Last Updated: May 27, 2021
Propel U.S. Consumer Privacy Notice
|FACTS||WHAT DOES PROPEL 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:|
|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 reason Propel chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Propel 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
|For our marketing purposes –|
to offer our products and services to you
|For joint marketing with other financial companies||No||We don’t share|
|For our affiliates’ everyday business purposes –|
information about your transactions and experiences
|No||We don’t share|
|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|
|Questions?||Email us at email@example.com|
|Who we are|
|Who is providing this notice?||Propel, Inc.|
|What we do|
|How does Propel protect my personal information?||To protect your personal information from unauthorized access and use, we use reasonable security measures that comply with industry standards. These measures include computer safeguards and secured files and buildings.|
|How does Propel collect my personal information?||We collect your personal information, for example, when you:|
|Why can’t I limit all sharing?||Federal law gives you the right to limit only:|
|What happens when I limit sharing for an account I hold jointly with someone else?||Your choices will apply to everyone on your account.|
|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|
|For California and Vermont residents: We will not share information we collect about you with affiliates or non-affiliates, except as permitted by your state’s law.|
Types of Personal Information We Collect and How We Collect It:
Personal Information That You Provide
We may collect the following personal information you provide when you use our Services, like when you sign up for an account, enroll in a program, apply for employment, or otherwise engage or communicate with us:
- Identity Data, such as your full name, date of birth, gender, social security number, household size, similar other data. We use this information to facilitate the creation of your account, and to assist in linking your account to your EBT processor portal(s). We do not store your SSN on our systems. Instead, this data is transmitted through our server to create an account for you on your EBT processor portal(s).
- Contact Data, including your email address, and ZIP code.
- Financial Data, including as relates to your EBT account(s) and EBT card details, and your EBT financial transaction history. The information we collect regarding your EBT account(s) is limited to what is displayed when you log into your EBT portal(s). We do not store the credentials necessary to log into your state’s EBT portal. Instead, those credentials are stored locally on your device and encrypted.
- Account Data, for both your Providers account and any EBT accounts that you chose to link to your Providers account, including your account username and password, the type(s) of government-administered benefits that you receive, and your interests. We use this information to facilitate linking your EBT account, and for account security purposes. While we integrate with EBT processor portal(s) that you link to your account with us, we cannot view and do not store your account credentials for those portals. Instead, any such information is stored locally on your device.
- Usage Information, including information about how you access and use our Services, such as your interactions with linked EBT accounts.
- Additional Information that you provide to us, such as through job applications, customer support inquiries, blog posts, and similar interactions with us. We may also collect any communications between Propel and you, including through recording phone calls made to or by Propel, and any other information that you provide to Propel.
Personal Information That We Collect When You Use Optional Products, Services, or Features
We additionally collect personal information that you provide when you choose to use optional functions, features, or products related to of our Services:
- If you agree to participate in our Beta Testing Program, you may be required to provide us with additional personal information or account login information so that we can test features and improve functionalities. We take reasonable and appropriate measures to store your information in a secure manner.
- If you activate any digital coupons offered through our Services, you may be required to provide us with a retailer loyalty account number. We collect and store this information to operate the coupons feature.
- If you have granted us permission, we may collect location information from your mobile device. We use this data for the purposes of providing you with certain features, such as a map of nearby SNAP-authorized retailers. We only collect this information if you authorize us to do so, and it is not necessary in order to use the majority of our Services.
Personal Information Collected Automatically
We additionally obtain certain personal information automatically when you visit our Website or otherwise use or Services, such as your IP address, MAC address, Device ID, and mobile application use information such as content views, interactions, and the amount of time spent in the application.
We use this information to analyze and improve our Services and content. In addition, our servers may keep log files that record data each time a device accesses our Website or Services. The log files may contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Websites or Services, or the pages you’ve clicked on while on our Websites or Services).
Propel uses “cookies” and similar technologies, such as pixel tags, to automatically collect these types of personal information, and to track your use of the Website and our other Services. These technologies, which are described below, collect information in relation to your experience on our Website and Services, such as pages clicked, navigation path, bounce rates, actions taken, and other metrics.
What Are Cookies? Cookies are small files that are stored within your browser and store data in relation to your visit to our Website or Services. Cookies serve a variety of purposes, such as securely maintaining your authenticated session and preferences (e.g., remembering log-in details or other settings), understanding your use of the Website or Services, and servings ads (whether our own ads on third-party websites or services or others’ ads on our Website or Services) based on your interests or actions. Each cookie typically has a pseudonymous ID associated with them (a set of randomized characters, typically alphanumeric) and may also store information related to your device or browser, such as IP address, browser and Operating System type, device type, etc.
Our Use of Tracking and Analytics Technologies
We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Services over time through cookies, pixel tags, and related technologies. We use the below analytics providers, which allow us to better understand how our users interact with our Services, and allow us to better tailor our content to you. We do not control the privacy practices of these third parties and cannot be held responsible for them (e.g., if they fail to comply with opt-out requests).
