Effective as of January 7th, 2019.
Motiv Money Inc. (“Motiv”, “we”) take your privacy seriously. We do not share your information with third parties unless necessary to provide services to you (e.g. Bank, Investment Advisor (if applicable), and the Motiv website or phone application relaying our services to you). We do not sell your information to third parties for marketing purposes.
Below is our policy on your privacy:
a. Information we collect includes:
Information you provide us: We collect nonpublic personal. information you provide to us when you apply for a Deposit Account or an Investment Account or if you otherwise use Motiv or our website or phone application services to send or receive funds. Additionally, when you communicate with Motiv and Bank about these services, we may collect this information. While not all of this information is necessary to use our services, if you opt out of sharing some of this information, this may affect your ability to use your Deposit Account or Investment Account or other services offered by Motiv, Bank, or Investment Advisor (if applicable).
The types of information we may collect include:
Consumer Identity Information: your name or aliases, physical address, phone number, email address, date of birth, gender, social security number or other tax identification number, photo identification, selfie, or video authorization, or any other information you choose to provide
Business Identity Information (if applicable): entity legal name or aliases / “doing business as” names, physical address, phone number, entity type, industry, organizational documents (e.g. articles of incorporation), employer identification number, or other information relating to your authorized signors or beneficial owners;
Bank Account Information: account and routing details and your username, passwords, and any security questions and answers associated with your linked Bank Account(s); and
Investment Profile Information: information relating to your financial goals and preferences, investment profile (risk appetite and investment time horizon), income range and sources, and other information we may requests from you in order to comply with the applicable law for your Investment Account
Other Information you provide to Customer Support, Bank, Investment Advisor (if applicable), or Motiv: If you provide information to customer support, Motiv or Bank, we may collect this information in order to provide services requested by you.
Information about your transactions: As you use your Deposit Account, Investment Account or otherwise send or receive funds through Motiv’s website or application, we collect nonpublic personal information in connection with each transaction, including transaction time, transaction amount and currency, and details relating to the sender or receiver of funds. We may also collect receipts, contracts, photos, memos or other information relating to your transactions.
Information from other sources: When you create a Deposit Account or Investment Account or otherwise send or receive funds through Motiv’s website or phone application services, we may collect information, including nonpublic personal information, about you from nonaffiliated third party service providers in order to verify your identity and to prevent fraud, and provide our services to you, including information relating to your location, phone number, email address, prior addresses and names, or information made available through a Bank Account you link to our services (e.g. account balances, transaction details, identity related information and your contact details associated with the account).
Additionally, we may collect information you share publicly on your social media accounts. If you do not wish to share this information publicly on your social media accounts, you should adjust your privacy settings with the site.
Information from your digital identity: Your access to Motiv services and Bank services is primarily limited to your internet connected devices. As a result, we may collect some information relating to your digital identity such as:
Digital Identity Related Information: IP address, your device “fingerprint” (e.g. hardware model, operating system and version, unique device identifiers and mobile network information), your device geographical location, browser type, pages visited on our website and pages visited before visiting our website.
Cookies + Our Website: If you visit our website, we use various technologies to collect information on our services and other websites, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us improve our services and your experience, see which areas and features of our services are popular and count visits. While most web browsers are set to accept cookies by default, if you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our website or other services. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
b. How we use your information
We may use your information, including nonpublic personal information as follows:
Provide, maintain and improve Deposit Account services, Investment Account services, and other services we offer you with Motiv and Bank;
Provide and deliver the products and services you request, process transactions and send you related information, including confirmations;
Verify your identity and prevent fraud;
Communicate between Motiv, Bank, and Investment Advisor (as applicable) in order to provide services to you;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Monitor and analyze trends, usage and activities in connection with our services;
Personalize and improve the services based on your usage;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected.
We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.
c. How this information is shared
(1) With financial service providers, including (A) the Bank identified in your Deposit Agreement that provide banking services in connection with your Deposit Account with Bank; and (B) the Investment Advisor identified in your Investment Agreement that provide investment services in connection with your Investment Account (if applicable);
(2) With non-financial companies, such as identity verification service providers and fraud prevention service providers that use the information to provide services to Motiv and other companies;
(4) With other nonaffiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:
In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process;
With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Motiv or others;
In connection with, or during negotiations of, any merger, sale of Motiv’s assets, financing or acquisition of all or a portion of our business to another company; and
With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.
