Privacy Policy - Daylight - Banking for LGBT+ people, by LGBT+ people

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Privacy Policy

Welcome to Daylight. We’re the first and only digital banking platform in the U.S. specifically designed for the LGBT+ community by the LGBT+ community. We’re based in Los Angeles, but operate across the United States. As a digital banking platform and provider of various banking services to monitor individuals’ banking, and related financial transactions in order to provide useful guidance, financial advice and management tools (the “Services”), we receive and process personal data of individuals. As we value your privacy, we have instituted a comprehensive data protection compliance framework in order to fulfil our responsibilities to protect your personal data. Therefore, this general online privacy policy (the “Privacy Policy”) is intended to inform you about our practices regarding the collection and use of your personal data that you may submit to us through our website www.joindaylight.com (the  “Website”).

Be Money Inc., 8335 Sunset Boulevard, West Hollywood, CA 90069, also known as (a.k.a.) Daylight (“Daylight” or “we”, “us” or “our”) is committed to protecting the privacy of individuals who use our Services and visit our Website.

Your privacy is very important to us. We conduct regular assessment reviews to ensure personal data we use, share and collect is protected. This Privacy Policy should be read alongside, and in addition to the Terms & Conditions. Please read the Privacy Policy carefully! 

By using the Website, you agree to the terms and conditions described in this Privacy Policy. If you visit or access your account from our Website, please review the privacy practices to understand how your online personal data may be collected, used and shared.

This Privacy Policy explains:

  • How we collect personal data when you visit, use or interact with us online;
  • How we may use or share personal data collected to deliver products and Services to you and for advertising purposes; and
  • How we protect the personal data you shared with us.

1. Updates to this Privacy Policy

This Privacy Policy is subject to change. Please review it periodically. If we make changes to this Privacy Policy, we will revise the Last updated date on this page. This Privacy Policy was updated on: November 12, 2020

2. Our Online Privacy Practices

We are committed to transparency about your personal data. We ask for your consent when required, otherwise by using our Website, you consent to the collection, use and sharing of your personal data subject to and consistent with applicable laws and other notices you may have received based on your relationship with us.

3. Protecting your personal data

To protect personal data from unauthorized access and use, we use security measures that comply with applicable federal and state laws. In the event of a data breach, we provide timely notification, in accordance with applicable laws. Our Website has appropriate, industry-standard security measures and technologies in place to help protect against the unauthorized access to, or unauthorized alteration, loss, misuse, or disclosure of your personal data processed under this Privacy Policy. 

4. Children’s policy

We also recognize the importance of protecting privacy where children are involved. Our Website is not directed to individuals under the age of 13 (or other under applicable law), and we request that these individuals do not provide personal data through our Website. We do not knowingly collect personal data from children under 13 (or other under applicable law). If it comes to our attention that we have collected personal data from such a person, we will delete or suppress this information as quickly as possible.

5. Making sure personal data is accurate

Keeping your personal data accurate and up to date is very important. If your personal data is incomplete, inaccurate or not current, please use the Contact Us option on our Website, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials.

6. Types of personal data we collect

We collect personal data about you through your computer, smartphone, tablet or other mobile device by the use of cookies and similar tracking technologies (see our Cookies Policy for more details) as well as personal data you provide when you visit or use our Website, for example when you:

  • Register for new products or Services, or request information about a product or Services through a “Join Daylight” section of our Website; 
  • Complete a survey, forms, or certain promotion displayed at our Website; 
  • Correspond with us by telephone, email, chat, social media or otherwise; or
  • Visit our Website and access our Services.

We may use external service providers and vendors to process personal data for business purposes on our behalf. External service providers and vendors are contractually obligated to comply with our policies to protect information we share with them or they collect on our behalf.

The personal data we collect is limited to what is required to provide our products or Services and to support legal and risk requirements.

