Effective as of January 1, 2021
3. What Types of Personal Information We May Collect. We may collect Personal Information about you, which may include: name, postal address, zip code, e-mail address, telephone number, account numbers, payment card expiration date, payment card identification or verification numbers, social security number, mobile device location, and other information that we can use to contact you, verify your identity, provide the functionality available through use of the App and the Service, and manage risks, such as information maintained about you by identity verification services and consumer reporting agencies, including credit bureaus, and payment and other transaction information, and history for payments and other transactions in which you participate through the Service, and any Personal Information that you may enter into information blocks present in the App interface or made available through the Service. We may collect information regarding your mobile device such as device settings, unique device identifiers, information about your location, and analytical information that may assist with diagnostics and performance. For your convenience, you may be asked to grant permission for access to your mobile device’s geolocation data. This information may be collected when you use certain services that are dependent on your mobile device’s location (such as the location of an ATM or in store transactions).
4. How We May Collect Personal Information About You. We may collect Personal Information about you from the following sources:
a. Information that you input to the App or that the App collects automatically;
b. Your use of the App and the Service, and your interactions with customer care, including information you enter or speak, and information transmitted by your computer or mobile device or other devices you use as part of your receipt of the Service; and
c. We may also collect Personal Information about you from others, such as Affiliates, or other companies (such as for fraud detection).
5. How We May Share Personal Information About You. We share Personal Information about you only as permitted by law. For Personal Information that is nonpublic and that we collect in connection with a financial service, U. S. federal law permits us to share such information only for the purposes shown in the following table:
|Reasons we can share Personal Information about you||Do we share?||Can you limit this sharing?|
|For our everyday business purposes – such as to process your transactions, respond to court orders and legal investigations, and report to credit bureaus;||Yes||No|
|For our marketing purposes – to offer our products and services to you;||Yes||No|
|For Joint Marketing with other financial companies;||No||We Do Not Share|
|For our Affiliates’ everyday business purposes (information about your transactions and experiences);||Yes||No|
|For our Affiliates’ everyday business purposes (information about your creditworthiness);||No||We Do Not Share|
|For our Affiliates to market to you;||No||We Do Not Share|
|For Nonaffiliates to market to you||No||We Do Not Share|
6. How We May Use Personal Information About You. We use Personal Information about you only as permitted by law, including but not limited to the following purposes:
a. To complete transactions and render services authorized by you;
c. For marketing purposes – to offer products and services to you, although you may opt-out of receiving commercial email marketing messages from us by following the opt-out processes described in those messages; and
d. If we are involved in a merger, acquisition, or sale of all or a portion of our assets that results in a change of the majority ownership of the App or the Service or the entity that owns them, you will be notified of this via email and/or a prominent notice on the App, as well as any material change in uses of your Personal Information, as well as any choices you may have regarding Personal Information about you.
7. Other Important Information.
Vermont: Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our Affiliates, unless the law allows. We will not share information about your credit worthiness with our Affiliates except with your consent, but we may share information about our transactions or experiences with you with our Affiliates without your consent.California: Under California law, we will not share information we collect about you with Nonaffiliates, unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our Affiliates to the extent required by California law.
“Affiliates” means companies related by common ownership or control. They can be financial or nonfinancial companies.
“Nonaffiliates” means companies not related by common ownership or control. They can be financial or nonfinancial companies.
“Joint Marketing” means a formal agreement between nonaffiliated financial companies that together market financial products or services to you.
9. How We Protect Personal Information About You. To protect Personal Information about you from unauthorized access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable federal and state laws. We also require our service providers and business partners to whom we disclose the information to do the same. When you enter sensitive information (such as a debit or credit card number) into the App, we encrypt the transmission of that information using secure socket layer technology (SSL). We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
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