OUR COMMITMENT TO PRIVACY
Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
PERSONAL DATA WE COLLECT
Personal Data You Provide
We collect personal information when you create an account, link your bank account(s) to the service, enter into transactions with your Braid debit card, or send money to or receive money from other users of the service through the payments platform. The personal information collected during these interactions may vary based on what you choose to share with us, but it will generally include your name, email address, phone number, bank account information (such as account/routing numbers and transaction data), and a log of the transactions you authorize through the payments platform and the Braid debit card. We may need to collect additional information, such as your street address, zip code, date of birth, certain digits of your social security number, and government-issued form of identification to fulfill our legal obligations related to providing the service to you. In addition, while you are using the App, we may collect your location information.
Personal Data We Collect Through Our Social Media Pages
We have pages on social media sites like Facebook, Instagram, and Twitter (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Personal Data We Receive Automatically from Your Use of the Service
When you visit, use and interact with the service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the service (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the service.
- Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
Third Party Credentials, Account Numbers and Other Account Information
When you use certain services, we may collect from you your usernames, passwords, account numbers, and other account information and use or share that information with third-party websites and Internet banking services that are not operated or controlled by Braid (“Third-Party Sites”) in order to provide the services to you. We also collect account information from you when you open a Braid Account and obtain a Braid debit card through our mobile application and we may share that information with our banking partner(s) and third-party providers in order to offer the services to you. Information you provide to us may be used to obtain your account, transaction, and other banking information from the relevant organization on your behalf, to display the information to you, or to fulfill your requests for certain products, services, or transactions through the service.
LINKS TO OTHER WEBSITES
Online Tracking and Do Not Track Signals
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
HOW WE USE PERSONAL DATA
We may use personal information for the following purposes:
- To help you access and use the service;
- To respond to your inquiries, comments, feedback or questions;
- To send administrative information to you, for example, information regarding the service, and changes to our terms, conditions, and policies;
- To analyze how you interact with our service;
- To develop new products and services;
- To market our services or the services of our affiliates or business partners to you;
- To prevent fraud, criminal activity, or misuses of our service, and to ensure the security of our IT systems, architecture and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
We may contact you to tell you about services we believe will be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, please contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and services and to respond to your requests.
SHARING AND DISCLOSURE OF PERSONAL DATA
In certain circumstances we may share your personal information with third parties without further notice to you, unless required by the law, as set forth below:
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, financial service providers (including payment card processors, banks, and API services), customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the Security standards we apply to your personal information.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the services, or the public, or (v) protect against legal liability.
- Other users: Your personal information may be accessible to other users of the service with whom you interact. For example, where you share a sub-account with other users (such as if you create a sub-account to share expenses related to a family vacation), the other users with access to the sub-account will have access to the transactions you authorize within that sub-account.
UPDATE YOUR INFORMATION
Please log in to your account or contact us if you need to change or correct your personal information.
Our service is not directed to children who are under the age of 13. Braid does not knowingly collect personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to Braid through the service please contact us and we will endeavor to delete that information from our databases.
You use the service at your own risk. We implement reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the service or e-mail. Please keep this in mind when disclosing any personal information to Braid via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the service, or third party websites.
In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our services, you may be unable to use those features. You can also contact us to ask us to update or correct your personal information.
CALIFORNIA PRIVACY RIGHTS
California Residents Rights Under The California Consumer Privacy Act
The California Consumer Privacy Act (the “CCPA”) provides that California residents, when making a verifiable consumer request, may request that a business subject to the law that collects consumer personal information to give consumers access, in a portable (if feasible) readily usable form, to the specific items and categories of personal information that business has collected about the consumer, the categories of sources for that information, the business purposes for collecting the information and the categories of 3rd parties with which consumer information is shared. California residents may submit a request for deletion of information under certain circumstances. We will never charge you or provide services of less quality if you choose to exercise your rights under the CCPA, unless the deletion of information at your request impairs our ability to provide those services.
- We do not sell your personal information
- We disclose personal information for business purposes.
You have the right to request the following from businesses that disclose personal information for a business purpose:
(1) The categories of personal information that the business collected about you; and (2) The categories of personal information that the business disclosed about you for a business purpose.
You have the right to request a business delete information collected from you, subject to certain exemptions, such as information necessary to provide services you have requested, necessary to continue any legal relationship we have with you, or comply with legal obligations. However, Braid is required to comply with all existing legislation and requirements around record retention related to financial transactions.
You have the right to be protected from discrimination for exercising your rights under the CCPA. If you exercise your rights under the CCPA, no business may discriminate against you by: (1) denying you any goods or services; (2) charging you different prices or penalizing you; (3) providing you with a different quality of goods or services; (4) suggesting that you will receive a different price, rate, level of quality of goods or services. However, nothing prohibits a business from charging different prices or offering differing qualities of goods and services if the difference is reasonably related to the value provided to the consumer by the consumer’s information.
For additional information on any of the foregoing, or to submit a request for personal information under the CCPA, please send an email to email@example.com with “CCPA” in the subject line. Please understand that we will then need to verify your identity and your residency in California before providing you with any information required by the CCPA.
Additional CCPA Disclosures:
Categories of personal information collected about consumers and disclosed for a business purpose (which business purposes include, but are not limited to providing services, maintaining and servicing accounts, providing customer service, processing transactions, performing analytics and quality control, auditing transactions, researching and testing features and improvements, detecting and preventing fraud and security incidents, debugging or repairing technical errors, marketing our services and compliance with applicable law):
(1) Information you provide us. This includes information you provide when applying for an account or submitting any form in which we request information.
(2) Information we automatically collect. We collect information on how you access and interact with our websites and our services.
(3) Information 3rd parties provide about you. To provide service for which you apply, we will collect information about you from 3rd parties, such as public records providers and other sources.
Braid Privacy Notice
What does Braid Network Inc. (“Braid”) 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:
- Social Security number and Account balances
- Payment history and Transaction history
- Account transactions
When you are no longer our customer, we continue to share your information as described in this notice.
All financial companies need to share 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 Bread chooses to share; and whether you can limit this sharing.
|Reasons We Can Share Your Personal Information||Does Braid 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||Yes||No|
|For our marketing purposes—to offer our products and services to you||Yes||Yes|
|For joint marketing with other financial companies||No||We don’t share.|
|For our affiliates’ everyday business purposes—information about your transactions and experiences||No||We don’t share.|
|For our affiliates’ everyday business purposes—information about your creditworthiness||No||We don’t share.|
|For nonaffiliates to market to you||No||We don’t share.|
To limit our sharing:
- Contact us at firstname.lastname@example.org
If you are a new customer, we can begin sharing your information 45 days from the date we send this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Contact us at email@example.com
Who we are
Braid Network Inc.
How does Braid track 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.
How does Braid collect my personal information?
We collect your personal information, for example, when you:
- Apply for a Braid account;
- Give us your contact information or provide account information; or
- Use your debit card
We may 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. See below for additional information on your rights under state law.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Nonaffiliates we may share with can our bank partners, nonaffiliated marketing companies, and service providers.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Other Important Information
We will also comply with more restrictive state laws to the extent they apply; for example, Vermont and California.