Cookie and personal data policy

Privacy Policy and Federal Privacy Notice – USA

LAST UPDATED: 25 June 2020

PRIVACY POLICY

This privacy policy (‘the Privacy Policy’) applies to ViaBill, Inc. and their affiliates and related companies, (together, ‘ViaBill’, ‘we’, ‘us’ or ‘our’), and details how we collect, manage and use Personal Information, including but not limited to Personal Information collected on our websites, mobile applications, via email, cloud-based services, or controlled widgets embedded in communication platforms with a link to this Privacy Policy (“Websites”). By “Personal Information” we mean information that is associated with a specific person and can be used to reasonably identify that person. Personal information does not include information that has been made anonymous, and cannot reasonably identify a specific person. It covers how we collect, use, and share that Personal Information as of the date that this Privacy Policy is posted.

ViaBill is committed to respecting the privacy of your Personal Information. We appreciate that individuals are concerned about the security of their Personal Information and we are committed to protecting any Personal Information in our custody or control.

This Privacy Policy applies when you sign up for, access, or use our services, features, technologies or functions offered on our Websites (collectively ‘ViaBill Services’) and in relation to Personal Information we may otherwise collect during the course of our business as set out in this Privacy Policy.

ViaBill partners with First Electronic Bank, a Utah state-chartered bank, Member FDIC, which originates and issues all loans through the ViaBill platform. If, after June 22, 2021, you have secured a loan through ViaBill’s services, you are also agreeing to First Electronic Bank’s Privacy policy which can be accessed here.

ViaBill’s retailers (which may include online marketplaces) and commercial partners (together, ‘our Partners’) are independent of ViaBill and may have privacy policies which differ from ours. Our Partners are responsible for their own privacy policies and privacy practices. Please contact our Partners directly for further information on their privacy policies.

The Websites may also contain links to third party websites. These linked sites are not under our control and we are not responsible for content on these sites, nor are these sites subject to this Privacy Policy. Before disclosing your personal information on any third-party website, we recommend that you examine the terms and conditions and privacy policy of that site.

ViaBill may amend the Privacy Policy at any time. The updated version will be available by following the ‘Privacy’ link on the Websites. The revised version will be effective from the time we post it on the Websites. ViaBill may highlight any material changes to the Privacy Policy that may impact you by notifying you by email or otherwise.

Collecting Personal Information

ViaBill strives to be fair and open about the way we collect information about you and what we intend to do with the information.

We receive and store certain types of information from you when you interact with our Websites to deliver the products you request from us, and help improve your overall online experience. For example, like many other websites, we store “cookies” and other web-based files on user devices to get certain types of information when your web browser, mobile phone, or other device accesses our Website. The information sent to us may include data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit our Websites or use ViaBill Services, we may also collect information about your transactions and your activities. Details on our collection of Personal Information through the use of cookies and analytical services is set out below.

In addition, if you open a ViaBill account with us or use ViaBill Services, we may collect the following types of information:

• Contact information, such as your name, address, phone number, email and other similar information.
• Financial information, such as the full bank account numbers and/or credit card numbers that you link to your ViaBill account or give us when you use ViaBill Services.
• Detailed Personal Information such as your date of birth, social security number, driver’s license number, or other identification information or documents.

We may also obtain information about you from third parties including our Partners and related companies, as well as credit reporting bodies and identity verification services, and publicly or commercially available sources for the purposes of complying with relevant legislation (eg. anti-money laundering laws).

ViaBill uses Plaid Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant ViaBill and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

You may choose to provide us with access to certain Personal Information stored by third parties such as social media sites (e.g., Facebook, Google, LinkedIn and Twitter). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your ViaBill account and authorizing ViaBill to have access to this information, you agree that ViaBill may collect, store and use this information in accordance with this Privacy Policy.

We may also collect your Personal Information if you enter a competition or promotion we run (either directly or through our marketing agents or our Partners), or if you apply for employment with us either directly or through a recruitment or employment agency.

We may collect Personal Information about our Partners’ staff directly from those staff or from our Partners. The information we collect about our Partners’ staff may include your name, position, contact details and training records.

We may also collect the Personal Information of our suppliers and service providers’ staff during the course of our business activities. This information may include your name, contact details and position. We will collect this information directly from you, or from the applicable supplier or service provider.

