TodayPay Privacy Policy as of Oct 12, 2023
OUR COMMITMENT TO PRIVACY
TodayPay, a TodayPay, Inc. service, knows that you care about how your personal information is used and disclosed, 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 Statement easy to find, we make it available from the home page of the TodayPay website at legal.todaypay.tech (the "website") and through our mobile applications. You may also email us at privacy@todaypay.me with any privacy-related questions you have.
APPLICABILITY OF PRIVACY STATEMENT
This Privacy Statement applies to all information we collect through our Services from current and former TodayPay users, including you. “Services” means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by TodayPay, Inc. in connection with a TodayPay account. When you are no longer our customer, we continue to disclose your information as described in this Statement. This Statement only applies to the Services and does not apply to the practices of any other TodayPay service.
TodayPay is always improving. As the Services evolve we may occasionally update this Privacy Statement to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by posting notice of the change on the "Privacy Policy" page of our website and mobile apps, otherwise the revised Privacy Statement will be effective as of the published effective date.
Throughout this Privacy Statement, 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 person.
THE INFORMATION WE COLLECT
When you visit the website or use one of our mobile applications or other Services, 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 Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service.
If you open a TodayPay 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 Social Security number ("SSN") (or other governmental issued verification numbers).
- Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, 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.
- Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to disclose your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
- Social Web Information - with your consent, we may also collect information from social networks, such as your Facebook Connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your email address, Facebook friends list, and public profile (including profile picture). We also allow you to import data from other social web services, including but not limited to Twitter, FourSquare, 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 TodayPay 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 TodayPay friends, or a comment on either such transaction), a link to your TodayPay 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 TodayPay account. TodayPay does not disclose financial information with third party social networking services such as those listed in the prior bullet.
- Audio, electronic, visual or similar information - Call recordings when you talk to customer service or sales.
- Professional or employment information – including business information, contact emails, phone numbers and taxpayer ID numbers.
- Information you provide when you contact us – your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, information about others if you choose to share it with us.
We may also collect the above data from other third parties, including service providers, internet service providers, partners and merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks and financial institutions.
We are committed to providing a safe, secure and all around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information to comply with law 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 Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or your operating systems 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, store results when you respond to a survey, or when you use TodayPay or another TodayPay service.
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 at by email at privacy@todaypay.me if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
INFORMATION FOR AND ABOUT TEEN USERS
In this section we explain how we handle your data if you use a TodayPay Teen Account. We may offer an account holder (“Account Holder”) the opportunity to create a TodayPay Teen Account for use by an authorized individual between the ages of 13 and 17 years old (“Teen User”). We will not collect more information about you than what is required to use the Teen Account.
What data do we collect?
Identifiers: An Account Holder provides your name, birthday, address, and phone number. You will create a username/password for online account access. You will also provide your email address when you sign up for access to the app. When you use your Teen Account, you can make changes to your name that is displayed to other users.
Device Information: Information about your mobile device or computer such as your device type and IP address.
Internet or network activity: Interactions with our Services, Information about response time for web pages, download errors, date and time when you used the Teen Account, statistics regarding how pages are loaded or viewed, and other usage information.
Why do we collect your data?
To provide our Services: We only collect data from Teen Users that is necessary to interact with the Teen Account, such as to enable you to send or receive money.
To manage and improve our Services: We collect data to conduct customer analysis, provide our Services, and to support internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.
Do we disclose your data?
We may need to disclose data to other parties. Disclose means that other people may see your information. For example, we may disclose the name you have chosen to display to other users when you make a payment to them.
Your data is disclosed with the Account Holder: the Account Holder will be able to monitor and access your activities and manage your user and privacy settings.
We disclose your data with Pathward, N.A. and Visa in order to provide you with the Debit Card services. We may also disclose data with service providers that help us with our internal operations and analysis at our direction, such as processing payments, ensuring compliance, audits, corporate governance, communications, IT development, and maintenance.
We may disclose your information or data with other parties. Depending on the settings an Account Holder chooses, your information or data might be seen by your friends, friends of the other party to the transaction or the public. We may also disclose your data with third parties if there is a legal obligation to do so.
