Privacy Policy and Privacy Notice
Privacy Policy and Privacy Notice
GDPR-Compliant
This Privacy Policy contains the Privacy Notice and California Financial Information Privacy Act form.
Please carefully read this Privacy Policy (hereinafter referred to as “Privacy Policy” or “Policy”). This Privacy Policy describes the ways Cardless, Inc., subsidiaries, our vendors, and other third parties acting on our behalf (collectively, “Cardless”) collect, protect, use, and store your personal information. You accept this Privacy Policy by accessing our website and/or using our products and services (collectively “services”) on our website or through any other means.
We may amend this Privacy Policy at any time by posting a revised version on our website (“the Site”). We will provide notice as required by applicable law upon making any changes. Unless otherwise stated, the revised version will be effective at the time we post it. By using our Services, you are consenting to our processing of your Personal Information and data as set forth in this Privacy Policy now and as amended. Personal Information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. As used herein, “processing” means using or accessing information in any way, including but not limited to collecting, storing, deleting, combining, and disclosing information. If you do not consent to this Privacy Policy, you must cease using the Site immediately.
Important information about procedures for opening a new account
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. This Privacy Policy is incorporated into the Terms of Service by this reference.
Information Cardless collects
Information we often request
The types of Personal Information we collect depends on the products and services you use and your interactions with us and the Site. It may include:
- Your contact information such as your name, address, phone, and email;
- Information that we use to verify your identity, make decisions about your credit card application, or manage risk such as your date of birth, Social Security number (if applicable), your financial account history, your identity, and program eligibility;
- Information about your education, such as your college, degree, major of field of study, test scores, and your personal interests or characteristics;
- Information so we can process your payments such as your bank account numbers;
- Information about your income and/or assets, including your employment, US Form I-20, domestic bank statements or other financial documentation; and
- Information about you when you visit the Site, including information submitted by you or our other customers when interacting with the Site’s features and using its online communication features
Information you give upon registration
If you desire to apply for a Cardless credit card account or access certain parts of the Services, you will be required to become a registered user and to submit certain Personal Information to Cardless. Personal Information that we may collect in such instances may include your full name, email address, mailing address, telephone number, date of birth and other information that you decide to provide us with as part of the credit card application. Additionally, we may request that you upload a copy of your travel passport/national identity card, a copy of your financial statement issued by a US bank, and/or a copy of your US I-20 Form and US Student Visa which are issued by the U.S. Department of Homeland Security in order to verify your identity, program eligibility, and ability to repay debt. We may also ask our users to generate a new personal identification number (PIN) or password to access our Services. In general, we may use any information provided by you to verify your identity or as part of a credit application or other business processes.
Information Cardless learns from your use
When you visit the Site or use the Services, we may collect information from your computer, mobile phone, or any other device. This information may include your IP address and device information including but not limited to identifier, device name and type, operating system, location, mobile network information, and standard web log information such as your browser type, traffic to and from our website, the pages you accessed on the Site, and any other available information.
We may also collect information about your use and interaction with the Site, application, or Services. For example, we may evaluate your computer, mobile phone, or other access device for indicators of fraud, or analyze your website clicks to assess your interest in our specific product terms. When you use our Services, we may also store information based on your usage history. This includes but is not limited to details of your purchases, content you viewed, event information, referring sites or click stream information, and web “cookies” or “tokens” that may uniquely identify your browser, device, or your account.
We may also collect information about you from any contact you have with any of our employees, our customer support team, or through surveys, or through interactions with our agents and/or affiliates. Location Data that Cardless may receive include varying degrees of location information from Social Media Services that you enable within our Service and also (with your permission) from your computing devices. For example, we may collect and use location data (e.g. GPS or IP-based geography detection) to screen for fraudulent activity or to verify self-reported information (for example, to verify you reside in a certain city or near a university in which you are enrolled) and to customize the Service to make it more relevant to you (for example, to send newsletter information that may be of interest to you).
