally
We collect Personal Data from various sources, including:
directly from you when you provide it to us;
automatically as you navigate through or otherwise use the Platform;
information that we create about you as you use our Platform; and
from third parties, for example, our service providers and business partners.
Information You Provide to Us
When you access or use our Platform, we collect Personal Data directly from you, including:
Identifiers: Real name, postal address, email address, account name, and telephone number.
Financial Information: Bank account and transaction data (collected, with your consent, by third-party financial data providers and shared with us).
In addition, we may also collect other types of information that you submit or otherwise provide through your use of the Platform, such as information that you provide by filling in forms on our Platform or through your correspondence with us. This includes: (i) information provided at the time of registering to use our Platform, applying to use our Service, requesting further information, or reporting a problem or other issue with our Platform; (ii) records and copies of your correspondence (including email), if you contact us; and (iii) details of transactions.
When you apply to use our Platform, you will be asked to connect your bank account through one of our third-party financial data providers. With your consent, your bank account and transaction information will be collected and shared with us. We do not receive or store your bank login credentials. Your use of these third-party financial data providers is subject to their own privacy policies, which we encourage you to review before connecting your account.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Platform, including information about your equipment, browsing actions, and patterns. This includes:
details of your visits to, and use of, our Platform, including traffic data, logs, referring/exit pages, date and time of your visit to our Platform, error information, and other communication data, as well as the resources that you use or otherwise interact with on or through the Platform;
information about your computing device and internet connection, i.e., your IP address, operating system, device make and model, and browser type; and
information collected through cookies running on our Platform. Cookies are small data files placed on your computing device that allow us to collect certain information whenever you visit or interact with our Platform. Some of these cookies are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies). For example, we use Google Analytics, a web analytics service provided by Google, Inc., to collect certain information relating to your use of our Website. Google Analytics uses cookies to help us analyze how users use our Website. For more information regarding Google Analytics (including how Google uses data when you visit our Website), please visit Google's website and the pages that describe Google Analytics, such as https://policies.google.com/technologies/partner-sites.
The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service by enabling us to perform actions including, but not limited to: (i) estimate our audience size and usage patterns; (ii) store information about your preferences; (iii) provide you with targeted advertising, which is based on your activities on the Platform and other online activities; (iv) customize our Platform according to your individual interests; (v) speed up your searches; and (vi) recognize you when you return to our Platform.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have disabled non-essential cookies through the cookie consent manager on our Platform or adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select these settings you may be unable to access certain parts of our Platform. You can find more information about cookies at http://www.allaboutcookies.org.
BY CONTINUING TO ALLOW COOKIES (SEE CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION), YOU HEREBY CONSENT TO OUR RECORDING AND DISCLOSURE TO THIRD-PARTY COOKIE PROVIDERS OF YOUR USE OF THE PLATFORM OR OTHER COMMUNICATIONS YOU MAY HAVE WITH OUR PLATFORM.
Third-Party Use of Cookies
Some content or applications, including advertisements, on the Platform are served by third parties, including advertisers, content providers, and analytics providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
Information We Create About You
We may create information about you based on your use of the Platform. For example, we may generate information about your use of certain features, your engagement with our education, motivation, and financial tools, or your account history (such as membership status or service usage patterns). When we associate this information with other Personal Data about you, we treat it as Personal Data under this Privacy Notice.
Information We Collect from Third Parties
We may collect limited Personal Data about you from third-party sources, such as third-party financial data providers, public databases, joint marketing partners, and social media platforms (if you engage with us there). This information may include Personal Data. When combined with other Personal Data we hold about you, we treat this information as Personal Data under this Privacy Notice.
How We Use Your Information.
We use information that we collect about you or that you provide to us, including any Personal Data:
to provide, support, personalize, and develop our Services and Platform;
to fulfill or address the reason you provided the information, including to provide you with information, products, or services you request from us, such as access to our financial wellness tools, instant pay features, and Bridge-a-Gap ("BaG") services;
to create, maintain, customize, and secure your account with us, including sending you notices about your account or membership, such as expiration, transaction dates, and renewal notices;
to process your requests, payments, and transfers, and to prevent transactional fraud;
to provide you with customer service and support and to respond to your inquiries, including investigating and addressing concerns and monitoring and improving our responses;
to allow you to participate in the interactive features of the Platform;
to administer various promotions;
to send newsletters and other educational, financial, or service-related communications not primarily for promotional purposes;
to send marketing communications (e.g., promotional offers, product updates, or tailored analytical services) related to our own products and services or those of third parties, and to deliver targeted advertising based on your interests or behavior. You may opt out at any time (see “Choices About How We Use and Disclose Your Information”);
for auditing related to behavioral advertising, including counting ad impressions, verifying ad delivery and quality, and auditing compliance with advertising standards;
to help maintain the safety, security, and integrity of the Platform, our Services, databases, technology assets, and business operations;
for internal testing, research, analysis, and product development, including to improve the functionality and performance of the Platform and our financial wellness features;
to train and improve our automated systems, including predictive tools, machine learning, and artificial intelligence models used in connection with the Platform;
to verify or maintain the quality and reliability of our Services;
to carry out our legal and contractual obligations, enforce our rights arising from any contracts entered into between you and us, and respond to law enforcement requests;
to exercise or defend legal claims, and to respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about you is among the assets transferred;
for any other purpose with your consent; and
in any other way we may describe when you provide the information or as otherwise permitted by applicable law.