Teen User Data Requests
Along with the Account Holder, you may review the personal information we have about you. You may also request your data be corrected if it is wrong or have it deleted.
If you would like to exercise your access rights, please log on to your account through the browser and submit the data access requests under the privacy link. For all other data subject rights, please contact us by emailing privacy@todaypay.me.
Account Holder Rights
The Account Holder has the right to review the personal information collected online from their Teen User; refuse to allow further use or online collection of personal information from their Teen User; and request the deletion of the personal information collected online from their Teen User (unless we are required to retain it). If an Account Holder doesn’t want us to continue to collect or use their Teen User’s personal information, or if an Account Holder asks us to delete it, we will remove their Teen User’s online profile and close their Teen User’s account. Account Holders that wish to exercise their Teen User access rights, please log on to your account through the browser and submit the data access requests under the privacy link. For all other data subject rights, please contact us by clicking here. The Account Holder will have the ability to control their Teen User’s transaction privacy settings, their visibility on friends’ list and the ability to block users. The Account Holder can make these changes by selecting the Teen account profile in the app.
A Teen User will get alerts and notifications about some activities in their account. Please note that the Account Holder will also receive messages about a Teen User’s activity, such as completed transactions.
HOW WE USE COOKIES
When you visit or use our Services, 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 Services, 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 Services.
Certain Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of certain Services 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.
STATEMENT ON COOKIES & TRACKING TECHNOLOGIES
When you visit or interact with our sites, services, applications, tools or messages, we or our authorized service providers and third parties may use cookies, web beacons, and other similar technologies. These technologies allow our sites, services, applications, and tools to store relevant information in your browser or device. Our authorized service providers and third parties may place cookies on your device via our services.
What are cookies, web beacons, and similar technologies?
Cookies – Are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:
- Session cookies expire at the end of your browser session and allow us to link your actions during that browser session. They remain on your device only for the duration of the browser session.
- Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites. They remain on your device for a longer period.
- First-party cookies are set by the site you are visiting.
- Third-party cookies are set by third-party sites separate from the site you are visiting.
Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites, services, applications, messaging, and tools, that typically work in conjunction with cookies to identify our users and user behavior.
Similar technologies – Technologies that store information in your browser or device utilizing local shared objects or local storage and other web application software methods. These technologies can operate across all of your browsers, and in some instances may not be fully managed by your browser and may require management directly through your installed applications or device. We do not use these technologies for storing information to target advertising to you on or off our sites.
We may use the terms “cookies” or “similar technologies” interchangeably in our policies to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
What information do cookies collect when you access our services?
- Technical Usage Data. Information about response time for web pages, download errors and date and time when you access the service, such as your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.
- Information from your device. Information about your language settings, IP address, browser ID, device ID, cookie preferences, time zone, operating system, platform, screen resolution and similar information about your device settings, and data collected from cookies.
- Location Information. Information from IP-based geolocation such as latitude and longitude data, and Global Positioning System (GPS) information when you give us permission through your device settings.
Why we use cookies?
Our uses of cookies fall into the following general categories:
- Essential. Some cookies are necessary for the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
- Performance. We may use cookies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
- Functionality. We may use cookies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
- Marketing. We may use first-party or third-party cookies to deliver content, including targeted advertising and remarketing, on our sites or on third party sites. This includes using technologies to understand how you interact with our services, the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement, measuring whether ad clicks resulted in successful outcomes, to help optimize our advertisement strategy to reach similar prospects, or help minimize advertisement that is not relevant to some users.
Any personal information that we collect and store through use of the tracking technologies for the Marketing category is based on your consent, obtained through a conspicuous disclosure on our website during your first visit. You can withdraw this consent through your browser settings as explained below.
You may manage your cookie preferences for TodayPay.com by visiting our cookies settings page in the Browser you wish to manage your preferences. When resetting your marketing preferences, we recommend you reset your cookies in your browser settings.
For browser-specific information on how to adjust cookie configurations on the following browsers, please click on the relevant link below:
Use of these technologies by authorized service providers
We may work with third-party companies, commonly known as service providers, who are authorized to place third-party cookies, web beacons, or similar technologies for storing information on our sites or in our services, applications, and tools. These service providers help us to provide you with a better, faster, and safer experience.