Server log data
When you interact with the Site or use our Services, our servers automatically receive and store certain personally non-identifiable information (“Log Data”). This Log Data is collected passively and may include (but is not limited to) information such as your IP address, browser type, mobile phone type, software settings/configurations, or the domain from which you are visiting, the Site pages you visit, the search terms you use, and any advertisements on which you click. We use Log Data and analytics-based observations to provide you with the Services (for example, to send an SMS to your mobile device) and we may pool Log Data with other information to monitor the use of the Services, and for the technical administration of the Services.
If we are asked to comply with a subpoena or other legal demand or where we suspect that there has been a violation of our policies, then we will associate your IP address with any other Personal Information to identify you personally, according to our Terms of Service and/or applicable law.
Cookies and anonymous identifiers
Like many websites and services, we also may use “cookie” technology to collect additional Site usage data and to improve the Site and Services and related offers. A cookie is a small data file that we transfer to your computer’s hard disk. Cardless may use both session cookies and persistent cookies (known as “persistent tokens”) to better understand how you interact with the Site and our Service, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our Services. A session cookie or security token enables certain features of the Site and Services and is often (but not always) deleted from your computer when you disconnect from or leave the Site. A persistent token will likely remain after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent tokens can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
Payment information
Cardless or its Partners or service providers, contractors, vendors, or other third parties that perform services on behalf of Cardless may collect payment information such as a valid credit card number, type, and expiration date, or other financial information such as a routing & account number for check payments. Payment information is collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable privacy policy.
Bank access/login credentials
Prior to establishing a Cardless account or after a Cardless account is established, or both, we invite Cardless cardholders to enter certain login credentials (such as a username and password) for certain online account types (for example, credit cards, debit cards, or traditional bank accounts) in order to verify their identity. This thereafter provides Cardless with persistent access to the financial account. Cardless uses the access to measure and assess a cardholder’s ability to repay debt or counter fraud.
Contacts information
If you permit Cardless to access the contacts/address book on your phone or other services (such as email) through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and execute our referral program. Access to contacts may be requested as part of a customer referral program or validation of self-reported information. Credit Card transaction information We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, locations, distance traveled, and other related transaction details. Additionally, if someone uses your customer referral code, then we may associate your name with that person.
Aggregated personal data
In an ongoing effort to better understand and serve the users of the Services, Cardless often conducts research on our customer demographics, interests, and behavior based on the information provided to us. This research may be compiled and analyzed on an aggregate basis and Cardless may share this aggregated data with our marketing affiliates, agents, and business partners. This aggregated information does not identify you personally. Cardless may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes. If we de-identify your Personal Information, we publicly commit to retain and use the de-identified Personal Information without attempting to re-identify the de-identified Personal Information.
Information obtained from third parties
We may obtain information about you from third parties such as credit bureaus, the U.S. Department of Homeland Security, student enrollment verification services, and identity verification services. We may also obtain information about you from third-party brand partners, retailers, and merchants, such as your name, address, date or birth, telephone number, and email address. You may choose to provide us with access to certain Personal Information stored by third parties such as social media websites and services or banking websites. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your Cardless account and authorizing Cardless to have access to this information, you agree that Cardless may collect, store, and use this information in accordance with this Policy.
Usage and preference information
We collect information about how you and Site visitors use and interact with our Services, including preferences expressed, and settings chosen. In some cases, we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
How Cardless uses your information
Cardless uses the Personal Information you provide in a manner that is consistent with this Policy. We may use your information, including nonpublic personal information as follows:
- Provide, maintain, and improve our Services;
- To provide inputs to our credit underwriting system and to assess creditworthiness of credit card applicants;
- Provide and deliver the products and services you request, process transactions and send you related information, including confirmations;
- Verify your identity and prevent fraud;
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions, and requests, and provide customer service;
- Communicate with you about products, services, offers, promotions, incentives, and events offered by Cardless and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Conduct audits relating to ad impressions and for compliance with this specification and other standards;
- Debug to identify and repair errors that impair existing intended functionality;
- Undertake internal research for technological development and demonstration;
- Personalize and improve the Services and provide advertisements, content, or features that match user profiles or interests;
- Process and deliver contest or promotion entries and incentives;
- Link or combine with information we get from others to help understand your needs and provide you with better service;
- Carry out any other purpose for which the information was collected;
- With your consent or authorization; and
- For our legitimate business purposes unless otherwise prohibited by law.
