DisburseFi Privacy Policy
Last Modified: Jan 4, 2024
DisburseFi and its affiliates (collectively "DisburseFi," "we," "our," or "us") are committed to protecting your privacy. This Privacy Policy explains how your personal data (“Personal Data”) is collected, used and disclosed by DisburseFi. This Privacy Policy applies to all our Services. By accessing or using our Services, or by otherwise demonstrating your consent to this Privacy Policy, you bear that you have read, understood and agree to our collection, storage, use and disclosure of your Personal Data as described in this Privacy Policy and our Terms of Use. If you are an Administrator, you represent and warrant that you are an authorized representative of Company with the authority to bind Company to this Privacy Policy, and that you agree to this Privacy Policy on Company’s and on each User’s behalf.
Terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use.
1. What Information Do We Collect and for What Purpose?
In Table 1, we provide the list of categories of Personal Data that DisburseFi collects and has collected within the last twelve months. We have also identified the main sources and purposes for collection in Table 1.
Please note that additional information may be requested and collected throughout the life of the account relationship to meet regulatory and legal requirements or depending on whether you enable optional features or functionalities of the Services. We may collect any communications between you and DisburseFi, including any photos, text, videos and any other information you upload or provide to us. We may, but have no obligation to, monitor, record, and store any Personal Data you provide to us in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. Optional features may require we collect certain additional data as may be further notified to you in connection with such features. By using the Services or enabling optional features, you consent to the recording, storage and disclosure of such communications you send or receive for the purposes outlined herein or as otherwise notified to you.
Table 1.
| Categories of Personal Data |
Specific Personal information |
Sources of Personal Data |
Purposes for Personal Data Collection |
| Identifiers |
Name, email address, phone number, billing or mailing address, date of birth, national identification numbers and documents that may include your photograph, such as social security number, photo of passport or driver’s license or other valid government photo identification. |
Directly from you, Administrator directly (e.g., forms you complete or services you obtain from us), third parties on your behalf and as instructed by you, other DisburseFi users and customers, our service providers and affiliates. |
• Keep track of the Personal Data associated with your Account
• Help you access and restore access to your Account
• Prevent others from accessing your Account
• Communicate directly with you, such as to send you email messages, push notifications and administrative information (e.g., account verification, change or updates to features of the Service, technical and security notices) |
| Financial Information |
Bank and credit account information, credit history as applicable, details of any transactions carried out using any of our services. |
Directly from you, Administrator directly (e.g., forms you complete or services you obtain from us), third parties on your behalf and as instructed by you, other DisburseFi users and customers, our service providers and affiliates. |
• Permit our financial partners to verify your identity
• Permit us and our financial partners to comply with applicable consumer protection laws and the USA PATRIOT Act
• Provide our Services to you and our customers |
| Business, Professional, and/ or employment-related information |
Business name, business bank account information, business telephone number, business email address, etc. |
Directly from you, Administrator directly (e.g., forms you complete or services you obtain from us), third parties on your behalf and as instructed by you, other DisburseFi users and customers, our service providers and affiliates. |
• Operate, maintain, and provide to you the features and functionality of the Service |
| Internet or other electronic network activity information |
Unique identification number, the model, operating system and version, your browser type and version, the presence of any device, operating system, or browser add-ons, the page you visited before navigating to our Services, and your mobile device’s location services, and your stored contacts. |
Directly from you, Administrator, or website browser indirectly (e.g., from activity on our Site or the App) |
• Analytics
• Advertising and marketing
• To keep our websites and app safe and secure
• Improve our Services |
| Other categories |
Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us or when you choose to participate in surveys where you provide feedback on our services).
Calls/emails/other correspondence. |
Directly from you, third parties on your behalf and as instructed by you | |
| Special categories of Personal Data |
Biometric Data in the form of ‘selfies’ (self-photographs). |
Directly from you, third parties on your behalf and as instructed by you, or from our service providers. |
Processed for the purposes of identity verification when you become a customer. |
2. Sharing of Your Information
Except as described in this Privacy Policy and unless otherwise expressly authorized by you in writing, DisburseFi will never share, sell, or communicate your Personal Data to or with anyone for any reason. We only share and disclose your Personal Data with the third parties set forth in this section. We have categorized each party in Table 2 so that you may easily understand the purpose of our data collection. We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
Table 2.
| Categories of third parties with whom Personal Data has been shared |
Why We Share Your Personal Data |
Is Personal Data shared for a business purpose? |
| Service Providers |
We may share your Personal Data with service providers including third party vendors, consultants, marketing companies, tax professionals and accountants, customer and support services, analytics services and web hosting companies who perform services for us or on our behalf and require access to such information to do that work.
Specifically, we may share your financial statements and other Personal Data with the following:
• Amazon Web Services
• Google
• Microsoft (GitHub)
• Plaid
• Slack
• Security / Compliance Providers
• CPA firms where the CPA firm has requested delivery to occur directly from DisburseFi for independence reasons. |
Yes |
| Law Enforcement |
We may share or transfer your Personal Data to third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of DisburseFi, our visitors, or others. |
No |
| Payment Processors |
We may share your Personal Data with our payment processors as necessary to enable them to process payments, and for anti-fraud purposes.
Yes
Business Partners and Affiliates
We may share your Personal Data with our business partners as necessary to provide you with the Services and to operate the DisburseFi Referral Program.
