Vanify respects your privacy. While Vanify’s Services are designed for use by business customers, we process some personal data when you use our Services, including when you apply to open a Vanify Account. This Privacy Policy ("Policy") is meant to help you understand the types of Personal Information that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices and your privacy rights. Please read this Policy carefully, as it applies when you use our Services or Products, visit our Website, or use the Vanify mobile app.
If you have any questions about this policy or privacy at Vanify, please reach out to us at privacy@Vanify.com or via any of the other methods identified in the “How to Contact Us” section below.
I. Who We Are and Some Other Definitions
A. Vanify. This Policy applies to Vanify and its affiliates, including, without limitation (collectively, “Vanify”, “we”, “our”, and “us”).
B. Personal Information. “Personal Information” is any information that identifies, relates to, or reasonably could be linked to or associated with a particular person.
C. Services. “Services” means the financial products, technology, virtual account numbers, cash management, payment services, integrations with Third-Party Services, and all other services provided by Vanify, including those available through your Vanify Account).
II. What Personal Information We Collect About You and Where It Comes From
A. Information Vanify Collects from You
We collect and process Personal Information through our Services when you interact with Vanify. The data we collect from you varies depending on what specific Services you and your company use. In some cases you actively provide us with the information and in others, Vanify collects the information automatically. Vanify collects personal information from you when you directly interact with Vanify in the following ways:
Vanify may collect the following categories of Personal Information from you when you interact with or use our Services.
B. Information Vanify Collects from Other Sources
1. Personal information related to administrators, employees, company owners, and authorized persons or representatives
In some circumstances, Vanify requires our business customers and their representatives to provide us with Personal Information relating to another person (such as providing us with Personal Information about the owners of your business during the application process or providing us with Personal Information about employees). If you are providing Vanify with information about other individuals, do not provide us with any Personal Information unless you have informed these individuals that their information is being transferred to a third party for onboarding purposes or a similarly appropriate category of third party or you are sure the disclosure of the Personal Information is otherwise permitted by law or contract. You must inform all other persons whose information you share with us how we collect and process Personal Information and all other terms of this Policy.
III. How Vanify Processes and Stores Personal Information
A. How Vanify Processes Personal Information
Vanify processes Personal Information to provide its customers with a reliable and secure solution for virtual account numbers. That requires us to process Personal Information for a number of purposes, as described below:
In addition, we may work with agencies, advertisers, ad networks and other technology services to place advertisements on our behalf on other websites and services. For example, we may place ads through advertising and social media firms that you may view on their platforms as well as on other websites and services. As part of this process, we (or these third parties) may incorporate tracking technologies into our own Website and emails or other communications as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you ("Interest-based Advertising").
While you may disable some tracking technologies in your browser settings by blocking cookies in your browser, using global privacy controls, or using other privacy settings on your device or browser, you may still receive non-targeted advertisements we send as part of a general marketing campaign. For further information on the types of tracking technologies we use on the Services and your rights and choices regarding analytics and Interest-based Advertising, please see the "Information Vanify Collects from You" and "Your Rights and Choices" sections.
When complying with court orders and other similar legal processes, Vanify strives for transparency. We will make reasonable efforts to notify our customers and users of any disclosure of their Personal Information, unless we are prohibited by law or court order, or exigent circumstances prevent us from doing so.
B. Anonymized and aggregated data. To improve and market our Services, better target advertisements, and for other promotional purposes, Vanify may transform Personal Information into de-identified information removing or masking information that could be used to identify you and by aggregating or combining de-identified data with other information.
C. For EEA and UK residents: Legal basis for processing
The General Data Protection Regulation (GDPR) in Europe requires a "lawful basis" for processing personal data. Our lawful basis includes where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our Service Providers, partners, or business customers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
The legal basis for Vanify’s different Personal Information processes is as follows:
IV. How Vanify Discloses Personal Information to Other Parties
A. Vanify’s Disclosures of Personal Information to Third Parties
Vanify discloses Personal Information for several business purposes. Vanify discloses the following data categories for the following purposes:
B. Restrictions on Service Provider’s Use of Your Personal Information
Vanify may transfer your Personal Information to our Service Providers. Vanify contractually prohibits our Service Providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us and fulfilling their own regulatory and legal obligations, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for other purposes except as prohibited by applicable law or contractual obligation.