The type of personal data we collect from and about you online will depend on how you interact with us and may include:

  • Personally Identifiable Information (the “PII”) is information that can be used to identify or contact an individual, including but not limited to your name, mailing address, e-mail address, telephone number, or other information that identifies you for ordinary business purposes. We collect, receive and store PII when you sign up or register for any of our Services through a “Join Daylight” section, or when you complete a survey, form or other questionnaire displayed on our Website, or when you otherwise correspond with us or directly provide such information to us.
  • Personal Non-Identifying Data is information about you and your characteristics, activities or behavior which cannot be used to identify or contact you or which has been stripped of any PII. This type of information includes for example your gender, city or state of residence, age, industry, financial profile and information, demographic profile and other non-identifying characteristics. We may collect, receive and store such information when you directly provide it to us through the Services, when you give us access to such information retained in your computer or accounts or when we collect such information from available public and third-party sources.
  • Information from your computer, smartphone, tablet or other mobile device, such as (i) Unique device identifiers (for example Media Access Control (MAC) and Internet Protocol (IP) addresses), (ii) Browser type, version, language, and display/screen settings, (iii) Information about how you use and interact with our Website (for example page visited, links clicked), (iv) Responses to advertisements on the Website where we advertise, and (v) Social media preference.
  • Cookies and similar tracking technologies (please see our Cookies Policy).
  • User Content is for example information, data, text, files, graphics, photographs, messages, communication or other materials that you uploaded or submitted to us.
  • Protected Class Information. Daylight does not generally collect information relating to your status as a member of a protected class under federal or California law. However, Daylight does collect and disclose your date of birth for the purposes applicable to traditional identifiers, described above. Your date of birth necessarily indicates whether you are a member of the protected class of persons age 40 or older, but Daylight does not use or share the fact that you belong to this group for any purpose.

7. Integrity and retention of personal data

Daylight makes it easy for you to keep your personal data accurate, complete, and up to date. We will retain your personal data for the period necessary to fulfill our contractual obligations and the purposes outlined in this Privacy Policy. When assessing these retention periods we carefully examine our need to collect personal data at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

8. How we use and share personal data

Personal data collected from and about you online described in this Privacy Policy may be used for many purposes such as:

  • Delivering products and Services to you by verifying your identity (for example when you request early access to join Daylight).
  • Personalizing your digital and mobile experience by enhancing overall Website organization and design and analyzing data to create relevant alerts, products or Services.
  • Providing advertising, promotional and marketing Services to our customers.
  • Protecting the safety of any person and detecting and preventing fraud, identify theft and other risks to you or Daylight.
  • Performing analytics concerning your use of our online Services, including your responses to our emails and the pages and advertisements you view.
  • Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.
  • Providing user support and handling user inquiries, when our customer service representatives are handling your inquiries and replying to your demands regarding our Services (for example when you contact us directly with your issue or problem with respect to our Services).
  • Using in any other manner, or for any other business purpose, for which you have given express permission or consent to us.

9. With whom do we share or to whom we disclose your personal data?

We may share the personal data we collect from and about you online described in this Privacy Policy (and subject to other legal restrictions and notices you may have received depending on your relationship with us) for a purposes it is collected with:

  • Affiliates and Subsidiaries of Daylight. In order to provide the best possible Services, we may cooperate with our affiliated companies and subsidiaries. Affiliate means any entity that controls, is controlled by, or is under common control with, another entity, but does not include a joint employee of the entity and the affiliate.
  • Third-Party Service Providers, Vendors and other External Service Providers who have contracts with Daylight (the “Third-Party Service Providers”). We may employ other companies, vendors, service providers and individuals (non-affiliated third party) to perform functions or services for us or otherwise act on our behalf. Non-affiliated third party means any entity that is not an affiliate of, or related by common ownership or affiliated by corporate control with us, but does not include a joint employee of that institution and a third party. Please note that we use reasonable efforts to require these companies to (i) provide adequate protections for PII that are no less protective than those set out in this Privacy Policy, and (ii) use PII only for the purposes for which the third party has been engaged by us. For example this include companies that help us resolving service problems, hosting websites or software, correcting errors related to the execution of our Services, analyzing data, providing marketing assistance, developing websites and software, providing customer service, assisting us with providing, administering, developing or improving our Services, and/or for other purposes within the ordinary course of business.
  • Joint Marketing Partners. We may share personal data collected about you with other financial institutions with which we have formal agreements to offer you financial products and Services.
  • Government Agencies as required by laws and regulations. We reserve the right to disclose PII and any other information when it is believed disclosure is appropriate to (i) comply with the applicable law, judicial proceeding, court order, subpoena or other legal process; (ii) detect, prevent, or otherwise address fraud, security, emergency situations or technical issues; (iii) enforce or apply the user agreement and other agreements, rights and remedies; or (iv) protect the rights, property, or safety of Daylight, our employees and contractors, users, or others.

Please note that Daylight does not and will not sell anyone’s personal data to third parties.