These service providers may use these technologies to help us deliver our own content and advertising, and compile site metrics and analytics. We do not permit any of these service providers to collect any of your personal information on our sites or in our services, applications, or tools for their own purposes. These service providers are subject to confidentiality agreements with us and other legal restrictions on their use or collection of any personal information.
With the exception of the use of such technologies by our service providers or other authorized third parties, we do not permit any third-party content on our sites. If you believe an unauthorized third-party might be collecting personal information or using tracking technologies on one of our sites in violation of this Statement, please report it to phishing@todaypay.me.
Ad networks and exchanges operated by authorized third parties for interest-based advertising
We may use third parties, such as advertising networks and exchanges, to allow us to serve you advertisements. These third-party ad networks and exchange providers may use third-party cookies, web beacons, or similar technologies to collect information about your visit to our site and elsewhere on the Internet. They may also collect your device identifier, IP address, or identifier for advertising. The information that these third parties collect may be used to provide you with more relevant advertising on our sites or elsewhere on the web. Third party cookies are covered by the third parties’ privacy policies.
For more information on third-party advertising-related cookies, interest-based advertising, and how to opt-out of that practice by companies participating in industry self-regulation, please visit the relevant website below based on your country of origin:
“Do Not Track”
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn't an industry or legal standard for recognizing or honoring DNT signals, we don't respond to them currently. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
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 laws and 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 information as well, including never sharing your TodayPay password with anyone.
If TodayPay learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that TodayPay may communicate with you electronically. TodayPay may post a notice on the website or mobile applications 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@todaypay.me.
HOW LONG WE STORE YOUR PERSONAL INFORMATION
We retain your Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law.
The criteria used to determine our retention period is as follows:
- Personal Information used for the ongoing relationship between you and TodayPay is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:
- a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under Anti-Money Laundering obligations
- litigation, investigations, audit, and compliance practices, or to protect against legal claims.
Our primary business 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 through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
- create an account connection between your TodayPay 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; and
- if you elect to disclose 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 DISCLOSE PERSONAL INFORMATION WITHIN THE TODAYPAY NETWORK
To process payments on TodayPay, we need to disclose 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 TodayPay.
We work with vendors to enable them to accept payments from you using TodayPay. In doing so, a vendor may disclose information about you with us, such as your mobile phone number or TodayPay username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a TodayPay customer and that the vendor should enable TodayPay 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 TodayPay, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.
HOW WE DISCLOSE PERSONAL INFORMATION WITH OTHER PARTIES
TodayPay does not disclose your personal information with third parties for their promotional or marketing purposes.
Some personal information is public information and may be seen by anyone on the internet, whether or not they have a TodayPay account. Public information may also be seen, accessed, reshared or downloaded through TodayPay's APIs or third-party services that integrate with our products.
- Public information for personal profiles includes your TodayPay username, profile photo, first and last name, month and year of TodayPay account creation, and public transactions in which you've been involved.
- Public information for business or charity profiles includes TodayPay username, profile and background photos, business or charity name, business or charity description, and QR code. Public information for business or charity profiles may be indexed by and searchable on search engines.
In addition to any public information, your TodayPay friends list may be seen by any logged-in TodayPay user; you may adjust or turn off this setting in the privacy section in your account settings.
We may disclose your personal information with:
- Our parent company, TodayPay, Inc. and affiliates and subsidiaries it controls, but only for purposes allowed by this document.
- Companies that TodayPay, Inc. plans to merge with 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 Statement with respect to your personal information. If your personal information could be used contrary to this Statement, 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 TodayPay 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 TodayPay 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 vendor’s behalf.
- The other TodayPay user participating in the transaction and, depending on the privacy setting of each TodayPay account transaction, your TodayPay friends and the TodayPay friends of the other user participating in the transaction, or the public, through the TodayPay 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.
- Partners and merchants, their service providers and others involved in a transaction, for example when you use the Services to initiate online purchases or return goods we may disclose information about you and your TodayPay account with the other parties (or their service providers) involved in processing your transactions. Please note that personal information shared with partners and merchants (or their service providers) involved in a transaction is subject to the partners’ and merchants’ own privacy policy and procedures.
