Privacy Policy - Banking as a Platform

1. Overview

ShiftCents, Inc. (collectively referred to herein as “BankShift,” “we,” “our,” or “us”) recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users,” “you,” or “your”) who visit our websites or use our services. This Privacy Policy (the “Policy”) applies to our collection, sharing, and use of data about you (“Personal Data”). This Policy shall apply to your use of our websites, including https://bankshift.com, applications, software, communications, capabilities, and services (each, a “Service” and collectively, the “Services”).

BankShift's business customers (“Customers”) use BankShift’s software to provide you with products and services you requested from them under a different brand. This Policy does not cover their data practices. It’s important that you review and understand their policies and agreements that apply to your use of their products and services.

Please familiarize yourself with this Policy and let us know if you have any questions. By using any of our software and services through our Customers, you signify your agreement to this Policy. If you do not agree to this Policy, please do not use the Services. If you have any questions or comments about this Policy, please submit a request to privacy@bankshift.com

Our Policy explains the following topics:

Personal Data We May Obtain
How We Use Personal Data
How We Share Personal Data
Your Consents
How We Protect Personal Data
Our Retention of Your Personal Data
Your Rights and Choices
Children’s Privacy
Website User Terms
Changes to this Policy
How to Contact Us

1. Personal Data We May Obtain

We may obtain Personal Data about you from: (1) you; (2) our Customers from whom you’ve requested products or services; (3) your financial institutions; and (4) third-parties.

The Personal Data that we may obtain depends on the nature of your interaction with us, and the products or services you’re requesting from our Customers. We will only obtain Personal Data that is required for those purposes. If you do not provide necessary information to us or allow us to obtain it from Customers or third-parties, we cannot provide the Services required by our Customers to provide you with the products and services you requested from them.

Personal Data we may obtain includes, but is not limited to, the following:

Personal Identifying Information: name, address, date of birth, Social Security number, email, mobile telephone number
Liability Account Information: names of your financial institutions, creditors, utility providers, account/liability type, account/loan term, account/loan number, routing number, balances, fees and charges, interest rates, due dates, payoff information, transaction and payment history, payment status
Payment/Transfer Account Information: account number, account type, routing number, balance, payment card number, CVC code, card expiration date
Electronic Device Information: IP address, device location and timezone, device model and operating system
Job Application/Employment Information: Personal Identifying Information (see above); information contained on your resume, cover letter, other application submissions, social media sites (like LinkedIn), background check, references; right to work information

We also collect Personal Data through cookies and similar online technologies. For more information, please see “Website User Terms” below.

2. How We Use Personal Data

We use your Personal Data in ways that are compatible with the purpose(s) for which it was collected, or authorized by you including, but not limited to, the following purposes:

To support our Customers in providing products or services you requested from them;
To provide, administer, and maintain the Services and fulfill the purpose(s) for which the Personal Data was collected;
To perform accounting, auditing, and billing activities;
To protect you, other Users, our Customers, ourselves, and others from fraud, misconduct, and malicious activity;
To improve, expand, enhance existing Services and to develop new products and services;
To comply with your direction and consent, permission, or authorization to use the Personal Data;
To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
To comply with applicable laws and regulations, and contractual obligations;
To perform data analysis and testing;
To investigate possible fraud, misconduct, malicious activity, other violations of our agreements or misuse of our Services, and to report or prosecute such conduct;
To resolve disputes and defend against claims;
To interview and vet candidates who applied for employment.

We will ask for your consent before using your Personal Data for a purpose other than those set out in this Policy.

3. How We Share Personal Data

We may share Personal Data so that our Customers can provide you with the products and services you requested from them. This means that we may share Personal Data, only as necessary and as permitted by law, to our Customers, to your financial institutions, or to third-parties who support certain functions required to provide the Services including, but not limited to, identity verification, data cloud providers, payment processing services, compliance monitoring and testing, fraud prevention and detection, and data privacy and security.

We may share Personal Data for legal reasons. For example, we may share Personal Data if we have a reasonable, good-faith belief that disclosure of such information is appropriate to comply with applicable law or regulation, court order or subpoena, or a government request.

We may share Personal Data if we have a reasonable, good-faith belief that such disclosure is appropriate to protect you, other Users, our Customers, ourselves, and others from fraud, misconduct, and malicious activity.

We may share Personal Data with our current or future parents, subsidiaries, or affiliates, or in connection with a business transaction establishing a new, related entity, or resulting in a change of ownership or control such as an acquisition, mergers, or reorganization.