Disclosure of Your Personal Data.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:
to our subsidiaries and affiliates;
to business partners, service providers, and other third parties we use to support our business and provide functionality and operate the Platform. These entities provide services such as IT and infrastructure support services, analytics, financial and payment processing services. Our financial service providers and payment processors’ privacy policy may be found at https://www.carmelsolutions.com/privacy-policy/, https://plaid.com/legal/#end-user-privacy-policy, and https://www.orum.io/privacy-policy.
to third-party cookie and other tracking technology providers for the purpose of providing analytics and cross-context behavioral advertising services to us;
to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Hamiltonian Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Hamiltonian Inc. about our Platform’s users is among the assets transferred;
to fulfill the purpose for which you provide it;
for any other purpose disclosed by us when you provide the information; and
with your consent (if required by law) or as otherwise permitted by applicable law.
We may also disclose your Personal Data as necessary to:
comply with: (i) federal, state, or local laws, or to comply with a court order or subpoena to provide information; (ii) civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; and/or (iii) certain government agency requests for emergency access to your Personal Data if you are at risk or in danger of death or serious physical injury;
cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers) believe may violate federal, state, or local law;
exercise or defend legal claims and to enforce or apply our Terms of Use (add a hyperlink) and other agreements; and/or
protect the rights, property, or safety of our Platform, its customers, or others.
Choices About How We Use and Disclose Your Information.
We do not control the collection and use of your information collected by third parties described above in Disclosures of Your Information. These third parties may also aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data we have collected about you. We have created mechanisms to provide you with control over your Personal Data:
Targeted and Behavioral Advertising. Our Platform may use certain technologies, including cookies, to display advertising to you based on your activities on our Platform and other online activities. You may disable our use of any non-essential cookies (e.g., analytics cookies) through the cookie consent manager on your computing device. You can also adjust the settings in your browser’s settings to refuse all or some cookies. If you disable or refuse cookies, please note that certain parts of our Platform may be inaccessible or may not function properly.
As noted above, we do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website by visiting www.aboutads.info.
Direct Marketing/Promotional Offers. We may send promotional or marketing-related emails to you about our own or third-party offerings, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by clicking the “unsubscribe” link at the bottom of the email. If you opt-out of receiving these types of emails from us, please note that you may continue to receive transactional or account-related communications from us.
By providing your mobile number, you expressly consent to receive marketing text messages from or on behalf of our Platform at the number provided, including messages sent via an automated system. Consent to marketing messages via text is not required to use our Services. Message and data rates may apply. Text STOP at any time to opt out.
Accessing and Correcting Your Personal Data.
In addition to the choices made available to you with regard to the Personal Data that we have collected about you, you can also access, correct or update certain Personal Data that we hold about you by contacting us through the Contact Information below of errors or changes in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not accommodate a request to correct or update your Personal Data if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Do Not Track Signals and Global Privacy Control Signals.
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities or the Global Privacy Control signal (“GPC Signal”). At this time, we do not honor such signals, and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
Data Security.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we have implemented measures to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Platform. We NEVER ask for your bank account information via email. NEVER provide your bank account information over email or phone to anyone.
Children Under the Age of 18.
Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Platform. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Platform or on or through any of its features, register on the Platform or, use any of the interactive or public comment features of our Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us through the Contact Information below.
Changes to Our Privacy Notice.
We may change this Privacy Notice at any time. It is our policy to periodically review and modify this privacy notice and to post the most recent update on this page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you and for periodically visiting our Platform and this Privacy Notice to check for any changes.
Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes.
Contact Information.
If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data as described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below.
109 E 17th Street, STE 430
Cheyenne WY 82001
1 (831) 337-0656
support@creditconvey.zendesk.com