10. Access and opt-out

If your personal data changes, or if you no longer desire our Services, you may correct, update, amend, delete or ask to have it removed from our Website by contacting us at the number below or postal mail at the contact information listed below. We will respond within a reasonable timeframe. When you are no longer our customer, we continue to process your information as described in this Privacy Policy (for example in order to comply with applicable tax, accounting, and legal requirements, or contractual obligations, audits and policies).

If at any time you would like to stop receiving promotional emails from us, you may opt out of receiving these secondary communications. To opt out, you must select the “Unsubscribe” link present in each email we send out to our customers. You can also unsubscribe by updating your account preferences when you access your personal account information. We reserve the right to send customers notification and administrative emails, which are considered a part of our Services.

11. Security and protection of your personal data

Daylight has, and requires our Third-Party Service Providers to have, administrative, technical, and physical safeguards in place in our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect the information contained within such systems from loss, misuse, and alteration. 

We employ commercially reasonable website security and customer verification procedures to protect your data. The measures we use may include storing personal data on secured servers, transmitting personal data using encryption technologies, and auditing and reviewing our data collection and storage practices.

User passwords and other sensitive information are saved and encrypted to prevent unauthorized access or disclosure and accidental loss, alteration, or destruction. We regularly review our operational and business practices for compliance with corporate policies and procedures governing the security, confidentiality, and quality of our information. We require all of our employees, contractors, and other third parties to protect confidential information as a condition of doing business with, and our business practices limit the use and disclosure of such information, including personal data, to authorized persons, processes, and transactions.

Please note that no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal data. You also play a role in protecting your personal data. Please safeguard your username and password for your account and do not share them with others. You agree to notify us immediately of any unauthorized use of your account or any other breach of security related to our Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your account, and to remove or edit content.

12. Third-party sites

Our Website includes links to other websites whose privacy practices may differ from those of Daylight. If you submit personal data to any of those websites, your information is governed by their privacy statements and policies. We encourage you to carefully read the privacy statement and policy of any website you visit. Daylight does not guarantee and is not responsible for the privacy or security of these third-party websites, including the accuracy, completeness or reliability of their information.

13. Your privacy rights

California

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data to third parties for their direct marketing purposes. Moreover, you have the right to restrict the sharing of your personal data and financial information with our affiliates (companies we own or control) and outside companies with whom we do business. You can make your choices here.

We are aware of your rights afforded to California residents under the California Consumer Privacy Act or “CCPA.” Even though the CCPA does not apply to us now, we are ready to protect your personal data and give you an option to exercise your right under CCPA once it becomes applicable. 

To contact us with questions about our rights under California privacy laws email us at privacy@joindaylight.com.

GLBA privacy notice

This privacy notice applies to our customers and consumers and explains how Daylight collects, uses, and discloses personal data covered by the Gramm-Leach-Bliley Act (the “GLBA”). This privacy notice also describes how we collect and share information with affiliates (companies we own or control) and outside companies with whom we do business and what types of information sharing customers and consumers may opt-out of. GLBA as the Federal law gives consumers the right to limit some but not all sharing. GLBA also requires us to tell you how we collect, share, and protect your personal data. Please read this GLBA Privacy Notice carefully to understand what we do.

14. Consent to processing and transfer of your personal data

Our Services are governed by and operated in, and in accordance with the laws of, the United States, and are intended for the enjoyment of residents of the United States. 

If you use our Services, or otherwise provide us with data, from outside the United States, you acknowledge and agree that your personal data may be transmitted outside your resident jurisdiction. In particular, please note that your personal data is stored and processed in the United States.

If you reside in a country outside the United States, please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country. By using our Website, you agree to have your information transferred to and used in the United States as set forth in this Privacy Policy. Therefore, international users, please note that it may be necessary to transfer your information internationally and, in particular, your information may be transferred to and processed in the United States.

Specifically, for residents of the European Union, please note that the data protection and other laws of other countries outside of the European Union may not be as comprehensive as those of the European Union (GDPR). Please be assured that we take steps to ensure that your privacy is protected as described in this Privacy Policy.

By using our Website and Service personal data you (i) acknowledge that the Services are subject to the laws of the United States, (ii) consent to being your personal data stored, processed and transferred to the United States and handled as described in this Privacy Policy, and (iii) waive any claims that may arise under the laws of the country where you reside, are a citizen, and/or from where you access the Services.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

Be Money Inc.
8335 Sunset Boulevard, West Hollywood, CA 90069
E-mail us: privacy@joindaylight.com