This policy is effective as of 22 April 2021
Last updated: 22 April 2021
This policy is effective as of 22 April 2021
Zenda Financial (“Zenda”, “we”, “us”) respects your privacy and takes our responsibility to safeguard your personal information seriously.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service.
1. Personal Information We Collect
1.1 Information Collected Voluntarily
1.2 Information Collected Automatically
1.3 Permission from Devices
1.6 Log Data
1.7 User-Provided Content
1.9 Third Party Analytics
1.11 Information Collected from Third Parties
1.12 Banks and Financial Institutions
2. Processing Personal Information
2.1 Use of Personal Information
3. How Zenda Shares Your Personal Information
3.3 Third Party Services
4. Other Disclosures
4.1 No Sales
4.2 How Long We Keep Your Personal Information
4.3 Children’s Privacy
4.4 Users Outside the United States
5. Your Rights and Controlling Your Personal Information
5.1 Marketing Permission
5.3 Right to Deletion
5.4 Right to Non-Discrimination
5.6 Security of Your Personal Information
5.7 Notification of Data Breaches
5.8 Limits of Our Policy
5.9 Changes to This Policy
5.10 Additional Disclosures for California Compliance
5.11 California Notice of Collection
Zenda collects information about you to provide you with the Services. Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information. “Voluntarily provided” information refers to any information you knowingly and actively provide us when using our App and its associated Services. “Automatically collected” information refers to any information automatically sent by your devices while accessing our App and its associated Services.
We may ask for personal information — for example, when you create for an account (“Account”), submit content to us or when you contact us — which may include one or more of the following:
- Date of birth
- Phone/mobile number
- Home/mailing address
- Social Security Number or Tax Identification Number
- Personal Bank Account Information
- Beneficiary information
- Dependent information
- Authorized user information
- Health Plan information
- Transactions with us such as contributions, withdrawals, payments and fees
- Receipts, photographs or other documentation which may contain PHI
- If you participate in surveys, or App questionnaires, we may collect additional information
Some data collected voluntarily is required to operate the Service. If you do not wish to provide required information, you may not be able to make use of the Service.
Information collected by the Service , which may be hosted by a third party, collect information via your device’s in-built tools, such as:
- Browser type
- OS Versions
- IP Address
- Your phone number
- Unique Device ID number
- Location data, GPS
- Storage, photos and/or media
- Background data refresh
Biometric data is not collected by the App, rather, by the OS manufacturer and is provisioned to us to assist in automatic logins. We neither collect nor retain any biometric
When you install the app or use your device’s tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app. Some features may be disabled if you do not grant permission for some data collection.
We use web beacons (“Beacons”) or pixel tags to collect information. Beacons are placed on website and applications and are used to track online movements and information. Beacons also allow us to send email in an optimized format for best user experience, and tell us whether emails have been opened. This information is collected to help us improve the Services and make them more useful to you.
When you access our servers via our Service, we may automatically log the standard data provided by your device. It may include your device’s Internet Protocol (IP) address, your device type and version, your activity within the Service, time and date, and other details about your usage.
Additionally, when you encounter certain errors while using the Service, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
We consider “user-generated content” to be materials (text, image and/or video content) voluntarily supplied to us by our users. We will not post or in any other way make public the information that is provided to us via the Services. We may use third parties to process and enhance this content, only for the operation of the Service.
In some instances your account may be established by your employer, health plan or other third party providing services to your employer. To enable the Services on your behalf, they may provide information that assists us to establish the accounts in a lawful manner. Further, these third parties may make available a website that allows you to access your Zenda account with or without logging in. When you access those sites, you are authorizing Zenda to pass this information, such as balances, to those systems.
In the establishment and ongoing maintenance of your Account, we receive information from banking and financial partners related to your account to provide the Services. You may receive separate terms and conditions from financial partners which will further describe their processing of your personal information. As part of the Service, you may receive a debit card to facilitate purchases from your Account. In this case, information will be shared between the financial institution, the card issuer, the payment processor, and us to provision of the Service. If you establish an investment account through the Services, we will transmit and receive information with the investment institution to provide you with the Service.
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to verify your identity, open and administer Accounts and provide services under the USA PATRIOT Act
- to provide you with our Services
- to enable you to customize or personalize your experience of our Services
- to link accounts and facilitate movement of funds for savings, payment and investments as directed by you
- to contact and communicate with you about your Account and the Services
- to help protect you and us from financial loss
- to prepare statements and annual tax statements, if applicable
- for internal record keeping and administrative purposes
- to comply with our legal obligations and resolve any disputes that we may have
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources.
We may share your Personal Information with third-party service providers for the purpose of enabling them to provide the Services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, marketing providers, professional advisors, and payment systems operators. These service providers are required to use your Personal Information solely to provide services requested by Zenda.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes.
Zenda Financial, Inc.
455B Portage Avenue
Palo Alto, CA 94306
You may access your Account through the App and update your personal information. For Personal Information cannot be changed via the App you may contact us at email@example.com. We will use commercially reasonable efforts to accommodate your request.
You may request deletion of your Personal Information. We may retain an copy of your records as required by law, to continue to provide you with the Services, or for other legitimate business purposes. If you choose to delete all of your Personal Information, then your Account may become deactivated.
We have policies and procedures to keep your Personal Information confidential and secure. We restrict access to those employees and other persons who must use that information to provide services on our behalf. We maintain physical, electronic, and procedural safeguards, in compliance with applicable laws, regulations, and industry standards, to protect the confidentiality of the Personal Information we obtain. We require our service providers to maintain the same level of confidentiality and security that we do. We continually update and improve our security standards and procedures to help protect against anyone gaining unauthorized access to your Personal Information and to prevent fraud.
We will comply with laws applicable to us in respect of any data breach. If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details above and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
If the changes are material, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) with the new details and links to the updated or changed policy. These changes will be effective immediately for new users of our Service, and details about when the changes take effect for existing users will be included in the communication about the changes. Continued use of our Site or Service following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Under California Civil Code Section 1798.83, if you live in California you may ask us about the information we release to other organizations for their direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year.
In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:
- Customer records, such as billing and shipping address, and credit or debit card data.
- Commercial information, such as products or services history and purchases.
- Audio or visual data, such as photos or videos you share with us or post on the service.
- Geolocation data.
- Employment and education data, such as data you provide when you apply for a job with us.
For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.