C. Transfers authorized by you, by the Vanify Account holder, or authorized representatives
Vanify enhances its Services by integrating with products and services provided by other companies. As identified section A above, Vanify currently has integrations that transfer Personal Information to provide accounting and ACH services. For these integrations to work, we may need to provide your Personal Information to these companies. Information we transfer to these companies will be used and disclosed according to that company’s privacy policy and subject to appropriate contracts with our partners. You should review the privacy policy of any company that has access to your Personal Information related to the integration with your Vanify Account.
D. Data transfers in corporate transactions
In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information and data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Vanify may continue to process Personal Information consistent with this Policy.
E. Compliance and compelled disclosures
We may disclose or transfer Personal Information in the following circumstances:
F. For California residents: No sale or sharing of Personal Information
Vanify does not sell or allow our Service Providers to process your Personal Information for their own use without your consent, unless the processing of that information is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, protect our property or operations, or enforce the rights and protect the property or operations of our business partners and customers. As part of our arrangements with Service Providers, Vanify may receive your Personal Information from and transfer your Personal Information to our Service Providers as part of providing our Services and Products, but these transfers are conducted under contracts that protect your data from additional uses and are not considered a sale pursuant to California law. Vanify also does not share Personal Information for cross-contextual behavioral advertising as defined in the California Privacy Rights Act.
Vanify has not sold or shared Personal Information for cross-context behavioral advertising for the last 12 months.
V. How Vanify stores and protects Personal Information
A. How long Vanify retains Personal Information and when we delete it
Vanify collects and retains Personal Information to provide our Services. We retain that information for as long as we have a business or operational reason to retain that information, or where we have a legal or regulatory obligation to continue to retain that Personal Information after it has served its business or operational purpose. Vanify deletes or de-identifies Personal Information when we no longer are required to or have a reasonable business purpose to retain it.
Vanify’s legal retention obligations may require us to retain your Personal Information after you are no longer an authorized user of a Vanify account or after your Vanify account has closed. These retention obligations also prohibit us in some cases from deleting certain Personal Information after you have asked us to delete your data under the data privacy and data rights laws in different jurisdictions. Vanify retains data where it is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements or where deleting it prevents us from billing for our Services, calculating taxes, conducting required audits, or carrying out other legitimate business functions.
Please see the “Your Rights and Choices” section and the sections detailing the rights you may have under the laws of your location below for more information.
B. Where Vanify stores Personal Information and international data transfers
As we strive to serve our customers everywhere in the world they operate, Vanify may process and store Personal Information for the purposes described in this Policy in the United States or any other country in which Vanify, its subsidiaries, affiliates, or Service Providers operate. These countries may have data privacy or protection laws that are different to the laws of your country and may not be as protective. Vanify takes measures to comply with applicable data privacy laws when we transfer Personal Information internationally.
For Personal Information transferred from Europe or the United Kingdom, we will provide appropriate safeguards, such as use of the Standard Contractual Clauses approved by the European Commission, to protect your Personal Information.
C. Vanify’s data security
Vanify uses organizational, technical, and administrative measures to protect Personal Information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. The specific measures we use include encrypting your Personal Information in transit and at rest, device and identity verification processes, and idle lockouts.
Where you have created a username and unique password to enable you to access your Vanify Account, or use our Services, it is your responsibility to keep this password secure and confidential.
Please contact us as set out in the "How to Contact Us" section below immediately if you believe that your Personal Information or any other confidential information that you have provided to us is no longer secure or has been lost or stolen.
VI. Additional Important Information About Your Personal Information
A. Vanify Account users and administrators’ access and authorities
Vanify Services are intended for use only by companies, and you may only use a Vanify Account or Card if you are an employee or other authorized representative of a company that has opened a Vanify Account. The information in your Vanify Account is governed by our agreements with the applicable business customer. You may access, update, or delete certain information within your Vanify Account through the Platform, provided that the business customer’s administrator is responsible for determining how that data is processed. The business customer's administrator is responsible for your Vanify Account associated with the business customer. The administrator can also access information about you via their own access to Vanify’s Services, access and retain information we have stored on its behalf, and limit your ability to edit, modify, delete, or use information associated with your use of the Services.
However, losing authorized access to a company’s Vanify Account does not deprive you of rights you may have under the data privacy or other data rights laws in your jurisdiction. Please see the “Your Rights and Choices” section and the sections detailing the rights you may have under the laws of your location below for more information.