- For our businesses and their beneficial owners, we report personal information to databases maintained by the card networks pursuant to the card scheme rules to fulfill listing and reporting obligations.
- 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 Statement, an "account connection" with such a third party is a connection you authorize or enable between your TodayPay account and a non-TodayPay account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, TodayPay and the third-party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your TodayPay account to a social media account or social messaging service; connecting your TodayPay account to a third-party data aggregation or financial services company, if you provide such company with your TodayPay account log-in credentials; or using your TodayPay account to make payments to a merchant or allowing a merchant to charge your TodayPay account.
- If you connect your TodayPay 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 TodayPay 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 Statement.
- Information that we disclose 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 TodayPay discloses with a third-party account or platform such as a social media account may in turn be disclosed with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
- If you choose to use Siri or iMessage to send payments via TodayPay 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 TodayPay User Agreement. By using Siri or iMessage, you authorize us to disclose some of your TodayPay 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 disclosed 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 TodayPay on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.
TodayPay 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 TodayPay 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 SERVICES OR SITES
The Services may contain links to (or allow you to link to) other third-party services or websites. TodayPay does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information.
HOW TO CONTACT US
If you have questions or concerns regarding this Privacy Statement, or any feedback pertaining to your privacy and the Services that you would like us to consider, please email us at privacy@todaypay.me.
Consumer Privacy Notice
TodayPay is a service provided by TodayPay, Inc. (“TodayPay”)
Facts |
What does TodayPay 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:
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 TodayPay chooses to share; and whether you can limit this sharing. |
Reasons we can share your personal information |
Does TodayPay 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 TodayPay, a service of TodayPay, Inc. in connection with its provision of TodayPay, and is applicable to your personal TodayPay account. |
What we do |
|
How does TodayPay 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 TodayPay 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. |
Definitions |
|
Affiliates |
Companies related by common ownership or control. They can be financial and nonfinancial companies. |
Nonaffiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
|
Joint Marketing |
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: The California Consumer Privacy Act (CCPA) permits consumers who are California residents to ask businesses covered under the CCPA about personal information it has collected about the consumer, submit an access or deletion request, and opt-out of the “sale” or “sharing” of personal information, if applicable. These provisions do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law such as the Gramm-Leach-Bliley Act. Contact us if you have questions about our privacy statement, this consumer notice, or your personal information. If your TodayPay 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 TodayPay 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. We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at legal.todaypay.tech or by emailing us at privacy@todaypay.me. |
California Consumer Privacy Act Notice
California Consumer Privacy Act Notice
If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the business purpose for which we use each category of “personal information” including “sensitive personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information.
Under California law, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We do not sell or share your Personal Information, including any Sensitive Personal Information.
This notice should be read together with TodayPay’s Privacy Statement 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 disclose personal information regarding California residents as described in this notice.
We did not sell or share any consumers’ personal information, including sensitive personal information. This includes personal information about anyone under 16 years of age.
California Residents’ Privacy Rights
California residents and residents of other certain states (such as Virginia) have rights to request access to certain personal information collected about them over the past 12 months, right to correct your personal information, right to opt out of the sale or sharing of personal information, right to limit the use or disclosure of sensitive personal information, or the right to 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.
If you or an authorized agent submit a request, we’ll first need to verify who you are before we can respond to your request. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will compare the information you submit against our internal business records to verify your identity. If we can’t verify your identity, we will not be able to fulfill your request. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.
Global Privacy Control setting is a browser setting that notifies website owners of users' privacy preferences regarding selling or sharing their personal information. TodayPay does not respond to these settings because we do not sell or share data.
You or your authorized agent may contact us by emailing privacy@todaypay.me. Learn more about how we have handled your Privacy Rights.
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: |
We disclosed such personal information with the following categories of third parties for business purpose: |
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. |
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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, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical 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. |
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c. Characteristics of protected classifications under California or federal law, including age or date of birth, national origin, disability, citizenship, military status. |
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d. Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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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. |
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f. Geolocation data, with consent. |
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g. Audio, electronic, visual, or similar information. |
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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, predispositions, behavior, attitudes, and abilities. |
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i. Sensitive Personal Information
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