08.01.06 – Disclosure of Information

We may disclose any information we collect about current and former customers, including non-public personal data, to affiliates and non-affiliated third parties as follows:

With financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your XXX account.

With another user, when you sign up for XXX’s services via a referral link. The user that referred you may receive information indicating that you have enrolled with XXX. You may avoid this sharing by not using a referral link to enrol.

With non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to XXX and other companies.

With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy.

With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:

  • In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.
  • With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
  • If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of XXX or others.
  • In connection with, or during negotiations of, any merger, sale of XXX’s assets, financing or acquisition of all or a portion of our business to another company; and
  • With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.

We will usually not share your personal data with other third parties without your consent. Where we need to transfer your data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.