B. Closure of a Vanify Account
Closure or deletion of your company’s Vanify Account will mean that the business customer will permanently lose access to the Personal Information and data associated with the Vanify Account. Personal information or de-identified information associated with your company’s Vanify Account may nonetheless remain on systems owned or maintained by Vanify where required to comply with the law, our contractual obligations, or carrying out legitimate business functions.
Where Vanify retains Personal Information after an account has closed, individuals may have the right to access, delete, or assert other rights under the laws of their jurisdiction.
C. For EEA and UK residents: Vanify’s role as a data controller and processor
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors"). Vanify acts as a controller with respect to personal data collected as you interact with and use our Services. For the Products, Vanify acts as a processor when we act on the instructions of or on behalf of a business customer, and as a controller when Vanify is deciding how to process your data directly. For example, when your data is being processed for your business’s financial planning, Vanify is acting as a processor, but when Vanify is processing data to comply with its regulatory obligations, like the requirements to detect and prevent financial crime, it is acting as a controller. This Policy describes the processing undertaken by Vanify as a controller.
Where Vanify is a controller you can contact us using the details in the "How to Contact Us" section. Any questions that you have relating to the processing of personal data by Vanify as a processor should be directed to the relevant business customer.
VII. Your Rights and Choices
A. Your Choices with Vanify
1. Electronic Communications
Please note that your opt out is limited to the email address or phone number used and will not affect subsequent subscriptions.
2. California Resident Rights and Choices
If you are a California resident, you have certain rights over the information that we have about you. You can:
Vanify will not discriminate against you for any use of your privacy rights.
To exercise any of these rights, you may make a request by emailing us at privacy@Vanify.com. Vanify will confirm receipt of your request and provide you with information about our processes for acting on your request, including when you can expect a response, within 10 business days. We will need to verify your identity to ensure the security of your Personal Information before providing you with any Personal Information.
If you are currently a Vanify user, you may correct any Personal Information we have about you either in your settings, by contacting your Vanify Account administrator.
3. European and United Kingdom Rights
You have the following rights regarding the Personal Information we collect and use about you:
To exercise any of these rights, please contact us at privacy@Vanify.com. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.
If Personal Information about you has been processed by us as a processor on behalf of a business customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of the customer on whose behalf we processed your personal data. We will refer your request to that third party, and will support them to the extent required by applicable law in responding to your request. Read more about how Vanify operates as both a controller and processor in the section "Vanify’s role as a data controller and processor" above.
Please note that we retain information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use your Personal Information, even after a data subject request, for purposes of our legitimate interests and to comply with our legal obligations, including where needed to resolve disputes, prevent fraud and financial crime, and enforce our agreements as well as to comply with statutory retention obligations.
4. Residents of other locations
If you reside in a US state or territory other than California or anywhere else in the world other than the European Economic Area or United Kingdom and would like more information about how Vanify processes your Personal Information or have questions about your rights under this Policy, please submit your request to privacy@Vanify.com.
B. Your Choices with Google Analytics and Interest-Based Advertising Providers
1. Google Analytics
Vanify uses Google Analytics to better understand how users interact with our websites and advertising. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.
2. Interest-Based Advertising
The companies we work with to provide you with targeted ads in connection with the Services are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance ("DAA") and/or the Network Advertising Initiative ("NAI"). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants' other customers or from other technology services).
Please note that if you opt out using any of the methods described for Google Analytics, DAA,or NAI, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities' statements regarding their opt out options or programs.
VIII. Updates to This Policy
We may update this Policy from time to time in response to changing legal, regulatory, technical or business developments. When we update this Policy, we will notify you of material changes, changes that limit any of the rights you have related to the manner in which we process your Personal Information, or that we are required to disclose by law, via a prominent notice on our website, login screen, your mobile app, or via email at least 30 days prior to the changes taking effect. We will obtain your consent to any material changes to this Policy if, and where, required by applicable data protection laws.
You can see when this Policy was last updated by checking the “Revised” date displayed at the top of this Privacy Notice.
IX. How to Contact Us
If you have concerns, questions, or would like to better understand our privacy practices at Vanify, please contact us using the following details:
By email: privacy@Vanify.com
By mail:
Vanify
Attn: Legal
4550 New Linden Hill Road,
Wilmington, DE - 19707
USA
By phone to our Customer Experience team: +1 919 341 9393
X. Previous Privacy Policies
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