Eazy Fintech Solutions Privacy Policy
Eazy Fintech Solutions and its affiliates and subsidiaries (collectively, “Eazy Fintech Solutions”) respect your concerns about privacy. This Privacy Policy 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 regarding our use of the information. 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 Policy applies to all the products and services offered by Eazy Fintech Solutions (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 Policy. Certain individuals also may be provided with additional privacy notices, as described below:
Eazy Fintech Solutions customers: When you sign up for an account with Eazy Fintech Solutions, Eazy Fintech Solutions may collect and use your personal information on behalf of The Evolve Bank and Mbanq (collectively, Eazy Fintech Solutions’s “Bank Partners”) to facilitate the provision of banking services pursuant to The Bancorp Consumer Privacy Notice and the Stride Consumer Privacy Notice as applicable. Federal law requires our Bank Partners to provide notice to certain consumers to explain what personal information they collect, how they share it, and how consumers may limit our Bank Partners’ sharing of the information. The privacy practices of our Bank Partners are subject to their privacy notices, which we strongly suggest you review. Eazy Fintech Solutions is not responsible for our Bank Partners’ information practices or privacy notices.
Notice to California Residents: If you are a California resident, please see our California Privacy rights.
1. Information We Obtain
We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with our member services representatives. In addition, we may obtain information about you when you send or receive payments to or from one of our members.
The types of personal information we may obtain about you include:
o Identifiers such as name, Social Security number, date of birth, postal and email address, and phone number;
o Government-issued photo ID, such as a driver’s license or passport, photograph, proof of address documentation and proof of identity documentation;
o Login credentials for your Eazy account;
o Financial information, including your account number from our Bank Partners, Eazy Fintech Solutions account transaction history, account information about your linked non-Eazy Fintech Solutions bank accounts (such as transaction information and balances), and payment card information;
o Direct deposit status (whether you electronically deposit a portion of your regular paycheck or benefit payment above a minimum threshold);
o Information included on a tax return you provide;
o Credit score and other credit history data from a credit reporting agency, if you enroll in certain features of the Services;
o Employment information, including occupation, information about your employer, and income details (such as source of income, approximate annual income and how frequently you are paid);
o Physical characteristics, demographic information and similar details (such as sex, gender, race, color, marital or family status, citizenship status, military or veteran status, signature, language preference and national origin) present in documents (e.g., IDs, tax returns) you provide;
o Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or services;
o Voice recordings (such as when you call to Eazy member services);
o Biometric information (such as a facial image collected for identity verification, if you use
certain features of our App);
o Social media handles;
o Information you provide through member services interactions and that you provide about your experience with Eazy Fintech Solutions, including via questionnaires, surveys, participation in user research or other feedback;
o Geolocation data;
o Information provided by marketers and other websites on which Eazy Fintech Solutions
advertises;
o Information you provide through contacts integration, including a list of contacts from your phone’s operating system; and
o Other information you choose to provide, such as through our “Contact Us” feature, emails or other communications (such as with member services), referrals, on social media pages, or in registrations and sign-up forms.