We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share certain transaction details such as amounts and zip codes in a pseudo-anonymous fashion to promote security and validity of the transaction ledger.
We take commercially reasonable measures to help protect your User Data and other information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we implement policies designed to protect the confidentiality and security of your nonpublic personal information. Except as detailed herein as it relates to Bank, Investment Advisor (if applicable), and Motiv, we limit access to your nonpublic personal information to employees that have a business reason to know such information, and implements security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.
What does Evolve Bank & Trust 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 information
· Account balances and payment history
· Credit history and transaction or loss history
When you are no longer our customer, we continue to share your information as described in this notice.
All financial companies need to share customers’ 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 Evolve Bank & Trust chooses to share; and whether you can limit this sharing.
Sharing Your Information
For our everyday business purposes
Evolve Bank & Trust shares your information to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.
For our marketing purposes
Evolve Bank & Trust shares your information to offer our products and services to you through a Motiv (as defined by the Deposit Agreement) or Synapse Financial Technologies, Inc., as a service provider to Evolve Bank & Trust.
We will NOT share your information with our joint marketing companies or affiliates
Evolve Bank & Trust will not share your information for joint marketing with other financial companies, for our affliates’ everyday business purposes such as information about your transactions and experiences, for our affliates’ everyday business purposes such as information about your creditworthiness, or for non-affliates to market to you.
How does Evolve Bank & Trust protect 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 Evolve Bank & Trust collect my personal information?
We collect your personal information, for example, when you:
· Open an account or provide account information
· Pay your bills or apply for a loan
· Make deposits or withdrawals from your account
We also collect your personal information from others, such as credit bureaus 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 non-affiliates to market to you
State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account. Limiting our use of your information may affect our ability to continue perform services for you as further detailed in your Deposit Agreement.
Companies related by common ownership or control. They can be financial and non-financial companies.
EVOLVE BANK & TRUST DOES NOT HAVE AFFILIATES.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
EVOLVE BANK & TRUST DOES NOT SHARE WITH NONAFFILIATES SO THEY CAN MARKET TO YOU. EVOLVE BANK & TRUST DOES EMPLOY SYNAPSE FINANCIAL TECHNOLOGIES, INC. (A THIRD PARTY SERVICE PROVIDER FOR BANKING SOFTWARE SERVICES RELATED TO MOTIV) AND CENLAR (A THIRD PARTY SERVICE PROVIDER, FOR MORTGAGE LOAN SERVICING).
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
EVOLVE BANK & TRUST MAY JOINTLY MARKET BANKING SERVICES WITH MOTIV OR SYNAPSE FINANCIAL TECHNOLOGIES, INC., OUR SERVICE PROVIDER FOR MOTIV.
CALIFORNIA RESIDENTS (consumer account with a California address): Please let us know if you would like to opt out of sharing with affiliates and with non-affiliated financial institutions that are joint marketing partners.
VERMONT RESIDENTS (consumer accounts with a Vermont address): We do not share information about your creditworthiness with our affiliates for their everyday business purposes without first obtaining your specific consent. The information we share pursuant to a joint agreement for marketing is limited to consumer name and contact information and our own transaction and experience information.
ONLINE BANKING PRIVACY: We employ bank grade processes and technologies to protect the privacy and security of your information when you bank online with us (e.g. firewalls, encryption techniques, and authentication procedures). If you visit our website or use any of our electronic banking services, we may put a cookie or similar file on your computer to customize the experience for you. By using cookies, we can collect technical and navigational information, such as computer browser type, internet protocol (“IP”) address, and other computer identification information, and match that with pages visited and time spent on our web pages. This information helps us improve our online services for you. If you use our online banking services outside of a Motiv’s website or application, we also may use the information in the cookie or similar file to match the Internet browser and computer you use with your online account for security purposes. We do not knowingly collect, maintain, or use personal information from our Web sites about children under the age of 13. For more information about our online security practices, please visit our website at https://www.getevolved.com.
Effective as of September 9th, 2017.