Last updated: September 14, 2022
1.0 About DailyPay. DailyPay is the leading fintech provider that enables employees to harness the power of their pay and provides innovative financial products and solutions to consumers.
2.0 Information Collected. We receive and/or collect personal information from or about you in the following ways (we also provide examples of how we may use the data):
2.1 We collect personal information directly from you, your bank, and your employer in order to provide our Services to you. The personal information categories may include: identifiers; employment or financial-related information, such as salary, bank account or employment status details; and geolocation data, internet, or network activity (for security purposes). The purpose for processing each is included below.
2.2 Account. In order to utilize our Services, you are required to create an account (“Account”). We may offer different options to create an Account, including:
- Online Registration Form: You may choose to complete and submit an online registration form. As part of the registration process, you may be asked to provide us with an email and mailing address, mobile phone number, date of birth, proof of identity documentation, and a password that you will use to access your Account, as well as other information that may be required to open your Account.
Regardless of which method you choose to register your Account, we may send an email or text message to your nominated email address, mobile phone number, or to the email address that you have designated in your Third Party Account to instruct you how to confirm your registration.
2.3 Contact Us Information. If you send us a ‘Contact Us’ request, whether by calling our customer service number, or submitting an online form, direct email to a DailyPay email address, or text message to our company number that we make available on the website, you may be required to provide us with certain information such as your name, phone number, and email address.
2.4 Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer our Services, track users’ movement around our Services, and gather demographic information.
2.5 Cookies and Other Tracking Technologies. Our website and mobile app may utilize cookies and other tracking technologies in order for us to provide our Services, and to advertise our Services. A cookie is a small text file that may be used, for example, to collect information about website and Service activity. Certain cookies and other technologies may serve to recall information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
2.6 Data Providers We may obtain information about you, such as mailing address, gender, age, marital status, ethnicity, and information about your home and automobile from third-party data providers. We may use this information for marketing purposes and research purposes.
- Marketing. We may use this info to market our products and services to you.
- Research. We may use this info to provide aggregated, anonymized insights to third party entities for the purpose of determining the impact of Services on user financial wellness.
3.0 Use of Personal Information. If you submit or we collect personal information through the Services, then such personal information may be used by us in the following ways:
3.1 We may use your personal information to provide and improve our Services, create insights about our users, to contact you in connection with the Services and certain programs, features or offerings that you may have registered for, to advertise our Services, and to identify and authenticate your access to the parts of the Services that you are authorized to access.
3.2. We may use your designated email address or mobile phone number to: (i) send you updates or news regarding the Services; and/or (ii) respond to a Contact Us or administrative request (for example, to change your password).
3.3 We may transfer your personal information to our subsidiaries, affiliates, or vendors in order to provide our Services.
3.4 We may share your name and contact information with other companies that offer products or services that may be of interest to you.
3.5 We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt out of our marketing communications as described in the Opting Out section below.
3.5 We may disclose your personal information if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) to administer our Services; (ii) comply with any applicable law, regulation, legal process or governmental request; (iii) enforce our Terms, including investigations of potential violations thereof; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to the rights, property or safety of DailyPay, our users, yourself or the public.
4.0 Use of Anonymous Information. We may create anonymous data from personal information by excluding information that makes the data personally identifiable, and use that anonymous data for our lawful business purposes, including to provide workforce insights to our employer partners.
5.0 Opting In and Opting Out. You may choose to receive promotional and advertising text messages from us by providing us with your written consent directly or through your employer. You may choose not to receive future promotional or advertising emails or text messages from us by selecting an unsubscribe link at the bottom of such emails or by texting STOP to opt out of such text messages. You also control your notifications in your account settings. If you opt out of receiving the foregoing emails or text messages, we may still send you a response to any Contact Us request as well as administrative emails necessary to facilitate your use of our Services (for example, in connection with a password reset request, an email/text message verification, or a payment-related email/text message).
6.0 Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
7.0 Online Tracking Opt-Out. There are a number of ways to opt out of having your online activity and device data collected:
7.1 Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
7.2 Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
7.3 Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
7.4 Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
- Google: https://adssettings.google.com
- Hotjar: https://www.hotjar.com/legal/compliance/opt-out/
- Twitter: https://twitter.com/settings/account/personalization?lang=en
- Sailthru: https://getstarted.sailthru.com/audience/managing-users/user-optout-levels/#Opt-out_Management
7.5 Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance: http://optout.aboutads.info
- Network Advertising Initiative: http://optout.networkadvertising.org
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
8.0 Access/Accuracy. To the extent that you do provide us with personal information, we wish to maintain accurate personal information. You may use the tools that we make available on our Services to remove or modify certain information in your Account.
10.0 Children’s Privacy. Our Services are not structured to attract children under the age of 13 years. Accordingly, we do not intend to collect personal information from anyone we know to be under 13 years. If we learn that we have collected personal information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us.
11.0 Record Retention. We retain personal information as long as reasonably necessary to achieve the collection and use purposes disclosed in this Policy. The criteria determining retention period are based on legal obligations and information sensitivity, security, product research and development, technical functionality, and experience improvement considerations. We specifically retain personal information:
- to respond to or comply with court orders, subpoenas, or regulator inquiries;
- as required by applicable state and federal law or regulation, including the Gramm-Leach-Bliley Act, the Electronic Fund Transfer Act, the Telephone Consumer Protection Act, and the Bank Secrecy Act; and
- in response to or anticipation of litigation.
12.0 Security. The security of personal information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the personal information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security or confidentiality.
13.0 Corporate Structural Event. In the event of our acquisition, merger, restructuring, bankruptcy, or comparable event, we reserve the right to transfer or assign personal information in connection with the foregoing events.
16.0 Notice to California Consumers. The California Consumer Privacy Act (“CCPA”) requires us to provide this supplemental privacy notice to our consumers in California. The CCPA provides rights to California residents. California defines residency as (1) every individual who is in the State for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State, but outside the State for a temporary or transitory purpose. All other individuals are nonresidents to whom the CCPA is inapplicable.
16.1 CCPA Notice Scope. This CCPA Notice and the rights it sets out do not apply to the personal information we collect, use or disclose about:
- Consumers who initiate or complete the process of onboarding to our Services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“FIPA”). This means that if you have initiated or completed an application for a DailyPay account, this CCPA notice and the rights it sets out do not apply to you.
- Representatives of businesses that seek to obtain our products or services, or to provide products or services to DailyPay.
If your engagement with DailyPay has been limited to visiting our website or communicating with us, this CCPA Notice applies to you because your information is not subject to the GLBA.
16.2 For the California residents to whom this CCPA notice does apply, the CCPA grants the following rights.
- Access. You can request a copy of the personal information that we maintain about you.
- Deletion. You can ask to delete the personal information that we maintain about you.
- Correction. In addition to the capability to correct inaccurate personal information identified in “Access/Accuracy” above (8.0), DailyPay will assist your employer or in our own discretion, directly correct valid requests to correct inaccurate personal information, to the extent doing so is neither impossible nor requires disproportionate efforts.
- Opt out of sale of your personal information. You can opt-out using the instructions below.
Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.
16.3 Here is how you can submit requests:
- To request access to or deletion of personal information collected via the Services, please email us at firstname.lastname@example.org or call us at tel: 1-855-481-3596.
- To opt out of sale of personal information, email us at email@example.com. or visit the Do Not Sell My Personal Information link on our website. Furthermore, we offer instructions on how to limit online tracking in the “Online Tracking Opt-Out” section above.
- To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
- Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf.
You are entitled to exercise these rights free from discrimination.