FelixFelix

Privacy Policy

1. Introduction

Felix Financial Services (“Felix,” “we,” “us,” or “our”) is a technology-enabled debt relief service that helps consumers understand their credit, prioritize accounts, and receive assisted negotiation with creditors. This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use the Felix platform, website, and related services (collectively, the “Services”).

By creating an account or using our Services, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with these practices, please do not use our Services.

2. Information We Collect

We collect the following categories of personal information:

2.1 Personal Identifiers

Name (first and last), email address, telephone number, date of birth, mailing address, and the last four digits of your Social Security Number (used for identity verification and credit inquiry purposes). We do not store your full Social Security Number in our systems.

2.2 Financial and Credit Information

Credit report data obtained through authorized soft credit inquiries, including credit scores, account balances, payment histories, creditor names, account types, and delinquency information. We obtain this data from consumer reporting agencies through authorized intermediaries, solely with your consent and for the purpose of providing our Services.

2.3 Payment Information

Subscription payments are processed by a PCI DSS-compliant third-party payment processor. We do not store your credit card numbers, debit card numbers, or bank account details on our servers. We retain transaction identifiers, subscription status, and billing history for account management purposes.

2.4 Communication Records

Records of communications sent and received on your behalf as part of the debt negotiation process, including emails, text messages, and physical correspondence. This includes the content, date, time, and delivery status of such communications.

2.5 Electronic Signatures and Documents

When you electronically sign documents through our platform (such as the Limited Power of Attorney), we collect and retain your typed legal name, drawn signature image, the IP address from which you signed, the date and time of signing, and the browser and device information used. Signed documents are securely stored and available to you upon request.

2.6 Device and Usage Information

IP address, browser type and version, operating system, referring URLs, pages visited within our platform, timestamps of access, and general usage patterns. This information is collected through server logs and analytics tools for the purpose of improving our Services and ensuring platform security.

2.7 Information from Third-Party Sources

We receive credit report data from consumer reporting agencies through authorized intermediary services, solely based on your prior consent. We may also receive information from the partner organization through which you enrolled, if applicable.

3. How We Use Your Information

We use your personal information for the following purposes:

  • Service Delivery: To provide debt relief services, including obtaining your credit report, analyzing your accounts, communicating with creditors on your behalf, negotiating settlements, and presenting offers for your review.
  • Identity Verification: To verify your identity and eligibility for our Services, including through soft credit inquiries.
  • Payment Processing: To process subscription payments and manage your billing account.
  • Communications: To send you account notifications, case updates, settlement offers, and service-related messages via email, SMS, or mail, in accordance with your communication preferences.
  • Automated Processing: To use technology, including artificial intelligence, to assist with negotiation strategy, creditor correspondence analysis, and communication drafting, as further described in Section 4.
  • Legal Compliance: To comply with applicable laws, regulations, legal processes, and government requests.
  • Security and Fraud Prevention: To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity.
  • Service Improvement: To analyze aggregated and de-identified usage data to improve the functionality, performance, and user experience of our Services.

4. Automated Processing and Artificial Intelligence

Felix uses automated tools, including artificial intelligence, to assist with certain aspects of our Services. These tools may be used to analyze creditor correspondence, identify settlement opportunities, draft negotiation letters, classify creditor responses, and recommend next steps in the negotiation process.

Important safeguards regarding our use of AI:

  • No automated system makes final decisions on your behalf. All settlement offers require your explicit approval before they are accepted.
  • You may request human review of any action taken or proposed by automated systems at any time by contacting our support team.
  • Data processed by our AI service providers is not used to train their models, is processed in the United States, and is subject to data processing agreements that protect your information.
  • All actions taken by automated systems are logged and auditable.
  • You may opt out of automated processing at any time; your cases will be handled through manual processes instead.

5. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information in the following circumstances:

  • Credit Reporting Agencies: We share necessary personal information with consumer reporting agencies and their authorized intermediaries to perform the soft credit inquiries you have authorized.
  • Your Creditors: As authorized by your Limited Power of Attorney, we share your name and account information with your creditors and their representatives for the purpose of negotiating on your behalf.
  • Payment Processors: We share billing information with our third-party payment processor to process subscription payments.
  • Communication Providers: We use third-party service providers to deliver emails, text messages, and physical mail on your behalf and for service notifications.
  • Electronic Signature Providers: We use a third-party electronic signature service to execute and store signed legal documents.
  • AI Service Providers: We share case-related data with our AI service providers for the automated processing described in Section 4, subject to data processing agreements that restrict the use of your data.
  • Analytics Providers: We share aggregated and de-identified usage data with analytics providers to improve our Services. This data cannot be used to identify you personally.
  • Partner Organizations: If you enrolled through a partner organization, we may share account status and case progress information with that partner to the extent described in your agreement with them.
  • Legal and Regulatory: We may disclose your information when required by law, subpoena, court order, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

6. Data Retention

We retain your personal information for as long as your account is active and as needed to provide our Services. Specific retention periods include:

  • Active Account Data: Retained throughout the duration of your active subscription and account.
  • Post-Cancellation: Case data, documents, and offer history remain accessible for 90 days following cancellation or termination of your subscription. After 90 days, inactive case data may be archived.
  • Consent Records: Records of your consents (credit pull, communications, electronic signatures, terms acceptance) are retained indefinitely as part of our compliance and audit obligations.
  • Credit Reports: Retained in accordance with Fair Credit Reporting Act (FCRA) requirements and our legitimate business needs.
  • Signed Legal Documents: Retained in accordance with applicable record-retention requirements and the ESIGN Act.
  • Audit Logs: System audit logs are retained indefinitely for security and compliance purposes.

Upon deletion of your account, we will delete or de-identify your personal information within a reasonable time, except where retention is required by law or necessary for our legitimate business interests (such as fraud prevention or compliance).

7. Data Security

We implement industry-standard administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, or destruction. These measures include:

  • Encryption of data in transit (TLS/SSL) and at rest.
  • Role-based access controls that restrict data access to authorized personnel.
  • Comprehensive audit logging of all access to sensitive personal information.
  • Row-level security in our database to ensure multi-tenant data isolation.
  • Regular security assessments and vulnerability monitoring.
  • All data is stored and processed within the United States.

While we take reasonable measures to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal information.

8. Your Privacy Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

  • Right to Know / Access: You may request a copy of the personal information we have collected about you.
  • Right to Correct: You may request that we correct inaccurate personal information.
  • Right to Delete: You may request that we delete your personal information, subject to certain exceptions required by law.
  • Right to Data Portability: You may request your personal information in a structured, commonly used, and machine-readable format.
  • Right to Opt Out: You may opt out of certain data processing activities, including automated decision-making and targeted advertising (though we do not engage in targeted advertising).
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

These rights may be available to you under state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), and other applicable state laws.

To exercise your rights: Contact us at support@meetfelix.app. We will verify your identity before processing your request and respond within 45 days (or as required by applicable law). If we need additional time, we will notify you of the extension and the reason.

9. Do Not Sell or Share

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law.

10. Cookies and Tracking Technologies

We use a limited set of cookies and similar technologies to operate our Services:

  • Essential Cookies: Required for authentication, session management, and platform security. These cookies cannot be disabled without losing access to the Services.
  • Preference Cookies: Remember your settings and partner-branded context across sessions.
  • Analytics Cookies: Collect aggregated, de-identified usage data to help us improve the Services. We do not use third-party advertising cookies.

You can manage your cookie preferences through your browser settings. For more information, please see our Cookie Policy.

11. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will promptly delete that information. If you believe a child has provided us with personal information, please contact us at support@meetfelix.app.

12. International Users

Our Services are designed for and directed to users in the United States. All personal information is stored and processed within the United States. By using our Services, you consent to the collection, transfer, storage, and processing of your information in the United States.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will post the updated policy with a new effective date and, where required by law, notify you via email or an in-app notification. Your continued use of the Services after the effective date of the revised policy constitutes your acceptance of the updated terms.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Felix Financial Services
Email: support@meetfelix.app