Last Modified: 11/1/2022
For individuals residing in the United States, you may also refer to the Power U.S. Consumer Privacy Notice, below, which provides additional details about our collection, use, and sharing of your personal information in connection with the financial services that we provide to individuals, and associated rights you may have under federal law.
We are committed to being transparent about your personal information. Please read this Policy carefully to understand our policies and practices regarding your information. By interacting with our Services, you are consenting to the practices described in this Policy. This Policy may change from time to time (see “Changes to this Policy”). Your continued use of this Website or our other Services after we make changes is deemed acceptance of those changes, so please check this Policy periodically for updates.
This Policy Explains…
- How we collect personal information when you visit, use, or interact with us online, and through our ads displayed through online services operated by us or non-affiliated third-parties; and,
- How we may use or share personal information collected to deliver products and services to you and for advertising purposes.
Linking to other sites
We may provide links to third-party sites, such as service providers or merchants. If you follow links to sites not affiliated with or controlled by Power, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Services. Power does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.
Protecting your personal information
While no organization can guarantee perfect security, Power has implemented and continuously seeks to improve technical and organizational security measures to protect the information provided via the Services from loss, misuse, unauthorized access, disclosure, alteration, or destruction.
If you have created an account with us, you are responsible for keeping confidential any usernames and passwords you use to access our Services. Do not to share this password with anyone else and not to use this password for other services or products.
We also recognize the importance of protecting privacy where children are involved. Individuals under the age of 18 are not eligible for our Services. As such, our Services are not marketed to individuals under the age of 18, and we request that these individuals do not provide any information through our Services. We do not knowingly collect or solicit any information from children under 18. In the event that we learn that we have inadvertently collected personal information from a child under age 18, we will take reasonable steps to delete this information. If you believe that we might have any information from a child under 18, please contact us at [email protected].
Making Sure Personal Information is Accurate
Keeping your personal information accurate and up to date is very important. If your personal information is incomplete, inaccurate, or not current, please use the Contact Us option on our Services, or call us at the appropriate telephone number for changes listed on your account records or other account materials.
Personal Information We Collect
The categories of personal information we collect depend on how you interact with us and our Services, and the requirements of applicable law. As further described below, we collect information that you provide to us, or that we obtain automatically when you use our Services, and we may additionally obtain information about you from third parties. The personal information we collect is limited to what is required to provide our products or services and to support legal and risk requirements.
In addition to our banking partners and retail brands (collectively, our “Partners”), we also collaborate with third-party companies to perform certain business-related functions on Power’s behalf (our “Service Providers”), which may also collect personal information from or about you. For more information about our Service Providers, please see “How We Use and Share Your Information,” below.
How do we collect personal information online?
- Apply for or open a new account;
- Register for a new product or service, or request information about a product or service;
- Complete a survey, contest or sweepstakes or other promotion; and,
- Use aggregation services in order to consolidate your financial account or information at one online location.
- Visit or navigate our Website, or otherwise use our online Services.
Power and our Partners may engage with customers on social media platforms such as Facebook®, Twitter®, YouTube® and LinkedIn® and others.
Types of personal information we collect online
The type of personal information we collect from and about you online will depend on how you interact with us and may include:
- Contact Information such as name, mailing address, email address, telephone and mobile number(s).
- Account Application information such as credit and income information.
- Identifiers such as Social Security number, account number(s), driver’s license number (or comparable) or other information that identifies you for ordinary business purposes.
- Access Authorization such as user name, alias, PIN and Passcode and security questions and answers.
- Communications with Power. You may be able to contact us via a contact form, email, by chat services or by other means (for example, with questions about our Services, for customer support, or to let us know your ideas for new products or modifications to existing products). You may also choose to respond to surveys that we send out. When you contact us, we collect the information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message.
- Information from your computer and mobile devices, where allowed by individual browsers and/or operating systems, such as:
- Unique device identifiers (for example Media Access Control (“MAC”) and Internet Protocol (“IP”) addresses)
- Browser type, version, language, and display/screen settings;
- Information about how you use and interact with our Services (for example activities on pages visited, links clicked or unique and measurable patterns such as keystrokes, mouse clicks and movements, swipes and gestures);
- Responses to advertisements on the Services where we advertise;
- Log information such as your search and voice to text queries in the mobile app; and,
- Search engine referrals.
- Essential Cookies. Some Cookies are strictly necessary to make our Services available to you (“Essential Cookies”). We cannot provide our Services without these Essential Cookies.
To the extent we use Google or Facebook for advertising purposes on our Website, including remarketing features of those products, please see these links provided by these respective companies for opt-out purposes: Google / Facebook. We are not responsible regarding the scope of, or the honoring of, any such opt-outs, as opt-out preferences provided by these companies are not under our control.
