Privacy Policy for the Card Valet Service (Effective as of January 01, 2021)
1. Introduction. This Privacy Policy describes the types of "Personal
Information" (information that is identifiable to a particular person)
that is collected (directly or through service providers) in connection
with the Card Valet downloadable application ("App")
and related services (collectively, the "Service") offered by your
financial institution ("we" or "us"). This Privacy Policy is intended to
supplement the disclosures in any Privacy Policy that you may have
already been presented by us in connection with online banking or other
services.
2. Eligibility. The Service is offered only to individual residents of
the United States, excluding its territories, who can form legally
binding contracts under applicable law. Without limiting the foregoing,
the Service is not offered to minors. Other restrictions and eligibility
requirements for the Service apply as described in the Card Valet Terms
of Use. We do not knowingly collect any Personal Information from or
about individuals under 18 years of age. Please do not submit such
information to us, and as a parent or legal guardian, please do not
allow your children to submit Personal Information without your
permission. By using the App or the Service, you represent that you meet
these requirements and that you agree to the terms of this Privacy
Policy.
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;
b.
Other everyday business purposes, such as to maintain your ability to
access the Service, to send you information about the Service, to
effect, administer and enforce transactions, to perform fraud screening,
to prevent actual or potential fraud and unauthorized transactions, to
verify your identity, to determine your credit history, to verify the
information you provide to the Service, to perform collections, to
report to credit bureaus (including furnishing delinquent account
information), to comply with laws, regulations, court orders and lawful
instructions from government agencies, to protect the personal safety of
users of the Service or the public, to prevent and defend claims, to
resolve disputes, to troubleshoot problems, to enforce our Terms of Use,
to protect our rights and property, and to customize, measure, and
improve the Service and the App, including pattern recognition,
modeling, enhancement and improvement, system analysis, and Service
performance analysis;
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.
8. Definitions.
a. "Affiliates" means companies related by common ownership or control. They can be financial or nonfinancial companies.
b. "Nonaffiliates" means companies not related by common ownership or control. They can be financial or nonfinancial companies.
c.
"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.
10. Data Retention. We will retain, protect, use and share Personal
Information about you as long as it is reasonably required for the
purposes described in this Privacy Policy, and as required by law,
including but not limited to for risk management, regulatory compliance,
and audit purposes.
11. Amendments. We may amend this policy at any time by posting a
revised version in the App. The revised version will be effective
immediately at the time it is posted unless a delayed effective date is
expressly stated therein. You may (in our discretion) also be provided
with an email notification of such amendments. If we make any change in
how we use your Personal Information, we will notify you by email or by
means of a notice in the App prior to the change becoming effective. You
may (in our discretion) be required to affirmatively acknowledge or
accept the revised Privacy Policy in order to continue using the App and
the Service. Any use of the App or the Service after a notice of change
will constitute your express agreement to such changes.