If you contact us by email through the Services, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you and provide you with information about our products and services and the products and services of our partners that we believe may be of interest to you. If you decide at any time that you no longer wish to receive such marketing information or communications from us, please follow the unsubscribe instructions provided in any of the communications.
In an ongoing effort to better understand and serve the users of our Services, Cardless occasionally conducts separate research efforts on its customer demographics, interests, and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed in the aggregate and Cardless may share this aggregated data with its affiliates, agents and business partners. This aggregated information does not identify you personally. Cardless may also disclose aggregate user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
When Cardless discloses your information
Information disclosure
We consider your information to be a vital part of our relationship with you and accordingly, we do not disclose it unnecessarily. There are, however, certain circumstances in which we may disclose your Personal Information with certain third parties without further notice to you, as set forth below:
- To enable our Service Providers. We may engage certain trusted third parties to perform functions and provide services to us, including system hosting and maintenance, customer relationship management, database storage and management, marketing communications, web analytics, credit analytics, and credit card processing. We will disclose your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services.
- To process payments and service your Cardless credit card. If we collect credit card information for payments, or other financial information related to payments, then that information will be collected and stored by our Payment Processor. We will from time to time request and receive of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, assessing credit risk, processing invitations to apply for increased credit limits, or enrolling you other programs in which you elect to participate, identifying or researching possible fraudulent transactions, and otherwise as needed to manage our business.
- To enable Social Media Services and related data collection. You can choose to access certain third party communication tools or Social Media Services through our Services. When you do so, you are disclosing information to those Social Media Services, and the information you disclose will be governed by their privacy policies and Terms of Service. You may also be able to modify your privacy settings with these Social Media Services to control what information the Social Media Services disclose to third parties such as Cardless. When you add Social Media Service accounts to the Service or log into the Service using your Social Media Services account, we will collect relevant information necessary to enable our Service and access that Social Media Service. In all cases, you will provide your login information, such as your username and password, directly to the Social Media Service (and not to Cardless). As part of such integration, the Social Media Service will provide us with access to certain information that you have provided to the Social Media Service, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of such third parties, and Cardless shall have no liability or responsibility for the privacy practices or actions of any Social Media Services that may be enabled within the Service.
- Business Transfers. Cardless may sell, transfer or otherwise disclose some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization, sale of certain assets or in the event of bankruptcy.
- Disclosures for Legal Purposes. Cardless may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Cardless, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability. If we are allowed to, we will inform you of the disclosure.
Privacy Notice
Cardless may disclose your Personal Information with third-parties and non-affiliates in accordance with any specific Privacy Notice that we have provided to you as part of your account. We may also disclose your Personal Information with your consent or in situations that further our legitimate business purposes.
How Cardless does not use your information
We don’t sell or rent your Personal Information to third parties.
Access your information
You can review and edit your Personal Information at any time by logging in to your account on the Site or by contacting us at privacy@cardless.com. You can also request to close your account by contacting us at 1-888-227-3537. If you close your Cardless account, we will mark your account in our database as “Closed,” but will keep your account information in our database to comply with our legal obligations. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or in accordance with this Privacy Policy.
Children’s Online Privacy Protection Rule (“COPPA”)
This Site is intended for an adult audience and is not meant for children. Cardless does not knowingly collect information from children under 13. Cardless’ policy is to not collect Personal Information of any person under 13. If Cardless obtains personally identifiable information in error of children under the age of 13, we will delete that information from our systems.
European Union General Data Protection Regulation (EU GDPR)
The aim of the GDPR is to protect the “personal data” of individuals located in the EU– including how data is collected, stored, processed and destroyed. The meaning of “personal data” under the GDPR exceeds how similar terms are defined in the U.S. Cardless accepts and reviews all applicants for credit. However, Cardless only issues cards to residents of the U.S. and its territories and protectorates: the U.S. Virgin Islands, American Samoa, Guam, Puerto Rico, and the Northern Mariana Islands.
How Cardless protects your information
Cardless takes reasonable security measures to protect, store, and process your information while maintaining physical, electronic, and procedural safeguards. However, no method of data transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your information.