Your Choices Regarding Cookies
You may stop or restrict the placement of some types of Cookies on your device or remove them by adjusting your preferences as your browser or device permits. You can also consult the “Help” section of your browser for more information (e.g. Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). However, please note that cookie-based opt-outs are typically not effective on mobile applications. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others. Please note that we do not recognize nor respond to browser-initiated Do-Not-Track (“DNT”) signals, which are a privacy preference that users can set in certain web browsers, because the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and developing a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
The online advertising industry additionally provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, the Your Ad Choices for App tool, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.
How We Use and Share Personal Information
How do we use your personal information?
Personal information collected from and about you online described in this Policy may be used for purposes including:
- Delivering products and services to you by consolidating your financial account information at one online location.
- Personalizing your digital and mobile experience by enhancing our Services organization and designing and analyzing data to create relevant alerts, products, or services.
- Providing advertising on our Services as well as non-affiliated third-party sites and through offline channels.
- Detecting and preventing fraud includingidentity theft and other risks to you or Power.
- Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view.
- Complying with and enforcing applicable legal requirements, industry standards, contractual obligations, and our policies.
- Allowing you to use features within our Services when you grant us access to personal information from your device such as contact lists.
- Loyalty and marketing of Power’s affiliates, partners, and subsidiaries products and services.
- Aggregated Data. We may aggregate, anonymize and/or de-identify information collected from or about you so that the information no longer identifies you (“Aggregated Data”).
With whom do we share your personal information?
We may share the personal information we collect from and about you online described in this Policy (and subject to other legal restrictions and notices you may have received depending on your relationship with us) as set forth below. Power does not sell your personal information.
- Affiliates, Partners and Subsidiaries of Power, such as Power’s issuing Bank Partners, in order to provide our Services. The purposes for which we may share information with these entities include providing you with customer support; administering funds; authenticating accounts; sending you informational communications; and conducting the other activities described in this Policy.
- Government Agencies as required by laws and regulations at Power’s determination.
- Successors-in-interest. We will share your information with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) and, in each case, any due diligence relating thereto.
- Pursuant to Legal Requirements. Power may disclose your information when we have a good faith belief that doing so is necessary to: (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to inquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organizations; (ii) protect and defend the legal rights, privacy, safety or property of Power, its affiliates, subsidiaries, employees, agents, contractors, or its users; (iii) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or any applicable Terms of Service.
In addition to the above, collected personal information may be aggregated and/or de-identified to remove any details that identify you personally. We may share this aggregated and/or de-identified information with third-party providers to help deliver products, services and content that are better tailored to the users of our online services and for our own business purposes where permissible under applicable laws and regulations.
Third-party Data Sharing
Some companies may offer aggregation websites and services that allow you to share your data with them in order to consolidate your account information from different sources so that you can view it in one location or perform actions related to your accounts using their services. To do this, a third party may request you to authorize access to your Power accounts by providing your Power username and passcode or by providing your information-sharing consent directly to Power. If you allow a third party to access your Power accounts, please remember:
- The third party may access, on your behalf, information about yourself, your Power relationship, and your accounts at Power.
- You should use caution and ensure that the third party has appropriate policies and practices to protect the privacy and security of any personal information you provide or to which they are gaining access.
- Use of your information by the third party is governed by your agreement with them, not by Power.
- We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your username and passcode.
- If you share your Power username and passcode or other information about your accounts with others, we will consider that you have authorized any transaction or action initiated by using the access information you provide.
- If you decide to revoke the authority you have given to a third party, we strongly recommend that you change your Power passcode to ensure that the third party cannot continue to access your account.
Bank Partnership Privacy Notice
When you sign up for an account with Power, we may collect and use your personal information on behalf of Power’s issuing Bank Partner to facilitate the provision of banking services pursuant to Power’s issuing Bank Partner’s Privacy Notice. The privacy practices of our Bank Partners are subject to their privacy notices, which we strongly suggest you review. Power is not responsible for our Bank Partners’ information practices or privacy notices.
Retention and Deletion of Information
We retain your information for as long as we deem necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, your information is only retained to the extent permitted or required by applicable laws. When we no longer need to retain your information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.
When determining the retention period for your information, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information about you, and mandatory retention periods provided by law and associated limitations periods.
Each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. In addition, if at any time you do not wish to receive future marketing communications, please contact us at the email address or postal address set forth under “Contacting Power,” below. If you opt out of receiving marketing communications, we may still send you informational emails about your account or any Services you have requested, used, or received.
Changes to this Policy
Power reserves the right to update or modify this Policy periodically and at any time. We will notify you of any material updates or changes we make to this Policy, including by posting an updated “Last Modified” date on this page. Please review this Policy periodically for any updates or changes. By using our Services and Services after any such update or modification, you acknowledge that you have read and understood the terms of the Policy as updated or modified. If you disagree with our revisions to the Policy, you can deactivate your account or otherwise discontinue the use of our Services.
Your access to and use of the Services is subject to Power’s Terms of Service and other terms that may be made available to you in connection with your use of the Services.
Please contact us if you have any questions about this Policy or Power’s information practices.
You can contact us as follows:
Power Finance Inc.
169 Madison Avenue #2159
New York, NY 10016
Power U.S. Consumer Privacy Notice