Eli's Privacy Policy

BankingOn, Inc.

Last updated: July 27, 2020

This privacy policy (“Privacy Policy”) applies to consumers (“you”, “your”, or “User(s)”) of our website, mobile application, APP Eli, and the services provided by APP and BankingOn, Inc. (“BankingOn”) (collectively the “Services”). Your use of the Services indicates your acceptance of all of the provisions of this Privacy Policy. If you do not agree to these practices, please don’t use the Services.

We appreciate the trust you place in us and would not want to jeopardize your trust in any way. We respect your privacy and are committed to protecting the security of your personal information. The Privacy Policy discusses our collection, storage, use, and disclosure of your personal information, which may include without limitation information that enables us to identify you directly or indirectly, such as your name, date of birth, address, social security number, telephone number, email, location, or other identifier specific to you (“Personal Information”).

What information does BankingOn collect?

How does BankingOn use my information?

Our primary goal in collecting Personal Information from you is to facilitate efficient transactions, to carry out our obligations to you arising from the Services, to improve the Services, and to provide you with information regarding changes to the Services. More specifically, these uses might include responding to your questions or customer service needs, authenticating your access to APP, connecting APP to your checking account, making transactions on your behalf, notifying you of changes to this Privacy Policy or Terms of Service, monitoring our systems, detecting and preventing fraud, and enforcing our Terms of Service.

How does BankingOn share your Personal Information?

BankingOn will not share, rent, or otherwise disclose your personal information without your permission except for the following circumstances: (i) to trusted employees, contractors, and agents so that they may perform services on your behalf; or (ii) to complete or confirm a transaction that you conduct with us. We will not share your Personal Information with: (a) other financial companies for joint marketing purposes; (b) affiliated companies for their everyday business practices; or (c) any third parties for marketing purposes.

We may share your Personal Information with unaffiliated third parties: (i) if you request or authorize it; (ii) if the information is provided to help complete a transaction for you; (iii) if the information is provided to: (a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Service or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our Users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (iv) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (v) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (vi) for our everyday business purposes; or (vii) as permitted by applicable law or otherwise described in this Privacy Policy. When you are no longer our customer, we continue to share your information as described in this Privacy Policy. Note that we reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.

Is my information secure?

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. We take commercially reasonable steps designed to protect data collected through the Services and your Personal Information. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). Note that our Services run on software, hardware, and networks, any component of which may occasionally require updates, maintenance, or repair and which may experience problems or breaches of security beyond our control. Our third-party service providers will be held to the same or stricter standards in their access and use of your Personal Information as we hold our own employees, contractors, and agents, and we will only transfer your Personal Information to trusted third parties who provide sufficient guarantees with respect to their technical and organizational security measures governing their processing of your Personal Information. Furthermore, our third-party service providers will only be permitted to use your Personal Information for the purpose BankingOn intends and only in accordance with our instructions. We may disclose anonymized, aggregate information to third-parties for our commercial purposes, as well. We currently share such various forms of information with partner banks, data processors, data providers, external cloud databases, and cybersecurity applications. You also play a role in protecting your Personal Information. Please safeguard your username and password for your APP account and do not share them with others. If we receive instructions using your APP account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your APP account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate your accounts, and to remove or edit content.

Accessing Your Information

You must notify us of any change in your Personal Information by updating your APP account profile through our Services. Any changes will affect only future uses of your Personal Information. Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy. You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Third-Party Product Providers

Eli uses Plaid Inc. ("Plaid") to gather End User's data from financial institutions. By using our service, you grant Eli 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.

What are the policies of third-party websites, mobile applications, or services?

This Privacy Policy only addresses the use and disclosure of Personal Information collected from you by BankingOn. You should be aware that when you are using the Services, you may also use or be directed to other websites, mobile applications or services of third parties that are beyond our control. BankingOn is not responsible for the privacy practices of third parties or the content of their websites, mobile applications, or services. We encourage you to read the posted privacy policy whenever interacting with any third party website, mobile application, or service.

Children’s Privacy

APP is not directed to or intended to attract minors under the age of 18. We do not knowingly collect information from individuals under the age of 18. If you are under the age of 18, please do not use the Services or submit any information to us.

Users Residing Outside the United States

We are headquartered in the United States of America. Your Personal Information will be accessed by us or transferred to us in the US and will be accessed by our US-based employees. If you visit our websites or use our Services from outside the US, be aware that your Personal Information will be transferred to, stored, and processed in the US where our servers are located, and our central database is operated. By visiting our websites or using our Services, you consent to this transfer of your personal information. If you are based in the European Union: (1) we will only process your Personal Information for a purpose described in the Privacy Policy if: (i) you have provided your consent (which can be withdrawn at any time); (ii) the processing is necessary for the performance of a contract we are about to enter into or have entered into with you; (iii) we are required by law; or (iv) the processing is necessary for the purposes of our legitimate commercial interests (except where such interests are overridden by your rights and interests); and (2) in certain circumstances you have other rights under the law over the Personal Information we hold about you to:

Where you believe that we have not complied with our obligation under this Privacy Policy or European data protection law, you have the right to make a complaint to an EU Data Protection Authority.

Opt Out; Policy Updates

If you do not wish to receive offers or other notices from us in the future, you can "opt out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your APP account or related transactions with us. BankingOn reserves the right to periodically amend its policies, including without limitation this Privacy Policy. If we amend this Privacy Policy, we will continue our commitment to keep your personal information secure. We will notify you of any changes before they take effect by posting revisions within our mobile application. If you do not agree to the terms of this Privacy Policy or any revised version of the Privacy Policy, your sole remedy is to terminate your access to and use of the Services.

Contact Us

If you have any questions about this Privacy Policy, or need to reach us for any other reason, you may contact us by e-mail at [email protected] or at BankingON, Inc. 5316W Highway 290, Ste 300 Austin TX 78735.