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, as indicated above, 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 or the offers available through the App. 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. Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to |
use all of the features of our Services. 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. 2. Third Party Credentials, Account Numbers and Other Account Information When you use certain Services, we may collect from you usernames, passwords, account numbers, and other account information for third-party websites and Internet banking services (“Third-Party Sites”). We also collect account information from you when you open a Eazy Banking Account and obtain a Eazy Card through our mobile application. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf in order to display the information to you or to fulfill your requests for certain products, services, or transactions through a Service. We use third-party service providers, such as Mbanq, Evolve Bank and Galileo Financial Technologies, Inc. to obtain this information. By using our Services, you grant Eazy Fintech Solutions, Evolve Bank, Mbanq and Galileo the right, power, and authority to act on your behalf to access and transmit this information from the relevant financial institution, including from Evolve for the Eazy Banking Account and Eazy Card. With respect to Mbanq, you agree to your personal and financial information being transferred, stored, and processed by Mbanq in accordance with Mbanq |
Privacy Policy How We Use the Information We Obtain |
o Provide the Services;
o Process and fulfill transactions;
o Establish and manage Eazy Fintech Solutions accounts;
o Personalize your experience on our Services;
o Facilitate payroll or other direct deposits (including tax refunds) to your Eazy Fintech Solutions account;
o Facilitate transfers between your external bank accounts and Eazy Fintech Solutions accounts;
o Verify your identity, including to facilitate a name change request;
o Respond to inquiries, provide member support and resolve disputes;
o Determine your eligibility for, and administer your participation in, certain features of the Services, including surveys, contests, sweepstakes, promotions and rewards;
o Facilitate and manage referrals from our business partners;
o Identify recipients for Eazy transfers;
o Advertise and market our products and services, and send information about third -party products and services we think may interest you;
o Provide you targeted offers and notify you of nearby third-party locations where you may use our products and services;
o Provide member support and quality assurance, and conduct customer service training; o Collect fees and other amounts owed in connection with your Eazy Fintech Solutions
account;
o Operate, evaluate and improve our business (including researching and developing new products and services; enhancing, improving, debugging and analyzing our products and services; managing our communications; establishing and managing our business relationships; and performing accounting, auditing and other internal functions);
o Maintain and enhance the safety and security of our products and services and prevent misuse;
o Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
o Exercise our rights and remedies and defend against legal claims; and
o Comply with and enforce applicable legal requirements, relevant industry standards and Eazy Fintech Solutions policies.
We also may use the information in other ways for which we provide specific notice at the time of collection. Third-Party Analytics Services We may use third-party analytics services on our Services, such as Google Analytics. The information we obtain through the Services may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. 2.1 Interest-Based Advertising On our Services, we may obtain information about your online activities to provide you with a dvertising about products and services that may be tailored to your interests. This section of our Privacy Policy provides details and explains how to exercise certain choices. You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track your online activities over time and across multiple websites and apps by |
collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information ad services may collect includes data about your visits to websites that serve Eazy Fintech Solutions advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Services and on third -party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts. The Services are not designed to respond to “do not track” signals from browsers. To learn how to opt out of interest-based advertising in the U.S., please 3. Information We Share We may share the information we obtain about you with our affiliates and subsidiaries; our Bank Partners; other Eazy Fintech Solutions users (including in connection with member referrals and use of the EazyPay service and Eazy Transfer); other companies in connection with co-branded products, services or programs; joint marketing partners; and consumer reporting agencies. We also may share the information we obtain about you with third-party 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. 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 se ll 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). |
4.Your Rights 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 at policies@eazyfintechsolutions.com section of this Privacy Policy. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. If you are a Eazy Fintech Solutions member, you may update certain of your account details and settings by logging into your account on our Services or by emailing us at support@eazyfintechsolutions.com 5.How We Protect Personal Information 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. 6.Children’s Privacy Our Services are designed for a general audience and are not directed to children. 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 at support@eazyfintechsolutions.com 7.Links to Third-Party Services and Features For your convenience and information, 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 statements 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 Eazy Fintech Solutions, we are not responsible for these third parties’ information practices. 8.Updates to Our Privacy Policy We may update this Privacy Policy 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 policy when it was most recently updated. |
9.How to Contact Us 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 Policy by calling us at +1 (408) 430-2195 or writing to us at support@EazyFintechSolutions.com. |
California Privacy Rights The California Consumer Privacy Act (“CCPA”) allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Eazy Fintech Solutions |
will not discriminate against you for exercising your rights, such as by denying you services, charging you different prices for services, or providing you a different level or quality of services. Please note that you must verify your identity and request before further action will be taken. As part of this process, we may require you to provide government identification. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification. We do not sell your personal information to third parties. We do, however, share personal information with third parties for the business purposes described in this Policy. California law also permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to exercise your data protection rights, where applicable, you can |
submit a request contacting us through Eazy Fintech Solutions’s Mobile App or trough support@eazyfintechsolutions.com. We will consider all requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such |
requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.
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