We may share Personal Data based on your consent and at your direction.

We do not sell your Personal Data and do not sell access to your Personal Data.

4. Your Consents

As stated at the beginning of this Policy, our Customers use our Services to provide you with products and services you requested from them. As part of your relationship with our Customer, and to allow our Customer to provide you with the services or products you requested, you acknowledge and agree that:

we may validate your identity and prevent fraud using your Personal Data obtained from our Customer, your wireless carrier, and our service provider(s). Solely for those purposes, you agree that we can share your Personal Data with your wireless carrier and our service provider(s), and that your wireless carrier may disclose information about you to us or our service provider(s);
we may share your Personal Data with one or more consumer reporting agencies, and you consent to us obtaining a consumer report and information about you from them ("credit pull"). You understand the credit pull is a soft inquiry that will not impact your credit score. We will use this information solely in connection with identifying and obtaining data on your liability/debt accounts such as account number, type, balance, interest rate, payoff information, late fees, payment history, etc. ("Enhanced Data");
You authorize and direct us to act on your behalf to access, obtain, and transmit the Enhanced Data from your financial institutions, lenders, creditors, and service providers, or any of their third parties, and you consent to us sharing the Enhanced Data with our Customer. Your authorization, direction, and consent remains effective for the duration of your business relationship with our Customer, solely for the purpose of our Customer providing you with services or products that you may request from them from time to time;
You acknowledge and agree to this Policy (https://bankshift.com/privacy) and our Terms of Service (https://bankshift.com/terms)

5. How We Protect Personal Data

We securely store any Personal Data with a third-party that maintains administrative, technical, and physical safeguards designed to protect Personal Data and other information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Our third-party uses commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL), or hypertext transfer protocol secure (HTTPS) to protect Personal Data.

For your own privacy protection, we urge you to keep all usernames and passwords confidential. You will never need to disclose your username or password for any of your financial accounts to us or to any of our Customers to use the Services. Please do not email us any sensitive information such as passwords, Social Security numbers, or payment information.

If you become aware of any breach of the terms of this Policy or of the security of the Services, please notify us by email at privacy@44.241.150.18

6. Our Retention of Your Personal Data

We keep Personal Data only for as long as necessary to fulfill the purpose for which it was collected, is being used, or to comply with applicable law.

7. Your Rights and Choices

You may have certain rights relating to your Personal Data, subject to applicable law. Whenever you use our Services through our Customers, how we may use your Personal Data is described in this Policy. We aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it—unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of the Personal Data we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

8. Children’s Privacy

We do not knowingly collect personally identifiable information from anyone under the age of 18. Our Services are not designed or intended to be used by anyone under the age of 18. If you are under the age of 18, you are prohibited from using the Services.

9. Website User Terms

If you use and interact with our websites or send us emails, we may collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data. We use information collected from cookies and other technologies, to improve your experience and the overall quality of our Services. If you “Contact Us” from our websites, or download certain content, we may require that you provide to us your contact information, such as your name, phone number, or email address.

We may use your Personal Data to see which of our websites you visit, which website you visited before coming to our website, and where you go after you leave our website. We can then develop statistics that help us understand how our visitors use our website and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We also collect and use aggregated and anonymized data such as statistical data for those same purposes. This data may be derived from your Personal Data, but once in aggregated and anonymized form it will not constitute Personal Data for as this data does not directly or indirectly reveal your identity.

You can generally opt-out, delete, or otherwise manage our websites’ use of cookies and similar technologies.

Direct Marketing and “Do Not Track” Signals

We do not track our Users over time and across third party websites to provide targeted advertising, and therefore we do not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our websites, which may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with our partners, such as advertising services. Our third party advertising and analytics partners include Google, Clearbit, LinkedIn, FullStory, and similar partners.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
Web Beacons. Pages of our Services or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information related to your browsing of our websites. Clickstream data may include information such as the webpage visited, the time spent viewing the page, links you clicked on that page, the preceding page viewed, and similar information. Clickstream data permits us to analyze how visitors arrive at our website, what content of ours is popular, what type of visitors in the aggregate are interested in particular kinds of content on our websites.

10. Changes to this Policy

Our Policy may change from time to time. We will post any updated Policy on our website at https://bankshift.com/privacy. We will also keep prior versions of this Policy and make them available on request.

11. How to Contact Us

If you have any specific questions about this Policy, you can contact us via email at privacy@bankshift.com.