We maintain physical security measures to guard against unauthorized access to systems and use electronic safeguards such as firewalls and data encryption. We authorize access to Personal Information only for those employees who require it to fulfill the responsibilities of their jobs. By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a system’s security breach, we may attempt to notify you electronically by posting a notice on our Site, by mail, or by sending an email to you. Cross-border transfers Our servers are located in the United States. Accordingly, if you reside outside the U.S., by using the Services, you acknowledge and agree that your Personal Information will be transferred to the United States and processed and stored in the United States. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
Third party links
Our Services contain links to other websites. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of every website you visit.
Retention of personal information
We store the Personal Information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. We endeavor to retain and dispose of all such Personal Information in accordance with reasonable industry standards.
Miscellaneous
This Privacy Policy is incorporated into the Terms of Service by this reference. If you have questions or concerns regarding this Privacy Policy, you should contact us at privacy@cardless.com or call 1-888-227-3537.
PRIVACY NOTICE
| FACTS WHAT DOES CARDLESS, INC. DO WITH YOUR PERSONAL INFORMATION? |
|---|
| Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share,and protect your personal information. Please read this notice carefully to understand what we do. |
| What? The types of personal information we collect and share depend on the product or service you have with us. This information can include: ·Social Security number and income ·account balances and payment history ·credit history and credit scores When you are no longer our customer, we continue to share your information as described in this notice. |
| How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Cardless, Inc chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does Cardless, Inc. share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes- such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or 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 | Yes | No |
| 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 don't share |
| For our affiliates to market to you | No | We don't share |
| For nonaffiliates to market to you | No | We don't share |
| Questions? | Call 1-888-227-3537 or email us at privacy@cardless.com | | --- |
| WHO WE ARE | |
|---|---|
| Who is providing this notice? | Cardless, Inc. |
| WHAT WE DO | |
|---|---|
| How does Cardless, Inc. protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does Cardless, Inc. collect my personal information? | We collect your personal information, for example, when you: apply for a loan or open an account, give us your contact information or pay your bills, use your credit or debit card. We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. |
| Why can't I limit all sharing? | Federal law gives you the right to limit only: • sharing for affiliates' everyday business purposes - information about your creditworthiness • affiliates from using your information to market to you • sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. |
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| DEFINITIONS | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies. Cardless, Inc. does not share with our affiliates |
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. Cardless, Inc. does not share with nonaffiliates so they can market to you |
| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include brand partners such as retailers and merchants. |
Other important information
Vermont Customers:
We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at www.cardless.com or call 1-888-227-3537.
Nevada Customers:
We are providing you this notice pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our Internal Do Not Call List by calling us at 1-888-227-3537 or emailing us at privacy@cardless.com. Please note that at this time, Cardless does not anticipate engaging in telephonic marketing communications. For more information, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General by mail: 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: 1–702–486–3132; email AGINFO@ag.nv.gov.
California Customers:
Under California law, we will not share information we collect about you with nonaffiliated third parties, unless the law allows. For example, we may share information to service your accounts or to provide rewards or benefits you are entitled to, or with your consent. For information about how we share your information with our affiliates and/or for joint marketing purposes, please refer to the notice provided below, entitled “Important Privacy Choices for Consumers.” North Dakota Customers: We will not disclose information we collect about you with non-affiliated third parties, including for joint marketing purposes, unless you provide consent or as permitted by law.
Important Privacy Choices for Consumers
You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choices below.
Your Rights
You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
Your Choices
Restrict Information Sharing With Companies We Own or Control (Affiliates): Unless you say “No,” we may share personal and financial information about you with our affiliated companies.
(_) NO, please do not share personal and financial information with your affiliated companies. Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you say “No,” we may share personal and financial information about you with outside companies we contract with to provide financial products and services to you.
(_) NO, please do not share personal and financial information with outside companies you contract with to provide financial products and services.
Time Sensitive Reply You may make your privacy choice(s) at any time. Your choice(s) marked here will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services. Your Name: Your Account(s): Your Signature: To exercise your choices, please fill out, sign and send back this form to us to the following address: Cardless, Inc. 350 Townsend, #610, San Francisco, CA 94107 or contact us at privacy@cardless.com.