MoneyUp Financial Inc. understands you may have questions about privacy. This Privacy Notice (“Notice”) describes the types of personal information we collect, how we use the information, with whom we may share it, and the choices available to you. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.
This Privacy Notice applies to MoneyUp Financial, Inc. and its affiliates (collectively, “MoneyUp” “we” or “us”). It applies to all the products and services offered by MoneyUp (including on our website (“Site”) and mobile application (“App”) (collectively, the “Services”)) to U.S. consumers, except where a product or service has a separate privacy notice that does not incorporate this Privacy Notice. Certain individuals also may be provided with additional privacy notices, as described below:
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Table of Contents
The personal information we collect depends on how you interact with us, the services you use, and the choices you make.
We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data.
The types of personal information we may obtain about you include:
We may infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we may infer your general geographic location (such as city, state, and country) based on your IP address.
When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.
When you use our App, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, battery and signal strength, usage statistics, referring emails and web addresses, dates and times of usage, actions taken on the App, and other information regarding use of the App. In addition, we may collect your device’s geolocation information. Your device’s operating platform may provide you with a notification when the App attempts to collect your precise geolocation. Please note that if you decline to allow the App to collect your precise geolocation, you may not be able to use all of the App’s features.
We may use these automated technologies on our Services to collect information about your equipment, browsing actions and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Services, including our online forms, tools or content; (3) tailor the Services around your preferences; (4) measure the usability of our Services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.
For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
We use the personal information we collect for purposes described in this privacy notice or as otherwise disclosed to you. For example, we use personal information for the following purposes:
We may use analytics on our Services. For example, we use Google Analytics to better understand how you interact with our Site. The information we obtain through our Services may be disclosed to or collected directly by these third parties. To learn more about Google Analytics please visit https://www.google.com/policies/privacy/partners/.
On our Services, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests.
To learn how to opt out of interest-based advertising, see our “Your Choices” section below.
We may share the information we obtain about you with our affiliates; our Bank Partners; other MoneyUp users (including in connection with member referrals and use of the user to user payment service); other companies in connection with co-branded products, services or programs; joint marketing partners; research study partners; and consumer reporting agencies. We also may share the information we obtain about you with vendors and other entities we engage to perform services on our behalf, such as payment and check deposit processors, risk detection and mitigation tools, and modeling and analytics tools. See Analytics and Interest Based Advertising above for more information about how we use and share for these purposes.
We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.
We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
We offer you certain choices in connection with the personal information we collect from you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the How To Contact Us section of this Privacy Notice. If you are a MoneyUp member, you may update some of your account details and settings by logging into your account on our Services or by emailing us at email@example.com.
Communications preferences. You can choose to not receive certain promotional communications from us by following the “unsubscribe” hyperlink at the bottom of promotional emails or by replying “STOP” to promotional texts. These choices do not apply to certain informational communications, including certain surveys and mandatory service communications. If you decide you do not want to receive push notifications from MoneyUp, you can use the settings on your mobile device to turn them off.
Cookies and similar technologies.
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
Our Services are not directed to children and you must be 18 or older to open an account with us. In connection with the Services, we do not knowingly solicit or collect personal information from children under the age of 13 without parental consent. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the How To Contact Us section of this Privacy Notice.
Our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy disclosures of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by MoneyUp, we are not responsible for these third parties’ information practices.
This section applies solely to consumers who reside in California and Virginia. If you are a resident of these states, and the processing of personal information about you is subject to the applicable information privacy laws, you have certain rights with respect to that information.
For California Consumers
Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our MoneyUp Privacy Notice and for the following business purposes specified in the CCPA:
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: government entities; other persons to whom we have a legal obligation to disclose personal information (including, for example, in response to a duly issued subpoena or search warrant); and other persons to whom you authorize MoneyUp to disclose your personal information.
Below are rights that are specific to California Residents. California residents also have additional rights as described in the California and Virginia Rights section below.
Right to Opt-Out / “Do Not Sell or Share My Personal Information”. The CCPA requires us to describe the categories of personal information we sell or share to third parties and how to opt-out of future sales. It is important to know that the definition of “sale” and “share” is very broad and the common flow of information for advertising and analytics may be considered a sale or sharing. MoneyUp does not provide information that you might typically think of as personal information to third parties in exchange for money; however, under the CCPA, personal information includes unique identifiers, including things like IP addresses, cookie IDs, pixel tags, and mobile ad IDs. The law defines a “sale” broadly to include simply making such personal information available to third parties in some cases. “Share” is defined as providing personal information to a third party to target advertising to a consumer based on information about their activity on multiple websites across the internet. In the last 12 months, when you access our online services, we may let advertising and analytics providers collect IP addresses, cookie IDs, advertising IDs, and other unique identifiers, which may be collected along with device and usage data, and information about your interactions with our online services and advertisements.
