“Personal information” is information that identifies you and that can be associated with a specific person. Personal information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.
Information we process may be transferred to, stored, and processed in, the United States or any other county in which System Financial, Inc. or its affiliates, subsidiaries, or service providers maintain operations. By using and providing information to us through the Apps, you agree and consent to the transfer to, storage in, and processing of your personal information to any such country in order to provide the Service.
Our Services are not intended for persons under the age of 18 or if you are not of a legal capacity to form a binding contract with The System. We do not knowingly collect personal information from persons under the age of 18.
Information we collect
We may collect the following categories of personal information about you through the Apps, including but not limited to:
Registration information: When you register for a Service, you will be asked for basic registration information, such as an email address and password.
Identification information: You may also be asked to provide identification information to confirm your identity, including your first and last name, username, address, and phone number.
Payment account information: For the payment of certain Services, you may be required to provide your checking account and routing numbers.
Third party credentials: You may also enter in certain passwords, usernames, account numbers, and other account information for third-party websites and Internet services ("Third-Party Sites"). These credentials will be used to provide the Services.
Information from Third-Party Sites: In order to display information to you through a Service, we may collect, on your behalf, your account and other personal information from Third-Party that you register under your account via the Service. For example, if you register your Bank of America account with us, we will aggregate your Bank of America information via our Apps in order to graphically present it to you as part of the Services.
Technical and navigational information: We collect information about your interaction with our Apps such as computer browser type, pages visited, average time spent on our Apps, IP address, unique identifiers of the device, operating system version, and app version.
Location information: We do not collect location information.
Other information: We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. In such instances, you will be given the opportunity to provide or decline that information.
How we use the information we collect
We use your personal information to:
- provide and improve the Services;
- fulfill your requests for certain Services;
- respond to your inquiries about our Services;
- analyze Apps usage;
- alert you to software compatibility issues and to improve our Apps design and functionality;
- deliver to you any administrative notices or alerts and communications relevant to your use of the Services;
- offer you other products, programs, or services that we believe may be of interest to you;
- perform market research, project planning, product development, troubleshooting problems, analysis of user behavior, marketing and promotions;
- detect and protect against errors, fraud, or other criminal activity;
- in connection with a merger, sale, of substantially all of our assets, or corporate reorganization.
In order to allow you to use certain Services, we may be required to verify your identity. To do so, we may, directly or through third parties, use information you provide to order a credit report or to verify information you provide against third party databases or through other sources. We may also use your information to verify your identity in the event you contact us for assistance with the Apps or Services.
We may use your information to pre-fill form fields on the Apps for your convenience.
We may use the checking account and credit card information you provide to confirm your accounts are valid and to access funds from your accounts pursuant to your instructions in connection with payment for Services that you subscribe to and to provide those Services.
We may use the information you provide to make payments on your behalf. For example, we may use the information you provide about a third party that you receive bills from to verify the validity of your account with that biller and to route payments to that biller pursuant to your instructions, and we will use your payment account details to access the funds in your specified payment account in order to pay the bills that you request be paid to that biller.
We may use your payment account information to suggest the best payment source. For example, we may recommend that you use a specific credit card to pay a given bill because that card has the lowest APR or other characteristics.
We may use information you provide about Third-Party Sites to provide the Services, which may include accessing the Third-Party Sites you select on your behalf, so that we can present the requested information to you. When you use the Apps, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the "Device ID"). Device IDs allow app developers, advertisers, and others to uniquely identify your device for purposes of storing application preferences and other data.
We may use your Device ID for security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Apps is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access was authorized.
How we disclose personal information
We will not, without your permission, sell, publish, or share your personal information to third parties for their marketing purposes.
We may share some of your personal information with third parties you are attempting to pay in order to process the transactions you have requested. We may also share your personal information with third party service providers to enable them to assist in fulfilling the requests you make or the transactions you conduct via the Apps, including the operation of certain Apps functions and Services.
We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other third parties:
- to respond to subpoenas, court orders, or legal process;
- in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Apps or Services;
- to respond to claims that any posting or other content violates the rights of third parties;
- in an emergency, to protect the health and safety of our Apps' users or the general public; or
- as otherwise required by any applicable law.
We may share your personal information with other third parties with your consent or instructions to do so.
We may share or make available anonymous or aggregate information that cannot be used to identify you individually to other users of the Service for purposes of comparison of their personal financial situation relative to the broader community.
How we protect the information we collect
We take the security of your information seriously. We use technical and administrative security measures such as but not limited to firewalls, encryption techniques, and authentication procedures, among others, to maintain the security of your online session.
We may send periodic Apps related alerts, weekly summaries, notifications, newsletters, promotions, or other information via email. You may choose to stop receiving alerts, summaries, newsletters and promotions by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in the email you receive. Please note that certain Services-related messages that we send are necessary for the proper functioning and use of the Services and you may not have the ability to opt-out of those messages.
Third party data collection
Blogs and other forums
To help operate the Apps, enhance your experience, and collect information about online activity, we may place small data files on your computer or other device. These data files may be in the form of cookies, pixel tags, local shared objects, or other similar technologies. Cookies and similar technologies enable us to personalize our Apps and Service for you. These technologies may allow us to store and manage your preferences and settings, measure and analyze how you use our Apps and effectiveness of our communications, offer targeted products, programs and services, and help us improve our products, services, and security.
Most browsers provide you with the ability to block, delete, or disable these technologies. If you choose to reject cookies or similar technologies, some Services may not be available or some functionality may be limited or unavailable. Please review your browser manufacturer’s help pages for assistance with changing your settings.
Changes to your personal information
You may access, review, and update much of the information you have submitted to us at any time via the Apps or Service.
You may choose to close or request that we delete your account for the Service at any time. We will use commercially reasonable efforts to remove your information, although some information may be retained. For example, some information may be retained on a backup server or media, which is necessary to help ensure continued availability of our Service.
We retain your personal information as long as necessary to provide the services you have requested. Additionally, we may retain personal information to comply with law, prevent fraud, resolve disputes, troubleshoot problems, enforce our Terms of Service, and as permitted by applicable law.