What this means for you: When you obtain a financial product or service offered by us, we may ask for your name, mailing address, other information or documentation, such as a copy of your driver’s license or other identifying documents, to verify your identity, information to identify key individuals who ultimately own or control the business and information to otherwise comply with the applicable laws and regulations.
In connection with your use of the Services, we collect three types of information about you: Business Information, User Information and General Information. Information from any of these categories may be linked with other information that we collect about you.
Business Information. Business Information includes information regarding businesses that use or otherwise access the Services (“Customers”). Business Information includes, but is not limited to
(i) business name, address, email, and telephone number;
(ii) company structure;
(iii) industry type;
(iv) incorporation date;
(v) annual revenue;
(vi) bank account information (e.g., average bank balance, bank statements, credit card statements);
(vii) payment information (e.g., payment history, merchant category code, payment card number);
(viii) accounting information;
(ix) information regarding our transactions and experiences with the business; and
(x) beneficial ownership information.
User Information. User Information includes information about the owners, principals and business representatives, such as: name, job title, user name(s), mailing address, email address, primary telephone number, date of birth, social security number and FICO score.
General information. General Information includes technical information such as information regarding your use of and interactions with the Site. This General Information includes, but is not limited to, information about
(i) your Internet connection;
(ii) the equipment you use to access the Site and usage details;
(iii) your operating system, browser version and internet protocol (IP) address,
(iv) the location of your mobile device, device type, your device’s unique identifier, and your mobile network information;
(v) web pages, content, communications, or advertisements that you view or otherwise interact with; and
(vi) referring/exit pages, clickstream data and information that you search for using the Services.
Information Provided by You. We collect any information you provide when you use the Services. For example, we collect User Information and Business Information from you when you
(i) register an account on the Site,
(ii) fill out forms or fields on the Site or
(iii) complete an application for a product or service available through the Services.
We also collect any information you may submit through communications with us by email, mail, text, telephone, facsimile or other means.
Information Received from Third Parties. In the course of providing the Services, we may also collect additional Business Information or User Information from third parties, including, but not limited to: financial institutions, referral partners, identity verification services, card networks, vendors, mailing list providers, consumer reporting agencies, commercial credit bureaus and associations, fraud prevention agencies, and publicly available sources. We may combine this information with information we already have about you.
Service-Related Usage. We use the information we collect about and from you, both in a personally identifiable form and in an aggregated or anonymized form, for a number of purposes, including for providing, supporting, promoting and improving the Services. Such uses include:
(i) enabling you to obtain products and services through the Services;
(ii) facilitating marketing, processing, servicing, and collections activities;
(iii) providing customer support;
(iv) understanding, customizing, and enhancing your experience;
(v) providing targeted marketing and advertising;
(vi) determining your eligibility for the Services;
(vii) verifying your identity, conducting appropriate diligence, and keeping your information current;
(viii) sending notifications and information regarding the Services;
(ix) measuring and improving the performance and functionality of the Site;
(x) managing and protecting our information technology infrastructure;
(xi) administering and managing the security of the Site;
(xii) developing new products and services;
(xiii) compiling, using, researching, analyzing, and generating data analytics reports to better understand our Customers and to improve the Services; and
(xiv) using the location of your mobile device for location-based Services that you may request, such as for fraud prevention purposes.
Communications. We may communicate with you using the information collected
(i) for customer service,
(ii) to provide you with updates or information relating to the Services, or
(iii) to conduct surveys and collect feedback about the Services.
Marketing and Advertising. We may use the information we collect for marketing and advertising purposes. These purposes may include communicating with you about our products and services, or products and services offered by or through our business partners (including our bank partners), including, but not limited to, providing you with promotional materials that may be useful, relevant, valuable, or otherwise of interest to you, and inviting you to participate in events or surveys.
Compliance with Law and Our Own Obligations. We may use the information we collect, to the extent permitted or required under applicable laws to the extent permitted or required under applicable laws
(ii) to detect and protect against potentially prohibited or illegal activities, including fraud and unauthorized access;
(iii) in response to lawful requests for information or legal process;
(iv) to establish, exercise, or defend a legal claim; and
(v) to comply with our contractual obligations, our policies, industry standards, and applicable laws.
Other Purposes. We may use the information we collect for other purposes for which we provide notice to you at the time of collection or for which we obtain your consent.
Aggregate Data. We may process your information in an anonymized or aggregated form for purposes other than described above.
We may share Business Information, User Information and General Information as follows:
Affiliates and Subsidiaries. We may share your information with and amongst our affiliates and subsidiaries for any of the purposes described in the Use of Information section above.
As Required By Law and Similar Disclosures. We may disclose your information if we believe doing so is required or appropriate to
(i) comply with applicable laws, regulations, and card association rules;
(ii) comply with regulatory investigations, enforcement requests, and legal process, such as subpoenas, court orders, and bankruptcy notices;
(iii) respond to your requests or resolve disputes or inquiries;
(iv) detect, prevent, or otherwise address fraud, confidentiality, security or technical issues;
(v) respond to regulatory authorities jurisdiction over us for examinations, compliance, or other purposes;
(vi) respond to requests from bank partners or third-party auditors; and
(vii) protect your, our, or others’ rights, property, or safety, or the security or integrity of our Services.
Corporate Changes and Transactions. We may disclose your information in connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation, or restructuring; the sale or transfer of some or all of our stock and/or assets; equity or debt financings, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.
Aggregated or Anonymized Information. We may share, license or distribute information in anonymized or aggregated form so that the information does not identify a specific user, without restriction, including, but not limited to, for producing data analytics and reports for third parties.
Consent. We may disclose your information to any third party with your consent. For example, we may disclose information at your direction, as described at the time you agree to share, or when you authorize a third party application or website to access your information.
Other Purpose. To fulfill the purpose for which you provide such information to us or any other purpose disclosed by us when you provide the information to us.
You may choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails. You may also request that we do not call you for marketing related purposes. In addition to following the unsubscribe instruction in relevant email communications, you may make these requests by contacting us at email@example.com, calling us at +1 646 491 0729 or writing to us at Attn: Marketing Opt-Out, 205 W 54th St, Apt 6E, New York, NY, USA 10019. We will respond to your request within a reasonable timeframe. Opting out of marketing emails or notifications will not stop your receipt of non-marketing emails and notifications related to the Services. Various browsers may offer their own tools to manage cookies. If you disable cookies, you can still use the Services, but your ability to use some features of the Services may be limited.
We take reasonable measures, including administrative, technical and physical safeguards to protect your information from loss, misuse, unauthorized access, disclosure, alteration and destruction. These security measures include firewalls, data encryption, physical access controls to our data centers and information access authorization controls. Your information is sent securely to us with at least 128 bit-encryption over the Transport Layer Security (TLS) protocol. This creates an encrypted connection between your browser and us so that any sensitive information you provide can be transmitted securely.
If you link your bank account information as a part of applying for or receiving the Services, we will have read-only access to such information. We do not have access to change, edit or modify your bank account information. We also cannot see your banking credentials (i.e., username and passwords). You are responsible for securing and maintaining the privacy of your banking credentials and account information. We are not responsible for protecting any information you share with a third party in relation to an account connection that you have authorized.
We will retain your information for
(i) as long as reasonably necessary to provide you Services,
(ii) as long as reasonably useful for commercial purposes, or
(iii) as long as necessary to comply with applicable laws and internal policies regarding recordkeeping, reporting, audits and litigation holds.