In order to help protect you from fraud and misuse of your Personal Information, we may collect information about your use and interaction with our Websites or ViaBill Services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

We may also collect additional information from or about you in other ways, such as through contact with our customer support team, suppliers or service providers (whether via mail, email or through telephone enquiries), your responses to a market survey, and from interactions with ViaBill’s Partners or as otherwise notified to you at the time.

Using Personal Information

ViaBill only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities, to market to you, or if required by law, court, or tribunal order.

We may use Personal Information we collect about you for a number of purposes including:

• provide (or assess whether to provide) ViaBill Services;
• customer support;
• process transactions and send notices about your transactions;
• resolve disputes, collect fees, and troubleshoot problems;
• investigate and prevent potentially prohibited or illegal activities;
• enforce our User Agreement with you;
• learn more about your level of satisfaction, your expectations of us and our Partners, and how we can meet them (for example, in relation to ViaBill Services, and the goods offered by ViaBill’s retailers);
• customize, measure, and improve ViaBill Services and the content, layout, and operation of our Websites;
• deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
• contact you via telephone, text (SMS) or email messaging, including as authorized by our User Agreement;
• compare information for accuracy and verify it with third parties;
• confirm your identity for the purposes of anti-money laundering and counter-terrorism laws and assess applications and your suitability for ViaBill Services;
• to consider you for a position at ViaBill for which you have applied;
• to acquire goods or services from you or from your employer;
• for the purpose of performing data analytics including to improve our and our Partners’ services;
• for other purposes to which you have consented; and
• as required or permitted by relevant laws and regulations.

You agree that we may use your Personal Information for the purposes for which we collect it and for related purposes which would be reasonably expected by you.

If all or some of your Personal Information is not collected or cannot be verified, we may be unable to provide you with ViaBill Services or a customized experience, engage with you, or do business with you.

How we share Personal Information with other parties

We may share your Personal Information with:

• Our affiliates and related companies;
• Our Partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;
• Our retailers, so that they can provide goods or services to you or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you;
• Financial institutions, including Bank, to service financial products Bank may offer.
• Credit reporting bodies and collection agencies, including to report account information, as permitted by law. When we share your Personal Information with credit reporting bodies, we authorize them to use that information for the purposes of providing their credit reporting services. To request a credit report, we will provide information to the credit reporting body that identifies you;
• Banking partners as may be required by credit card association rules for inclusion on their list of terminated merchants;
• Companies that we plan to merge with or be acquired by or who may invest in us;
• Law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to ViaBill; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate suspected violations of our User Agreement, as allowed by state and/or federal law
• Your nominated referees so that we may check your references if you are applying for a position with ViaBill; and
• Other third parties with your consent or direction to do so.

Please note that these third parties may be in other countries where the laws on processing Personal Information may be less stringent than in your jurisdiction. When we disclose your Personal Information overseas, we will take all reasonable measures to ensure that your information is held, managed and accessed in accordance with appropriate standards for the handling of Personal Information.

In addition, you should note that retailers you buy goods or services from or contract with (even if such goods or services are purchased using ViaBill Services) have their own privacy policies, and ViaBill is not responsible for their actions, including their information protection practices.

We will only share your Personal Information with third parties as described in this Privacy Policy or as otherwise notified to you at the time of collection or with your consent.

If you open an ViaBill account directly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on ViaBill’s Websites) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with Personal Information. ViaBill is not responsible for the content or information practices of such third parties.

Consent

We may require your consent to use and/or disclose your Personal Information if we need to use your information for a purpose that is not related to the purpose for which it was collected.

If you do not consent to ViaBill collecting, using and/or disclosing your Personal Information for such other purposes, this may affect ViaBill’s ability to deliver and improve our products and services, or to engage or do business with you.

When you provide us with your name, date of birth and residential address in establishing your profile with us, you consent to us disclosing that information to credit reporting bodies and requesting an assessment of whether it matches personal information held by the body to assist in verifying your identity under anti-money laundering laws. The body may provide us with that assessment and use your personal information, and the names, residential addresses and dates of birth of other individuals, to prepare that assessment.

If there is a failure to verify your identity in the way described above, we will notify you within the secure ViaBill service or otherwise.

