Privacy Policy

Accelerated Strategies, LLC DBA: Solvit ("Solvit," "Company," "us," "we," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at solvitmoney.com, use our mobile applications, or engage with our services (collectively, the "Services"). Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICES.

Table of Contents

1. Who We Are
2. Information We Collect
3. How We Use Your Information
4. Administrative Account Access for Customer Support
5. Legal Bases for Processing (EEA/UK)
6. Disclosure of Your Information
7. Cookies and Tracking Technologies
8. Third-Party Services and Links
9. Data Retention
10. Data Security
11. International Data Transfers
12. Your Privacy Rights
13. California Privacy Rights (CCPA/CPRA)
14. Virginia Consumer Data Protection Act (VCDPA)
15. Colorado Privacy Act (CPA)
16. Other State Privacy Laws
17. Your Rights Under GDPR
18. Children's Privacy
19. Do Not Track Signals
20. Changes to This Privacy Policy
21. Contact Us

1. Who We Are

Accelerated Strategies, LLC DBA: Solvit is a financial technology company that provides personal finance management tools, including budgeting, debt tracking, and accelerated debt payoff strategies. Our registered address is:

For GDPR purposes, Accelerated Strategies, LLC DBA: Solvit is the data controller responsible for your personal data. For CCPA purposes, we are a "Business" as defined under California law.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when you:

• Create an Account: Name, email address, password, phone number
• Use Our Services: Financial information including income, expenses, debt balances, account numbers (encrypted), bank account information through secure third-party integrations
• Make Payments: Payment card information, billing address (processed by PCI-compliant third-party processors)
• Contact Us: Name, email, phone number, and any information you include in your message
• Subscribe to Communications: Email address, communication preferences
• Participate in Surveys or Promotions: Responses, demographic information

2.2 Information Collected Automatically

When you access our Services, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers, browser type and version
• Log Data: IP address, access times, pages viewed, referring URL, actions taken on our Services
• Location Data: General location based on IP address; precise location only with your explicit consent
• Usage Data: Features used, time spent on pages, navigation patterns, search queries
• Cookies and Similar Technologies: See Section 6 for details

2.3 Information from Third Parties

We may receive information from:

• Financial Data Aggregators: Account balances, transaction history, and other financial data you authorize us to access through secure API connections (e.g., Plaid)
• Identity Verification Services: Information to verify your identity and prevent fraud
• Analytics Providers: Aggregated usage statistics and behavioral data
• Marketing Partners: Demographic and interest-based information

2.4 Sensitive Personal Information

We may collect sensitive personal information as defined under applicable privacy laws, including financial account information. We use this information only for the purposes disclosed in this Privacy Policy and as permitted by law. We do not use or disclose sensitive personal information for purposes other than those specified in applicable regulations.

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Delivery

• Provide, maintain, and improve our Services
• Process transactions and manage your account
• Sync and analyze your financial data
• Use Artificial Intelligence (AI) to analyze your financial data
• Generate personalized debt payoff strategies and recommendations
• Send transactional communications (confirmations, alerts, updates)

3.2 Business Operations

• Analyze usage patterns to improve user experience
• Develop new features and services
• Conduct research and analytics
• Ensure security and prevent fraud
• Comply with legal obligations

3.3 Marketing and Communications

• Send promotional emails and newsletters (with your consent where required)
• Personalize content and advertisements
• Conduct surveys and collect feedback

3.4 Legal and Safety

• Protect our rights, privacy, safety, or property
• Enforce our Terms of Service
• Comply with applicable laws and regulations
• Respond to lawful requests from public authorities

4. Administrative Account Access for Customer Support

4.1 Overview and Legal Basis

To provide effective customer support and troubleshooting services, authorized internal team members ("Admin Users") may access your account in "impersonation mode." This access is based on the following legal grounds:

• Legitimate Interest (GDPR): Providing customer support and resolving technical issues
• Contractual Necessity: Fulfilling our service delivery obligations to you
• Business Purpose (CCPA/CPRA): Customer service operations and account maintenance

4.2 Permitted Actions - What Admin Users CAN Do

Admin Users may perform the following actions within your Solvit account for troubleshooting, setup support, and issue resolution purposes:

Debt Payoff Scenario Planning & Illustrations:

• Create, edit, and delete debt payoff scenarios
• Analyze payoff scenarios and results
• Adjust scenario parameters for troubleshooting purposes

Budget Categories & Amounts:

• Modify budget category names and allocations
• Create or remove budget categories
• Adjust budget amounts for setup support

Budget Transactions:

• Correct, edit, or remove transaction errors
• Re-categorize transactions
• Provide "done for you" budget setup support

Debt Account Attributes:

• Edit interest rates, terms, and payment dates
• Correct balance information
• Update account names and details

4.3 Prohibited Actions - What Admin Users CANNOT Do

Admin Users are strictly prohibited from the following activities:

No Access to External Financial Accounts:

• Cannot access your online banking login credentials
• Cannot log into your bank, credit card, or financial institution accounts
• Cannot view, access, or store your bank account passwords

No Financial Transactions:

• Cannot transfer, move, or handle any funds on your behalf
• Cannot initiate payments or withdrawals
• Cannot access or modify external account balances

No Access to Sensitive Banking Information:

• Cannot access routing numbers, account numbers, or bank IDs
• Cannot view authentication credentials for financial institutions
• Cannot export or copy sensitive financial identifiers

4.4 Regulatory Compliance & Security Controls

Access Controls (GLBA Safeguards Rule Compliance):

• Admin access is granted based on the Principle of Least Privilege - only staff required to resolve specific issues have access
• Access is role-based and regularly reviewed

Audit Logging & Monitoring (FTC Guidelines):

• Every admin access session is automatically logged
• Logs include: timestamp, admin user identity, actions taken, and duration
• Audit logs are retained for compliance purposes
• Logs are reviewed periodically to detect unauthorized access

Session Security:

• Admin impersonation uses secure, session-limited tokens
• Sessions automatically expire after inactivity
• Admins do not see or store user passwords during impersonation

Employee Training & Accountability:

• All Admin Users undergo mandatory security and privacy training
• Training covers handling of sensitive financial data
• Employees sign confidentiality agreements

4.5 User Control & Explicit Consent (GDPR Art.7, CPRA §1798.135)

How to Enable: You may enable admin account access at any time by navigating to User Settings → Security → Admin Access and toggling on the "Allow Admin Support Access" option.

Consequences of Opting Out:

• Troubleshooting support may be limited
• Some support requests may require additional steps or longer resolution times
• You can re-enable access at any time

4.6 Your Rights Under Applicable Laws

California Residents (CCPA/CPRA): You have the right to know which categories of employees access your data. You may request a record of admin access to your account.

EEA/UK Residents (GDPR): Admin access is processed under legitimate interest for service delivery. You may object to this processing by opting out.

All Users: You may request a summary of any admin access to your account by contacting privacy@solvitmoney.com.

4.7 Indemnification and Hold Harmless for Administrative Actions

Indemnification: You agree to indemnify, defend, and hold harmless Accelerated Strategies, LLC DBA: Solvit, its parent companies, affiliates, directors, officers, employees, and agents from any claims, actions, losses, liabilities, damages, expenses, and costs (including attorneys' fees) arising from:

• Errors, omissions, or inaccuracies in data modifications made during admin support sessions
• Unintended changes to budget categories, transactions, debt scenarios, or account attributes
• Any decisions you make based on data modified during admin access
• Any discrepancies between Solvit platform data and actual financial account data

Limitation of Liability: The Company shall not be liable for any direct, indirect, incidental, consequential, or punitive damages arising from admin modifications. Maximum liability is capped at fees paid by you in the preceding 12 months.

No Warranty on Admin Actions: All administrative modifications are provided "as-is" without warranty of accuracy or completeness. You are responsible for reviewing and verifying any changes made during admin support sessions.

User's Duty to Review: You agree to review your account data after any admin support session. You have seven (7) days to report any errors or discrepancies following admin access. Failure to report errors within this period constitutes acceptance of modifications.

5. Legal Bases for Processing (EEA/UK)

If you are in the European Economic Area or United Kingdom, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide our Services to you
• Legitimate Interests: Processing for fraud prevention, security, analytics, and service improvement, where not overridden by your rights
• Legal Obligation: Processing required by applicable laws
• Consent: Processing based on your explicit consent, which you may withdraw at any time

6. Disclosure of Your Information

We do not sell your personal information. We may share your information in the following circumstances:

6.1 Service Providers

We share information with third-party vendors who perform services on our behalf, including:

• The Kwak Brothers organization which includes:
  • Accelerated Strategies, LLC
  • Kwak Brothers Coaching LLC DBA: Accelerated Real Estate Academy
  • Novo Elite, Inc. DBA: The Kwak Brothers
  • Current and Future Affiliate Partners from all herementioned organizations
• Marketing Partners that provide complementary services
• Cloud hosting and data storage providers
• Payment processors (PCI-DSS compliant)
• Financial data aggregation services
• Customer support platforms
• Analytics and marketing tools
• Email service providers

All service providers are contractually obligated to protect your information and use it only for the purposes we specify.

6.2 Legal Requirements

We may disclose your information:

• To comply with laws, regulations, or legal processes
• To respond to lawful requests from government authorities
• To protect our rights, privacy, safety, or property
• To enforce our agreements and policies
• In connection with investigations of suspected fraud or illegal activity

6.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information.

6.4 With Your Consent

We may share your information for other purposes with your explicit consent.

7. Cookies and Tracking Technologies

We use cookies, pixels, beacons, and similar technologies to collect information and improve our Services.