Firebase Analytics. We use the development platform Google Firebase and its related functionalities to help us gather information on user interactions with our Services. For further information on how Google uses data for marketing purposes, please visit https://www.google.com/policies/ technologies/ads.
AppsFlyer. We analyze the use of our mobile application via AppsFlyer. We use this information to improve our content, and to make our Services more relevant and accessible. For further information about data processing at AppsFlyer, please see their data protection statement here: https://www.appsflyer.com/privacy-policy/.
Amplitude. We also use Amplitude, a tool which provides product analytics for our mobile application. Amplitude helps us understand how you use our mobile application so we can improve the experience. Additional information about the manner in which Amplitude processes data is available at: https://amplitude.com/privacy.
Facebook SDK. We have integrated the Facebook SDK into our mobile application, which allows us to link certain services provided by Facebook with our own mobile application for marketing purposes. For further information on Facebook SDK on iOS please visit: https://developers.facebook.com/docs/ios. For Android devices, please visit: https://developers.facebook.com/docs/android.
Your Choices Regarding Tracking Technologies
Most Internet browsers are set up to accept cookies and pixel tags automatically. You can set your browser to notify you when a cookie is set to your device, allowing you to decide whether or not to accept those cookies, block all third-party cookies (cookies dropped by third-party vendors), or all cookies generally (both Propel’s and third-party vendors’ cookies). Users choosing not to accept any cookies or similar technologies may not be able to take full advantage of the Website or Services. If you use a different device or change browsers, you may need to perform the opt-out task again. Propel does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
On your mobile device, you may be able to limit certain interest-based mobile advertising through settings on your device, such as resetting your ID for Advertising for iOS (IDFA), Google Advertising ID, and similar mobile identifiers. Please refer to specific guidance from your device manufacturer and/or operating system for details.
How We Use Your Personal Information
We use the information discussed above in a number of ways, such as:
- Verifying your identity, such as when you access your account information;
- Managing your preferences;
- Preventing fraud and enhancing the security of your account and our Services;
- Responding to your requests and communicating with you;
- Providing you with our Services, and tailoring content to your location and interests;
- Performing analytics concerning your use of our Services, including your responses to our emails, and the pages or application content that you view;
- Complying with and enforcing applicable legal requirements, industry standards, contractual obligations, and our other policies;
- Monitoring and troubleshooting errors and incidents on our Website and other Services, analyzing web traffic, and optimizing user experience;
- Operating, evaluating, and improving our business, including developing new products and services, improving our existing Services, performing data analytics, and performing accounting, auditing, and other internal functions; and,
- For any other purpose that we may specifically disclose at the time that you provide or we collect your information.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify you) for various business purposes, where permissible under applicable laws and regulations.
How We Share Your Personal Information
We may share some or all of the personal information that you provide to one or more of our service providers, professional agencies, vendors, law enforcement, card networks, payment processors and others as necessary for:
- Providing our Services to you, such as by transmitting your personal information to any EBT processor portal(s) that you have linked to your account;
- Providing our customer support functions;
- Assisting in delivery of physical and electronic communications to you;
- Other business purposes, such as the administration of our Website and our other Services, compliance with audits, for tax purposes, as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Propel;
- Responding to requests by law enforcement, regulators, and other government bodies; and,
- Any other purpose as permitted by law.
If you have a Providers Debit Card, we may share your personal information as necessary to provision access to your Providers debit account, and to effectuate the processing of payments. For more information, please visit: https://www.joinproviders.com/providers-card/privacy.
We additionally may share your IP address with our partner organizations, and may also share data that we collect from or about you on an aggregate or anonymous basis (such that it does not identify you) for various business purposes, where permissible under applicable laws and regulations. Propel does not sell your personal information to any third party, but we may provide certain of your personal information to third parties to facilitate account creation, identity and benefits verification, or similar purposes.
Propel may contact you from time to time with information concerning new products or services. You can manage your receipt of marketing communications by clicking on the “Unsubscribe” (or similar) link located on the Propel of an applicable Propel marketing email and following the instructions found on any page to which the link may take you. Note, however, that you cannot opt-out of transactional or administrative emails.
We use reasonable physical, electronic, and procedural safeguards that comply with federal standards to protect and limit access to personal information. This includes device safeguards and secured files and buildings. In addition, we have built many of our Services to function without saving sensitive personal information to our servers, such as your EBT card number or PIN. However, no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be completely secure.
Propel retains your personal information for as long as it is deemed necessary and relevant by Propel for Propel’s operations, unless a longer or different retention period is required or permitted by law.
We do not knowingly collect or solicit any information from anyone under the age of 13 in providing our Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
If you have questions or concerns regarding this statement, or if you have any questions or suggestions, please contact email@example.com.