Effective Date: January 1, 2020
Thank you for using Zirtue!
Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
THE INFORMATION WE COLLECT
When you visit the website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use our Service.
If you open a Zirtue account, we collect the following information from you:
Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
Identification Information - your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
Device Information - information about you: (a) from your mobile device such as your device type, device model, machine or mobile device identification number, geo-location, time zone, system OS, app version, cellular network, language setting, advertisement ID, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
Social Web Information - including but not limited to your Facebook connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your friends contact information. We also allow you to import data from other social web services, including but not limited to Twitter, Facebook, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve the Services and fight fraud). Additionally, another Zirtue user may mention you in a transaction to which you are not a party by tagging your username in a transaction note or comment. When you are mentioned in a transaction note or comment into which you have visibility (e.g., a public transaction, a friends only transaction by one of your Zirtue friends, or a comment on either such transaction), a link to your Zirtue profile will appear in the transaction note or comment and, if your push notifications are turned on, you will receive a push notification about the mentions. You may manage certain contact preferences and notifications in your account settings.
Financial Information - bank account online login information, bank account and routing numbers and credit cards linked to your Zirtue account. Zirtue does not share financial information with third party social networking services such as those listed in the prior bullet.
We are committed to providing a safe, secure and all-around great Service. Therefore, before permitting you to use our Service, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.
When you are using the Zirtue, we collect information about your account transactions, and we may collect information about your computer or other access device for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.
INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact Us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.
HOW WE PROTECT & STORE PERSONAL INFORMATION
We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Zirtue password with anyone.
If Zirtue learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Zirtue, you agree that Zirtue may communicate with you electronically. Zirtue may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at email@example.com.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:
provide the services and customer support you request;
process transactions and send notices about your transactions or your network activity;
resolve disputes, collect fees, and troubleshoot problems;
prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
create an account connection between your Zirtue account and a third-party account or platform;
customize, personalize, measure, and improve our services and the content and layout of our website;
send you updates about new products and services that we are offering to customers;
compare information for accuracy and verify it with third parties; and
perform other duties as required by law.
if you elect to share your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.
HOW WE SHARE PERSONAL INFORMATION WITHIN THE ZIRTUE NETWORK
To process payments on Zirtue, we need to share some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through Zirtue.
We work with vendors to enable them to accept payments from you using Zirtue. In doing so, a vendor may share information about you with us, such as your mobile phone number or Zirtue username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a Zirtue customer and that the vendor should enable Zirtue as a form of payment for your purchase.
Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you through Zirtue, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.
HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
Zirtue does not share your personal information with third parties for their promotional or marketing purposes.
We may share your personal information with:
Law enforcement, government officials, or other third parties if Zirtue is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Zirtue User Agreement, or as otherwise required by law.
Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendors behalf.
The other Zirtue user participating in the transaction and, depending on the privacy setting of each Zirtue account transaction, your Zirtue friends and the Zirtue friends of the other user participating in the transaction, or the public, through the Zirtue feed on our website and mobile application and elsewhere on the internet.
Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that Zirtue shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the accounts or platforms privacy practices.
If you choose to use Siri or iMessage to lend or borrow money via Zirtue or to otherwise use the Services, such use is subject to Apple’s terms and conditions for use of iMessage and/or Siri, as applicable, and the terms of the Zirtue User Agreement. By using Siri or iMessage, you authorize us to share some of your Zirtue account data (including your friends list, list of persons you have transacted with most recently and most frequently, transaction instructions, and transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data shared with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to Zirtue on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You can review and update your personal information in your account settings at any time by logging in to your account.
LINKS TO OTHER SITES
The website or mobile application may contain links to other third-party websites. Zirtue does not control the information collection of third-party websites that can be reached through links from the website. We encourage our users to be aware when they are leaving the website and to read the privacy statements of any third-party website that collects personally identifiable information.
HOW TO CONTACT US
Consumer Privacy Notice
Zirtue is a service provided by Zirtue, LLC ("Zirtue")
What does Zirtue 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:
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 Zirtue chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does Zirtue share?
Can you limit this sharing?
For our everyday business purposes—
For our marketing purposes—
For joint marketing with other financial companies
For our affiliates’ everyday business purposes—
For our affiliates’ everyday business purposes—
We don’t share
For our affiliates to market to you
We don’t share
For nonaffiliates to market to you
We don’t share
Who we are
This privacy notice is provided by Zirtue, a service of Zirtue, LLC in connection with its provision of Zirtue, and is applicable to your personal Zirtue account.
What we do
How does Zirtue 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 Zirtue collect my personal information?
We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Other important information
We may transfer personal information to other countries, for example, for customer service or to process transactions.
California: If your Zirtue account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.
Vermont: If your Zirtue account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.
California Consumer Privacy Act Notice
Personal Information Collection and Purposes of Use
We collect, use and share personal information regarding California residents as described in this notice.
We did not sell any consumers’ personal information in the preceding 12 months.
California Residents’ Privacy Rights
California residents have rights to request access to certain personal information collected about them over the past 12 months, or deletion of their personal information, subject to certain exceptions, and may not be discriminated against because they exercise any of their rights under the California Consumer Privacy Act. We may require you to provide additional personal information to verify your identity before we process your request; we may not process your request if we are unable to verify your identity. You may contact us by clicking here.
In the preceding 12 months, we have collected the following categories of personal information from California Residents:
We have collected such personal information from the following categories of sources:
We collected such personal information to use for the following purposes:
In the preceding 12 months, we shared such personal information with the following categories of third parties:
a. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
b. Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
c. Characteristics of protected classifications under California or federal law.
d. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
e. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
f. Geolocation data.
g. Audio, electronic, visual, thermal, olfactory, or similar information.
h. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.