Privacy Policy

Version 1.2

 

Scope

This Privacy Policy describes System Financial, Inc.’s (“we”, “our”, or “us”), collection, use, disclosure, and protection of your personal information collected or provided through our websites, mobile web app, and mobile device applications (collectively, “Apps”) and how we use personal information in connection with our Services (as defined in our Terms of Service) offered through the Apps. It applies to any Apps where this Privacy Policy is posted, referenced, or linked to.

“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.

By using our Service or otherwise providing us your personal information, you agree to this Privacy Policy and agree to be bound and abide by our Terms of Service. If you do not agree with this Privacy Policy, you may not provide us your personal information or use the Apps.

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.

We use Plaid Technologies, Inc. (“Plaid”) to gather your data from financial institutions. By using our service, you grant us 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. (http://plaid.com/legal)

 

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;
  • enforce our Terms of Service and this Privacy Policy; and
  • 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.

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Apps and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.

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.

Your choices

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

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online promotions, develop new services, or analyze Apps activity. We may permit these service providers to use cookies and similar technologies to perform these services. We do not share any personal information about our customers with these third party service providers, and these service providers do not collect such information on our behalf.

Blogs and other forums

We may offer bulletin boards, blogs, chat rooms, message boards, or similar public forums where you can communicate with us or other users. Any information that you submit or post to these blogs or other forums could be viewed by other viewers or may otherwise be publically available. If you choose to post personal information, other viewers may use this information to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these blogs and other forums. If you would like to request removal of your information from our blogs or other forums, please contact us using the information provided at the end of this Privacy Policy or in the Terms of Service. In some cases, we may not be able to remove your information, and we will let you know if we are unable to do so.

How we use cookies and similar technologies

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.

Changes to this Privacy Policy

We may update this Privacy Policy periodically. Changes are effective immediately upon posting. The date last revised appears at the top of this Policy.

Got Questions

If you have questions or concerns regarding this Privacy Policy, our security practices, or our information handling practices please contact System Financial, Inc. at contact@getonthesystem.com.