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LAST UPDATED: JANUARY 2021
Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is NorthOne, Inc. of 18 W 18th St, New York, NY 10011.
BANK INFORMATION: You may contact NorthOne at any time to request information about the Bank by emailing us at firstname.lastname@example.org.
Must Read Sections: We draw your attention in particular to the sections entitled “International Data Transfer” and “Your Rights.”
Changes to this Policy: We will post any modifications or changes to the Policy on our Apps/Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Apps/Services prior to such changes(s) taking effect.
1. PURPOSES OF PROCESSING
What is personal data?
We collect information about you in a range of forms, which could include any information which, either alone or in combination with other information we hold about you, identifies you as an individual, for example, your name, date of birth, social security number, postal address, email address and telephone number.
Why do we need your personal data?
We need certain personal data in order to provide you with access to the Apps/Services. We will only process your personal data in accordance with applicable data protection and privacy laws.
2. COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
Information You Give Us. This includes:
Information We Get from the Bank. We may also get information about you from the Bank, for example, your financial accountant information and transaction history, in order to provide you the Services and information you request from the Bank.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Apps/Services. For example, when visiting our Apps/Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Apps/Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Apps/Services. We collect this information about you using cookies. Please refer to the sections on cookies.
Automated Decision Making and Profiling.
We may use automated decision making and/or profiling in regard to your personal data for some services and products, for example if you opt-in to see if you pre-qualify for certain financial products of the Bank, we may use the information you provide to automatically determine whether you pre-qualify for such products. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us at: email@example.com.
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to help analyze how you use our Apps/Services to improve their design, efficiency and use.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Apps/Services; and (2) third party cookies, which are served by service providers on our Apps/Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our Apps/Services use the following types of cookies for the purposes set out below:
Type of cookie
These cookies are essential to provide you with services available through our Apps/Services and to enable you to use some of its features. For example, they allow us to identify whether you have downloaded the App, or determine whether you qualify for certain features offered through the Apps/Services.Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Apps/Services to remember choices you make when you use our Apps/Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Apps/Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Apps/Services.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Apps/Services and how users use our Apps/Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Apps/Services, the websites that referred them to our Apps/Services, the pages they visited on our Apps/Services, what time of day they visited our Apps/Services, whether they have visited our Apps/Services before, and other similar information. We use this information to help operate our Apps/Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Apps/Services.
We use Google Analytics, Mixpanel and Segment for this purpose.
Google Analytics, Mixpanel and Segment each use their own cookies. These cookies are only used to improve how our Apps/Services works.
You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Apps/Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can find out more information about how Mixpanel processes your data here: https://mixpanel.com/legal/privacy-policy
You can find out more information about how Segment processes your data here: https://segment.com/docs/legal/privacy.
We may place cookies on the websites of our third party partners to track those users who click on links to our website and/or download our Apps. We use this information to help identify the effectiveness of our partners’ links and comply with our requirements with such partners.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Apps/Services. For example, we may not be able to recognize your device and you may need to answer challenge questions or provide additional information each time you log on.
4. DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
5. USING YOUR PERSONAL DATA
We may use your personal data as follows:
6. SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
7. ANONYMOUS DATA
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies.We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Apps/Services.
8. USER GENERATED CONTENT
If you provide feedback to us, we may use and disclose such feedback on our Apps/Services, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first name and last initial along with your feedback on our Apps/Services. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
9. INTERNATIONAL DATA TRANSFER
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and the Bank outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our App(s)/ Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 15 below.
We will retain your personal data (i) as long as reasonably required for you to use the Apps and/or to provide you with the Services; (ii) in order to improve our services; and/or (iii) as required by applicable law or for regulatory purposes.SENSITIVE PERSONAL DATA
If you send or disclose any sensitive personal data to us when you log-in to your account, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you will not be able to create or log-in to an account.
12. YOUR RIGHTS
If you wish to exercise any of these rights, please contact us using the details in Section 15 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for regulatory or recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: firstname.lastname@example.org. We will reply to your complaint as soon as we can and in any event, within forty-five (45) days.
14. CONTACT INFORMATION
We welcome your comments or questions about this Policy. You may contact us in writing at email@example.com or 215 Spadina Ave, Suite 500, Toronto, Ontario, M5T 2C7, Canada.
What does The Bancorp do with your personal information?
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.
The types of personal information we collect, and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice.
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 The Bancorp chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does The Bancorp 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
For our marketing purposes—
to offer our products and services to you
For joint marketing with other ﬁnancial companies
We don’t share
For our afﬁliates’ everyday business purposes—
information about your transactions and experiences
We don’t share
For our afﬁliates’ everyday business purposes—
information about your creditworthiness
We don’t share
For nonafﬁliates to market to you
We don’t share
Who we are
Who is providing this notice?
This notice is provided by the business units of The Bancorp, Inc., and its affiliates, including, but not limited to, The Bancorp Bank, Bancorp Card Services, Inc., and TBBK Direct Leasing, LLC.
What we do
How does The Bancorp 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. We also limit access to information to those employees for whom access is necessary.
How does The Bancorp collect my personal information?
We collect your personal information, for example, when you open an account or apply for a loan pay your bills or make a wire transfer provide account information. 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.
Afﬁliates: Companies related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies. Our affiliates include companies such as The Bancorp Bank, Bancorp Card Services, Inc., and TBBK Direct Leasing, LLC.
Nonafﬁliates: Companies not related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies. The Bancorp 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. The Bancorp doesn’t jointly market.
Other Important Information
In accordance with Vermont law, we will not share personal information about you other than transaction experience information, with other Bancorp companies or affiliates, nor will we share any personal financial information about you with other Bancorp companies for marketing purposes.
Nevada law requires that we provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; email: agInfo@ag.nv.gov
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) permits consumers who are California residents to (a) ask a covered business which categories and pieces of personal information it collects and how the information is used; (b) request deletion of the information; and (c) opt out of the sale of such information, if applicable. These provisions of the CCPA do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law.
To contact us with questions about our compliance with the CCPA, call 1-833-981-1080; visit our website: thebancorpbank.com; or write to: The Bancorp/CCPA, PO Box 5017,
Sioux Falls, SD 57117-5017.
*Banking services provided by LendingClub Bank, N.A. Additional ATM fees may be charged by 3rd party ATMs.
© 2021 NorthOne. All Rights Reserved.
Banking Services provided by LendingClub Bank, N.A, Member FDIC. The NorthOne MasterCard Business Debit Card is issued by LendingClub Bank, N.A pursuant to a license from MasterCard U.S.A. Inc. and may be used everywhere MasterCard Debit Cards are accepted. ATM network fees may apply.