Last Updated: April 20 2023
These Disclosures apply solely to our processing of personal information of individual California residents within the scope of CCPA. Any terms defined within the CCPA have the same meaning when utilizing within this CA Disclosures. The other provisions of the Policy continue to apply except as modified in these CA Disclosures.
These CA Disclosures do not apply to:
The majority of personal information that eMoney collects or maintains, including as a service provider to financial institutions, is covered by one or more of the exemptions described below (“CCPA Exemptions”). As a result, in most cases, eMoney may deny CCPA requests because the personal information at issue is subject to an exemption. For example, your CCPA request may be denied if:
You can find a list of the categories of personal information that we collect in the “Our Collection of Personal Information” section above. For details regarding the sources from which we obtain personal information, please see the “ Our Collection of Personal Information” section above. We collect and use personal information for the business or commercial purposes described in the “Our Use of Personal Information” section above.
In the last 12 months, we have collected and disclosed the following categories of personal information for a business purpose:
|Category of Personal Information||Collected?||Disclosed for Business Purpose?|
|Basic Identifiers: Name, postal address, phone
number, and email address, and similar identifiers
|Personal Information Categories in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): including your contact information, identifiers, such as name, email address, mailing address, phone number, account id, and security/authentication information, financial account information, joint account holder and family information, credit and identity information relating to your account, account history relating to your account, and any other information you provide to us, including tax records, income level and signature||Yes||Yes|
|Protected Classification Characteristics: including age, date of birth, gender, and sex.||Yes||Yes|
|Commercial Information: including account history, investment history, purchases, transaction information, insurance coverage information, service profile information, interests, and feedback information, order details, order/product preferences, and credit information||Yes||Yes|
|Biometric Information: Particular survey participants only||Yes||Yes|
|Device Information and Other Unique Identifiers: including log file data (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our Sites or Services)||Yes||Yes|
|Geolocation Data: including your general geographic location based on your IP address or more precise location when accessing our Sites or Services through a mobile device||Yes||Yes|
|Sensory Information: including voice recordings from calls to customer service||Yes||Yes|
|Profession/Employment Information: including the business you represent your employer, department, income if provided, work history, and work title||Yes||Yes|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99): including education history and any other educational information provided to us.||Yes||Yes|
|Inferences Drawn from Personal Information Collected: including user preferences, customer characteristics, and behaviors.||Yes||Yes|
|Sensitive Information: including social security, driver’s license, state identification card, or passport number; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; sexual orientation.||Yes||Yes|
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information (which includes the charts above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for your personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means. For certain types of personal information, we will only maintain it for a limited duration. For example, for the Sensory Data we collect, we retain customer care call recordings for one (1) year.
Subject to certain limitations, California residents have the right to request access to (also referred to as the “right to know”) the categories and specific pieces of personal information we collect, use, and disclose; the right to request deletion of their personal information; the right to correction of their personal information; the right to opt out of any selling or sharing of personal information that may be occurring; the right to limit use and disclosure of their sensitive information; and the right to non-discrimination.
Right to Know
You have the right to request:
Right to Delete
You have the right to request the deletion or erasure of personal information we have collected about you. Following receipt of a verifiable request to delete, we will let you know what, if any, personal information we can delete from our records. We will also notify our service providers and contractors, and any third parties to which we transferred your information about your request to delete. If we cannot delete all of your personal information, we will let you know why.
Right to Correct
You have the right to request the correction of personal information we have collected about you. Upon receipt of a verifiable request to correct inaccurate personal information, we will take into account the nature of the personal information and the purposes for which we process it. We may require documentation from you in order to process your request where we have reliable documentation showing the accuracy of the information.
Right to Opt-Out
You have the right to direct us to not sell your personal information to third parties or share your personal information for cross-context behavioral advertising.
You can also opt-out of being tracked by these third parties by clicking “Do Not Sell My Personal Information” link at the bottom of our website and selecting your preferences, or by broadcasting the global privacy control (“GPC”) signal. Please note GPC signals are browser dependent and some browsers may not accept GPC signals unless a browser extension is used; please refer to your browser requirements to ensure you are transmitting the GPC signal accurately. Please note that your use of our website may still be tracked by eMoney and/or our service providers when necessary, such as to provide the website or security purposes.
We do not knowingly sell the personal information of consumers under 16 years of age.
Right to Limit
You have the right to direct us to limit the use and disclosure of your sensitive personal information. You may direct us to limit the use and disclosure of your Sensitive PI to uses/disclosures that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. To limit our use of your Sensitive PI, please click here.
Right to Non-Discrimination
You have the right to be free from discrimination for exercising any of the rights described above. The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. In addition, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may not be able to provide access to certain of our products and services to individuals who exercise these rights, or to otherwise engage with such individuals going forward.
To Exercise Your Right to Know, Delete, or Correct as a California Resident, please submit a request by:
We will need to verify your identity before processing your request. To verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know, right to deletion, and/or right to correct, particularly where we are unable to verify your identity.
You may designate an authorized agent to submit a request to know, delete, correct, request to opt-out of sale/share, and request to limit use of sensitive personal information on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; or (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
If you have been designated as an authorized agent to submit a request on behalf of another consumer, you must (1) download and complete this Authorized Agent Designation Form found here and have it signed by the consumer, and (2) attach the signed form when you submit a request to us at email@example.com.
We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the date at the beginning of these CA Disclosures to include the “Last Updated” date. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our Sites or Services (such as by placing a conspicuous announcement of the new CA Disclosures on the Sites or by presenting you with a web page containing an electronic copy of the new CA Disclosures), or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Your only remedy, if you do not accept the terms of these CA Disclosures.