If you do not want to proceed in this way to verify your identity, you should contact us, as provided below.

USA Patriot Act & OFAC Disclosure Important Information about Procedures for Opening a New Account:

To help the government fight the funding of terrorism and money laundering activities, the USA Patriot Act 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 or change your account, you will be asked for your name, address, date of birth, and other information that allows us to identify you. We will also ask to see your driver’s license or other identifying documents. These efforts are designed to prevent crimes such as identity theft, and account fraud by terrorists to finance their operations. We will request the information required by law, and we will use the information only for purposes of complying with the law. Your privacy is our top concern, and we will respect and protect it as always, consistent with the law’s requirements.

Marketing and privacy

ViaBill may send marketing materials from time to time to those who have provided ViaBill with Personal Information about products and services offered by ViaBill and our Partners.

If you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message. You can also log-in to your account to opt-out and update your marketing preferences at any time. Even after you’ve opt-out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product-related inquiries, outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.

You may also contact us on:
Email: help@viabill.com

Controlling Our Tracking Tools & Do-Not-Track Disclosures

Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Websites. If you block or delete cookies, not all of the tracking that we have described in this policy will stop. If you continue without changing your settings, we will assume that you consent to receive all cookies on this Site. You can change your cookie settings at any time. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.

Cookies and third-party analytical services

We use cookies and track IP addresses via our Websites so we can improve our services provided by our Websites and enhance your user experience.

When you access our Websites or use ViaBill Services, we (including our Partners and companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively ‘Cookies’). We use Cookies to ascertain which web pages are visited and how often, to make our Websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in.

For example, Cookies allow us to save your password so you do not have to re-enter it every time you visit our site.

Most web browsers automatically accept Cookies. You can find information specific to your browser under the “help” menu. You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our Websites and ViaBill Services.

Controlling Online Interest-Based Ads

We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Websites. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your postal code may be used

to target an ad for people in your area. These ads may also be based on your activities on our Websites or on third party websites.

Our Websites also use Google Analytics, a web analysis service of Google Inc. (‘Google’). Google Analytics uses Cookies to monitor traffic to, and use of, the Websites. Information about the use of the Websites generated by these Cookies is generally transferred to a Google server in the USA and stored there. Google uses this information on our behalf to evaluate your Website usage, to compile reports on the Websites activities, and to provide additional services connected with the Websites. We will not identify you to Google, and will not merge personal and non-personal information collected through this service. You can prevent the use of Google Analytics Cookies by adjusting the settings on your browser software, however, you may not be able to fully use all of the functions of the Websites if you do so.

In addition to Google Analytics, we may also use other third-party analytics tools including but not limited to Amplitude (an analytics service provided by Amplitude Inc.) to monitor, analyze and collect information about your use of the Websites.

For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit http://optout.aboutads.info

Protecting Personal Information

ViaBill will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorized access, use, modification, and disclosure.

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.

We also review our security procedures periodically to consider appropriate new technology and updated methods. Only properly authorized people who have a need to access Personal Information to perform their job will be able to see or use that information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

Accessing and requesting correction of Personal Information

Email: help@viabill.com

For California Residents. California Civil Code (section 1798.83) gives ViaBill customers who are California residents the right to request certain information about our disclosure of Personal Information to third parties for their own direct marketing purposes. If you wish to make this request, please e-mail, call, or write to us at the address provided above.

If you are a California resident, you may request that we disclose to you the following information:

• The categories of Personal Information that we collected about you and the categories of sources from which we collected such Information 12 months preceding your request;
• The business or commercial purpose for collecting Personal Information about you;
• The categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom we disclosed such Personal Information (if applicable); and
• The specific pieces of Personal Information we collected about you.

If you are a California resident, you may also request that we delete Personal Information that we collected from you. The California Consumer Privacy Act (CCPA) sets forth exceptions for when information is not required to be deleted including, but not limited to, information necessary to provide a good or service that you requested, comply with a legal obligation, detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity.

Resolving your concerns

If you have a complaint regarding ViaBill’s management of your Personal Information, please prepare your complaint in writing and email it to us at help@viabill.com ViaBill will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.

FEDERAL PRIVACY NOTICE (Rev.8/2018)