Last Updated: March 15, 2021
Remember that your use of our Services is at all times subject to our Terms of Service, which incorporates this Policy.
This Policy covers how we treat “personal information” that we gather when you access or use our Services. If you have a financial product or service with us, we will use and share any nonpublic personal information that we collect from or about you in accordance with our consumer Policy (see below), which offers you certain choices with respect to the collection, use, sharing, and processing of your nonpublic personal information by financial institutions. This includes any “nonpublic personal information” and “personally identifiable financial information,” as each term is defined by Gramm-Leach-Bliley Act or its promulgating regulations, we collect when you access or use the Services to manage or conduct financial transactions involving a financial institution.
Our Services are intended for a U.S. audience. If you visit or use one of our Services, your information may be transferred or processed in the United States. We currently do not offer products or services to non-U.S. customers.
This Policy only applies to us and not to any third-party sites or services you may access through our website, our mobile application, or by using any of our Services and does not apply to information submitted or collected by websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third-party websites.
What is Personal Information?
When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you. It also does not cover “nonpublic personal information” and “personally identifiable financial information,” which are governed by the consumer policy below.
Our Collection of Personal Information
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.
Personal Information You Provide
We collect the following personal information you provide in connection with our services:
- account registration information, such as your name, email, postal address, user name and password, telephone number and preferences when using our Services;
- information about your personal characteristics, such as your full name, age, phone and/or cell number, date of birth, nationality, gender, signature, utility bills, citizenship, disability, military status, and photographs;
- government-issued identification, such as your social security number or equivalent, driver’s license number, taxpayer identification number, and passport number);
- financial information, such as your bank account information, including account and routing numbers, tax information; credit and debit card information, credit history, and credit scores;
- employment-related information, such as your job title and salary information;
- other information you may provide, such as information you provide when you contact us with questions, feedback, survey responses, participation in contests, promotions or other prospective seller marketing forms or devices, suggestions for improvements of our services or products, referrals, or otherwise communicate with us; and
- personal information you affirmatively disclose to us in connection with your interactions with us, including through your use of our Services.
Personal Information Automatically Collected
As is true of most digital platforms, we collect certain personal information automatically when you visit our online services, including:
- log file data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited;
- analytics data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”);
- location data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device;
- information sent by your mobile device or web browser. We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services; and
- “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Personal Information from Other Sources and Third Parties
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
We receive the same categories of personal information as described above from the following sources and third parties:
- public databases and ID verification partners. We obtain information about you from public databases and ID verification partners to verify your identity and information you may provide us.
- credit reporting agencies. We also obtain information about you from third party sources, such as credit report information, identity verification information, fraud detection processes, where relevant collection procedures, and information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
- data append services, data brokers, and joint marketing partners. We receive personal information from these sources so that we can better understand which of our Services may be of interest to you.
- external bank account information providers. When you use certain Services, we may collect from you, e.g., usernames, passwords, account numbers, and other account information for third-party websites and Internet banking services. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf.
- lenders, financial institutions and brokers. We obtain information about you from your lender, financial institution or broker.
Our Use of Personal Information
We use personal information we collect to:
- to provide you with our Services. We use your personal information to provide you with our Services;
- to improve our Services and run our Services. We may use personal information to research, analyze, and understand how users access and use our Services, both on an aggregated and individualized basis, in order to help us improve our Services and develop new products. We also use personal information to operate, maintain, test, improve (including developing new products and services), enhance, update, monitor, diagnose, fix, and improve our Services;
- to correspond with you. We use personal information to provide you with customer support anytime you reach out to us with questions or issues arising from your account. We also use personal information to send customers technical alerts, updates, security notifications, and administrative communications;
- personalize your experience. When you use our services and sites, as well other third-party sites and services. In this case, we might use tracking technologies like cookies;
- for marketing purposes. We may use your personal information to communicate with you regarding certain products, services or promotions offered by us or certain third-party products and services we believe you may be interested in, provided that you have not already opted out of receiving such communications;
- send you locally relevant options. We can only do this if you agree to let us track your location. If you do, this can help us enhance the security of our sites and services, and customize our services by sending your relevant coupons and otherwise personalizing content for you (e.g., through appropriate ads and search results);
- make it easy for you to find and connect with others. For example, if you let us access your contacts, we can suggest connections with people you may know;
- to detect, investigate, and prevent fraud and security issues. We use your personal information as necessary to protect our company, our customers, and our business partners, including by investigating and preventing fraudulent activities, unauthorized access to the Services, and other illegal activities;
- comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to comply with anti-money laundering laws, to report to credit bureaus, and to respond to subpoenas or requests from government authorities; and
- prevent, investigate, or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you.
If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
We may also use personal information for any other purposes disclosed to you at the time your information is collected or pursuant to your consent.
Our Disclosure of Personal Information
We do not “sell” personal information as most people would typically understand that term. However, we may share your personal information across our services We share your personal information in the following ways:
- service providers. We share your personal information with service providers that we have engaged to perform services on our behalf. This includes service providers that: conduct research and analytics; create content; provide customer, technical or operational support; conduct or support marketing (such as email or advertising platforms); host the Services; maintain databases; send or support online or mobile advertising; allow you to conduct transactions in connection with the Services; and otherwise support or help us provide the Services. Service providers also include payment processors, payment networks, external bank account information provider, credit reporting and scoring agencies, providers of identity services, risk investigation and mitigation service providers, hosting, technology and communication providers, security and fraud prevention consultants, risk investigation and mitigation service providers, support and customer service vendors and product fulfillment and delivery providers;
- advertising and marketing partners. We share your personal information with other third parties, including advertising/analytics partners who enable the delivery of interest-based advertising to users, as well as vendors that provide specific services we do not;
- business transaction or reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- affiliates, investors and business partners. We share your personal information with our affiliates to support the Services and investors and business partners, subject to the terms of this Policy or otherwise as we disclose to you at the time the data is collected;
- credit bureaus and collection agencies. Depending on circumstances, we may share your personal information with credit bureaus and collection agencies, as permitted by law;
- legal obligations and rights. We may disclose personal information to third parties, such as legal advisors and law enforcement:
· in connection with the establishment, exercise, or defense of legal claims;
· to comply with laws or to respond to lawful requests and legal process;
· to detect, suppress, or prevent fraud;
· to reduce credit risk and collect debts owed to us;
· to protect the health and safety of us, our customers, or any person; or
· as otherwise required by applicable law; and
- consent. We may disclose personal information about you to certain other third parties with your consent.
Children’s Personal Information
Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to firstname.lastname@example.org.
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at email@example.com.
Our websites and online services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Policy, this Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective policies.
Protecting Your Information
While we take reasonable steps to protect your personal information, nothing on the internet is 100% secure. For these reasons, we cannot guarantee that all of your personal information will never be disclosed in ways you do not expect or which are not described in this Policy. While we protect our systems and services, we cannot guarantee the security of your information during transmission and any transmission is at your own risk. Also, you are responsible for keeping your password(s) and account information safe and private. You are also responsible for making sure you’re your personal information is accurate and up-to-date.
Updates to This Policy
We will update this Policy from time to time. When we make changes to this Policy, we will change the "Last Updated" date at the beginning of this Policy. If we make material changes to this Policy, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Policy or other privacy-related matters, please send an email to firstname.lastname@example.org.