Zirtue Privacy Policy

Effective Date: January 1, 2020

Thank you for using Zirtue!

Zirtue, LLC (the "Zirtue"), knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy easy to find, we make it available from home page of the Zirtue website at zirtue.com (the "website") and through our mobile applications. You may also email us at privacy@zirtue.com with any privacy-related questions you have.

APPLICABILITY OF PRIVACY POLICY

This privacy policy applies to all information we collect through our web and mobile applications from current and former Zirtue users, including you. When you are no longer our customer, we continue to share your information as described in this policy. This policy only applies to the Zirtue and does not apply to the practices of any other Zirtue service.

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.

HOW WE USE COOKIES

When you visit our website, use our mobile application or the Zirtue, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer; customize Zirtue, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our sites and Zirtue.

Certain aspects and features of the Zirtue and our website are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the websites and Zirtue may be limited or not possible.

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 privacy@zirtue.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:

  • Companies that Zirtue LLC plans to merge with, acquire or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.

  • 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.

    • For the purposes of this privacy policy, an "account connection" with such a third party is a connection you authorize or enable between your Zirtue account and a non-Zirtue account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Zirtue and the third-party will exchange your personal information and other information directly. Examples of account connections include: linking your Zirtue account to a social media account or social messaging service; connecting your Zirtue account to a third-party data aggregation or financial services company, if you provide such company with your Zirtue account log-in credentials; or using your Zirtue account to make payments to a merchant or allowing a merchant to charge your Zirtue account.

    • If you connect your Zirtue account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Zirtue account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.

    • 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.

Zirtue does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of Zirtue and is subject to the terms of use and privacy policies of such third parties.

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.

CHANGES TO OUR PRIVACY POLICY

Zirtue is always improving. As the Zirtue evolve we may occasionally update this privacy policy. If we modify this privacy policy, we will post the revised privacy policy to the website, and we will also revise the "last updated date" stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our mobile application or website or by sending you an e-mail. It is your responsibility to periodically review this privacy policy; users are bound by any changes to the privacy policy by using the Zirtue after such changes have been first posted.

HOW TO CONTACT US

If you have questions or concerns regarding this privacy policy, or any feedback pertaining to your privacy and the Zirtue that you would like us to consider, please email us at privacy@zirtue.com

Consumer Privacy Notice

Zirtue is a service provided by Zirtue, LLC ("Zirtue")

Facts

What does Zirtue do with your personal information?

Why?

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.

What?

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 balances

  • Payment history or transaction history

When you are no longer our customer, we continue to share your information as described in this notice.

How?

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—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes—
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes—
information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes—
information about your creditworthiness

No

We don’t share

For our affiliates to market to you

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

Who we are

Who is providing this Privacy Policy?

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

  • open an account or provide account information

  • link your credit or debit card to your Zirtue account or give us your contact information

  • use your Zirtue account to send or receive funds

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

  • sharing for affiliates’ everyday business purposes— information about your creditworthiness

  • affiliates from using your information to market to you

  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include Central Bank of Kansas City

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Our joint marketing partners include financial companies.

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

In this notice, we are addressing specific disclosure requirements under the California Consumer Privacy Act of 2018 for California residents. This notice should be read together with Zirtue’s Privacy Policy and applies to all California residents who visit our Sites or use the Services.

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.

  • from you when you use our Services

  • merchants

  • service providers

  • financial institutions

  • provide the Services and customer support

  • 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

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • financial institutions

  • merchants

  • third party accounts or platforms

  • parties to the transaction

  • other Zirtue users

  • internet users (some personal information is public information including your Zirtue username, Zirtue profile photo, Zirtue profile first and last name, month, and year of Zirtue account creation, and public transactions in which you’ve been involved, and may be seen by anyone on the internet, whether or not they have a Zirtue account)

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

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.

  • from you when you use our Services

  • merchants

  • service providers

  • financial institutions

  • provide the Services and customer support

  • 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

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • financial institutions

  • merchants

  • third party accounts or platforms

  • parties to the transaction

  • other Zirtue users

  • internet users (some personal information is public information including your Zirtue username, Zirtue profile photo, Zirtue profile first and last name, month, and year of Zirtue account creation, and public transactions in which you’ve been involved, and may be seen by anyone on the internet, whether or not they have a Zirtue account)

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

c. Characteristics of protected classifications under California or federal law.

  • from you when you use our Services

  • service providers

  • provide the Services

  • prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement

  • send you updates about new products and services that we are offering to customers

  • compare information for accuracy and verify it with third parties

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • financial institutions

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

d. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • from you when you use our Services

  • merchants

  • service providers

  • financial institutions

  • provide the Services and customer support

  • 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

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • financial institutions

  • merchants

  • third party accounts or platforms

  • parties to the transaction

  • other Zirtue users

  • internet users (some personal information is public information including your Zirtue username, Zirtue profile photo, Zirtue profile first and last name, month, and year of Zirtue account creation, and public transactions in which you’ve been involved, and may be seen by anyone on the internet, whether or not they have a Zirtue account)

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

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.

  • from you when you use our Services

  • merchants

  • service providers

  • provide the Services and customer support

  • 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

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • financial institutions

  • third party accounts or platforms

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

f. Geolocation data.

  • from you if you elect to share this information

  • service providers

  • to enhance the security of Services, provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content

  • prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

g. Audio, electronic, visual, thermal, olfactory, or similar information.

  • from you when you use our Services

  • provide the Services and customer support

  • process transactions

  • resolve disputes, collect fees, and troubleshoot problems

  • prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement

  • compare information for accuracy and verify it with third parties

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties

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.

  • from you when you use our Services

  • merchants

  • service providers

  • provide the Services

  • prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement

  • 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

  • perform other duties as required by law

  • Zirtue, LLC and affiliates and subsidiaries it controls

  • service providers

  • financial institutions

  • third parties for our business purposes or as permitted or required by law

  • law enforcement, government officials, or other third parties