Specifically, we may share your Personal Data with the following:
• Clearing Partners
• Partner Banks
• Payment Partners |
Yes |
| Other Third Parties |
We may share your Personal Data with other third parties not mentioned above at your direction or with your explicit consent. We may require you to verify your identity prior to sharing the Personal Data. |
Yes |
3. How We Use Cookies and Other Tracking Technology to Collect Information
We, and our third-party partners, automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, objects, web beacons, file information and similar technology (collectively, "Tracking Technologies"). "Cookies" are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will "remember" information about your use. We use both first and third party session cookies and persistent cookies. Session cookies make it easier for you to navigate our Services and expire when you close the Services. Persistent cookies remain on your device for an extended period of time or until you delete them. Persistent cookies enable us to track and target the interests of our visitors to personalize the experience on our Services.
Through the Tracking Technologies we collect information about your device and its software, such as your IP address, browser type, Internet Service Provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your Account, and other such information. We also collect information about the way you use our Services, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on the Services. When you access our Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
We may use one or more third–party analytics services to evaluate your use of the Services, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet Service Provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Website you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.
By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of this Privacy Policy, you may not be able to use the full functionality of the Services. We use the third-party analytics providers listed below; this list is subject to change:
For Google Analytics, please visit: https://www.google.com/analytics
The following link explains how Google uses data when you use its partners’ websites and applications: www.google.com/policies/privacy/partners/. Your use of the Services is evidence of your consent to DisburseFi storing and accessing cookies and other information on your computer or phone and DisburseFi’ use of Google Analytics in connection with such activities. Please read the information at the link provided so you understand what you are consenting to.
We use or may use the data collected through Tracking Technologies to: (a) provide custom, personalized content and information, including content and advertising; (b) identify you across multiple devices; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Services; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Services.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Services, as some features and services on our Services may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies.
We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about use of Tracking Technologies by our third-party partners, please see "Third Party Tracking and Online Advertising" below. For further information about cookies, visit allaboutcookies.org.
4. Control Over Your Personal Data
Profile and Data Sharing Settings: You may update certain profile information, such as profile photo, and may change some of your data sharing preferences on your Settings Page.
How to Control Your Communications Preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
Modifying or Deleting your Personal Data: If you have any questions about reviewing, modifying, or deleting your Personal Data, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at info@disbursefi.com. We may not be able to modify or delete your Personal Data in all circumstances.
5. Site Data
In an ongoing effort to better understand our users and the Services, we might analyze Site Data to operate, maintain, manage, and improve the Services. This Site Data does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose Site Data and aggregate user statistics to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.
6. Third Party Tracking and Online Advertising
We may share, or we may permit third party online advertising networks, social media companies and other third-party services, to collect, information about your use of our Services over time so that they may play or display ads that may be relevant to your interests on our Services as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the Services, and other information. This information is used to display targeted ads on or through our Services or on other websites or apps, including Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s resources at www.aboutads.info/choices. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at info@disbursefi.com.
7. How We Store and Protect Your Information
Data Storage and Transfer: Personal Data collected through our Services may be stored and processed in the United States or any other country in which DisburseFi or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer Personal Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you acknowledge such transfer of information to the U.S. or any other country in which the DisburseFi or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
Keeping Your Information Safe: We care about the security of your Personal Data and use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all Personal Data collected through our Services.
8. Children’s Privacy Policy
DisburseFi does not knowingly collect, use, sell, or solicit any Personal Data from anyone under the age of 13 through our Services. If you are under 13, please do not give us any Personal Data. In the event that we learn that we have inadvertently collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at info@disbursefi.com.
9. Links to Other Web Sites and Services
The Services may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share Personal Data. We are not responsible for the privacy practices or the content on the websites of third-party sites.
10. California Privacy Policy Rights
If you are a California resident, you have the following choices regarding our use and disclosure of your Personal Data subject to certain limitations under the California Consumer Privacy Act (“CCPA”):
Right to know: You may request, up to twice in a 12-month period, the following information about the Personal Data we have collected, used, disclosed or sold about you during the past 12 months:
the categories and specific pieces of Personal Data we have collected about you;
the categories of sources from which we collected the Personal Data;
the business or commercial purpose for which we collected the Personal Data;
the categories of third parties with whom we shared the Personal Data; and
the categories of Personal Data about you that we disclosed for a business purpose and sold to third parties, and the categories of third parties to whom the information was disclosed or sold.
Right to delete. You may request that we delete the Personal Data we have collected from you, subject to certain limitations under the CCPA.
Right to opt-out from sale of Personal Data. You have the right to opt-out of the sale of your Personal Data. We do not sell your Personal Data.
Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
To submit a request to exercise any of the rights described above, you may email us at info@disbursefi.com or fill out this online form. We will verify your identity before responding to your request by either verifying that the email address from which you send the request matches your email address that we have on file, or by requiring you to log into your Account.
Consumer Request by an Authorized Agent
If any authorized agent submits a consumer request under the CCPA on your behalf, we require the authorized agent to submit the following information so that we can confirm their authority to act on your behalf:
Evidence of authorization to act on behalf of the California consumer: (1) California Secretary of State authorization, (2) notarized written permission from the California consumer, or (3) power of attorney.
Evidence of identity of the California consumer: (1) first and last name, (2) email address, and (3) password.
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of Personal Data that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact disbursefi via email at info@disbursefi.com.
11. How to Contact Us
If you have any questions about this Privacy Policy or the Services, please contact us at info@disbursefi.com.
12. Changes to Our Privacy Policy
We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the ’last modified’ date at the top of this page. If you object to any changes, you may close your Account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.