We do not knowingly sell or share the personal information of minors under 16 years of age.
Learn more about how to opt-out in the “how to submit a request” section below.
MoneyUp may offer rewards or prizes for participation in certain activities that may be considered a “financial incentive” under California law. These activities may involve the collection of personal information. The categories of personal information we collect is limited to what information you provide us, but may include: identifiers, protected class/demographic information, commercial information, online activities, geolocation information (general and precise), sensory information, employment information, and inferences.
Activities we engage in that may be considered a financial incentive include surveys where we may provide compensation such as a gift card in exchange for your time, financial activity, and responses, or a prize through your participation in promotions and sweepstakes. Participation in these programs may be subject to separate terms and conditions. Your participation in these programs is voluntary and you can terminate at any time as explained in any applicable terms.
When we offer gift cards in exchange for your participation in a survey or in a financial activity, or when we engage in promotions or sweepstakes, the amount provided is reasonably related to the value of the data you provide, which takes into account a number of factors, including, the anticipated benefit we receive such as product improvement, better understanding how you use our products, to enhance our understanding of consumer and market trends, increased consumer engagement, and the anticipated expenses we incur in relation to the collection, storage, and use of the information we receive. The value may vary across surveys, promotions, and sweepstakes.
If you are a California or Virginia resident, you have rights regarding your personal information, as described below (for California residents, these are in addition to the choices described in the California section above).
Access. You have a right to request that we disclose to you, twice in a 12-month period, the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information, which is also provided in this privacy statement.
Right to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions.
Right to opt-out of targeted advertising (Virginia residents). To opt-out from or otherwise control targeted advertising, you have several options:
-You can utilize any of the options in the “cookie and similar technologies” section under “Your Choices.”
-You can use the controls available through our website to decline advertising-related cookies, which includes by clicking “do not sell or share my personal information”
-You can use the Global Privacy Control setting in a web browser or browser extension as described below.
These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.
Shine the Light Request. You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
How to Submit a Request. To submit an access, correction, or deletion request, please email firstname.lastname@example.org, or call us at (866) 770-7299. To submit a Shine the Light request, email us at email@example.com. If you designate an authorized agent to make an access or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Privacy Notice.
How to Submit a Sale or Share Opt-Out Request. If you’d like to tell us not to make your personal information available in ways that we’ve identified may be a sale or sharing under the CCPA, toggle off the setting your App settings. Alternatively, you can click on our “Do Not Sell or Share” link at the bottom of our homepage or use the Global Privacy Control signal described below, but these options will only be saved to your browser for the session which you are currently active in and will not change your account settings. Further, using these choices will not stop all interest-based advertising and will opt you out of sales and sharing only after the point in time at which you make your selection.
Global Privacy Control. You can also use the Global Privacy Control (GPC). Some browsers and browser extensions support the GPC or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect this signal, we will make reasonable efforts to respect your choices indicated by the GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (with the exception of a request to opt-out of sales). We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your MoneyUp account, one or more recent transactions, and the last four digits of one or more MoneyUp-branded cards associated with your account. If you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Retention of Personal Data. We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.
Additional Information. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us. Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal to firstname.lastname@example.org. Please provide the state that you are writing from and include any documentation you may have regarding the matter that you are appealing.
If you are a resident of the State of California, under the California Consumer PrivacyAct (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically,
To submit a request to exercise any of the rights described above, you may contact MoneyUp Financial, Inc. d.b.a.MoneyUp either by email to email@example.com or contact us via postal mail, proper postage prepaid, at:
MoneyUp Financial, Inc.
Attn: Your California Privacy Rights
335 George St Ste 4 PMB 1084
New Brunswick, NJ 8901
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
We may update this Privacy Notice from time to time and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the Notice when it was most recently updated.
You can update your preferences, ask us to remove your information from our mailing lists, submit a request or ask us questions about this Privacy Notice by calling us at +1 (866) 770-7299 or writing to us at firstname.lastname@example.org.
This Agreement is effective 04/2023