7.1 Types of Cookies We Use

• Essential Cookies: Required for basic functionality (authentication, security, preferences)
• Analytics Cookies: Help us understand how visitors interact with our Services (e.g., Google Analytics)
• Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness
• Functional Cookies: Remember your preferences and personalize your experience

7.2 Your Cookie Choices

You can manage cookies through:

• Your browser settings (blocking or deleting cookies)
• Our cookie consent banner (where applicable)
• Opt-out tools: NAI Opt-Out, DAA Opt-Out
• Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout

Note: Disabling cookies may affect the functionality of our Services.

8. Third-Party Services and Links

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

We use third-party services including but not limited to:

• Plaid (financial data aggregation)
• Stripe (payment processing)
• Google Analytics (website analytics)
• Postmark (email delivery)

9. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal obligations (e.g., tax, accounting requirements)
• Resolve disputes and enforce our agreements
• Fulfill the purposes described in this Privacy Policy

When you delete your account, we will delete or anonymize your personal information within 90 days, except where retention is required by law or for legitimate business purposes.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256)
• Secure authentication mechanisms including multi-factor authentication
• Regular security assessments and penetration testing
• Access controls limiting employee access to personal data
• Employee training on data protection and security
• Incident response procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Data Breach Notification

In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have different data protection laws.

When we transfer data internationally, we use appropriate safeguards including:

• Standard Contractual Clauses approved by the European Commission
• Data processing agreements with appropriate security provisions
• Compliance with applicable cross-border data transfer mechanisms

12. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Portability: Request your data in a portable format
• Opt-Out: Opt out of marketing communications
• Restriction: Request restriction of processing
• Objection: Object to certain processing activities

To exercise these rights, contact us at privacy@solvitmoney.com. We will respond within the timeframe required by applicable law.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Your Rights

• Right to Know: Request disclosure of personal information collected, used, disclosed, and sold
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: Opt out of the sale or sharing of personal information
• Right to Limit Use: Limit the use and disclosure of sensitive personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

Categories of Information Collected

In the preceding 12 months, we have collected:

• Identifiers (name, email, IP address)
• Personal information under Cal. Civ. Code § 1798.80(e)
• Commercial information (transaction history, purchasing history)
• Internet activity (browsing history, search history, interaction with our Services)
• Geolocation data
• Inferences drawn from the above

Do Not Sell or Share My Personal Information

We do not sell your personal information for monetary consideration. We do not "share" your personal information for cross-context behavioral advertising as defined under the CPRA.

To submit a request, email us at legal@acceleratedstrategies.com with the subject line "California Privacy Request."

Authorized Agents

You may designate an authorized agent to make requests on your behalf. We will require verification of your identity and the agent's authority to act on your behalf.

14. Virginia Consumer Data Protection Act (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act:

• Right to access and obtain a copy of your personal data
• Right to correct inaccuracies
• Right to delete your personal data
• Right to obtain your data in a portable format
• Right to opt out of targeted advertising, sale of personal data, or profiling
• Right to appeal our decisions regarding your requests

To exercise these rights or submit an appeal, contact privacy@solvitmoney.com.

15. Colorado Privacy Act (CPA)

Colorado residents have similar rights under the Colorado Privacy Act, including rights to access, correct, delete, and port their data, as well as opt-out rights. To exercise these rights, contact privacy@solvitmoney.com.

16. Other State Privacy Laws

We comply with applicable state privacy laws, including but not limited to:

• Connecticut Data Privacy Act (CTDPA)
• Utah Consumer Privacy Act (UCPA)
• Texas Data Privacy and Security Act (TDPSA)
• Oregon Consumer Privacy Act (OCPA)
• Montana Consumer Data Privacy Act (MCDPA)

If you reside in a state with applicable privacy legislation, you may exercise your rights by contacting privacy@solvitmoney.com.

17. Your Rights Under GDPR

If you are in the European Economic Area (EEA) or United Kingdom (UK), you have the following rights under the General Data Protection Regulation (GDPR) and UK GDPR:

• Right of Access: Obtain confirmation and a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion ("right to be forgotten")
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests or direct marketing
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: File a complaint with your local supervisory authority

To exercise these rights, contact privacy@solvitmoney.com. We will respond within 30 days as required by GDPR.

18. Children's Privacy

Our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@solvitmoney.com. If we discover that a child under 18 has provided us with personal information, we will promptly delete such information.

19. Do Not Track Signals

Our Services do not currently respond to "Do Not Track" signals. However, you may opt out of tracking as described in Section 7 (Cookies and Tracking Technologies).

We honor Global Privacy Control (GPC) signals where required by applicable law. When we detect a GPC signal, we will treat it as a valid opt-out request for the sale or sharing of personal information.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Notify you by email (if you have an account) or through a prominent notice on our Services
• Obtain your consent where required by applicable law

We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes constitutes acceptance of the updated Privacy Policy.

21. Contact Us

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

We will respond to your inquiry within the timeframe required by applicable law (generally 30-45 days).