Privacy Policy

LAST UPDATED

October 29, 2020

OUR COMMITMENT TO PRIVACY

Tend, a service of GlobeOne, LLC, knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. This Privacy Policy, which includes the Regulation P Privacy Notice (see Appendix A) and the California Consumer Privacy Act Notice applicable to California residents (Appendix B), is available from the home page of the Tend website at tend.money (the "website") and through our mobile applications.

This Policy and Notice are reviewed at least annually. Tend employees receive training on this Policy and Notice upon being hired, when any changes are made, and annually. If the Notice changes, all current customers must receive revised new Privacy Notice (reflecting the new rev. date) at least 30 days prior to the effective date of the changes so that you may opt out (if the change permits this) or close your account before the information is shared.

APPLICABILITY OF PRIVACY POLICY

This privacy policy applies to all nonpublic personal information we collect through our Services from current and former Tend users, including you. “Services” means any products, content, features, technologies, or functions, and all related websites, applications and services offered to you by Tend in connection with a Tend account. When you are no longer our customer, we continue to share your information as described in this policy. This policy only applies to the Tend Services and does not apply to any other practices of any other GlobeOne LLC company.

Under the law, the Tend is permitted to disclose nonpublic personal information about our customers to unaffiliated third parties under specific exceptions stated in Regulation P. These exceptions include sharing with Government entities in response to Subpoenas for Records, Attachments and/or Garnishments Orders served upon us by any Court of Law, responding to Levies from State Governments or the Internal Revenue Service; reporting payment and credit information related to the consumer’s transaction to the Credit Bureaus; sharing information in order to carry out the requested transaction or product; providing information to Legal Counsel, Accountants, Auditing and Consulting firms, Regulatory Agencies and as otherwise required as a part of being a partner with a depository financial institution. WE DO NOT DISCLOSE ANY NONPUBLIC PERSONAL INFORMATION ABOUT OUR CUSTOMERS TO ANYONE, EXCEPT AS PERMITTED BY LAW. Because of our policy of how we share customer nonpublic personal information, we do not provide any customer Opt Out for sharing as part of our Privacy Notice.

Throughout this policy, we use the term "personal information" to describe nonpublic information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.

THE INFORMATION WE COLLECT

When you visit the Tend website or use our mobile applications or other Services, we collect your IP address and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Services.

If you open a Tend account, we collect information from you, including the following:

• Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
• Identification Information - your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
• Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
• Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to share your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
• Social Web Information – including but not limited to Facebook information that you authorize that allows us access to your email address, Facebook friends list, and public profile (including profile picture). We may also allow you to import data from other social web services, including but not limited to Twitter, TikTok, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve the Services and fight fraud). You may manage or limit certain contact preferences and notifications in your account settings.
• Financial Information - bank account online login information, bank account and routing numbers and credit cards linked to your Tend account. Tend does not share financial information with third party social networking services such as those listed in the prior bullet.

We are committed to providing a safe, secure and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you that we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.

INFORMATION FROM CHILDREN

The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

MEDICAL INFORMATION

On occasion Tend may obtain access to medical information on customers. Tend will not share its customers’ medical or health information without the written consent of the customer and in accordance with HIPAA regulations.

HOW WE USE COOKIES

When you visit or use our Services or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer; customize Services, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our Services.

Certain Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of certain Services may be limited or not possible.

Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

HOW WE PROTECT & STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security of our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Tend password with anyone.

If Tend learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services and providing the acknowledgement required by the Electronic Signatures in Global and National Commerce Act, you agree that Tend may communicate with you electronically. Tend may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. You may have a legal right to receive notice of a security breach in writing.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

• provide the services and customer support you request;
• process transactions and send notices about your transactions or your network activity;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
• create an account connection between your Tend account and a third-party account or platform;
• customize, personalize, measure, and improve our services and the content and layout of our website;
• send you updates about new products and services that we are offering to customers;
• compare information for accuracy and verify it with third parties;
• perform other duties as required by law; and
• if you elect to share your Geolocation Information, we may use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.

HOW WE SHARE PERSONAL INFORMATION WITHIN THE TEND NETWORK

To process payments on Tend, we need to share some information with the person or company that you are paying or that is paying you. Your contact information, date of sign-up and other verification information may be provided to users or companies when you transact with, on, or through Tend.

We work with vendors to enable them to accept payments from you using Tend. In doing so, a vendor may share information about you with us, such as your mobile phone number or Tend username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a Tend customer and that the vendor should enable Tend as a form of payment for your purchase.

Regardless, we will not disclose your card number, bank account number, social security number, tax identification number, or date of birth to anyone you have paid or who has paid you through Tend, except with your express permission. We are required to comply with subpoenas and other forms of legal process.

HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

Tend does not share your personal information with third parties for their promotional or marketing purposes. We do share your personal information with our banking partner in order to jointly market and provide the Services to you.

Some of your information is public information and may be seen by anyone on the internet, whether or not they have a Tend account. Public information may also be seen, accessed, reshared or downloaded through Tend's APIs or third-party services that integrate with our products.

• Public information for personal profiles includes your Tend username, first and last name, month and year of Tend account creation, and public transactions in which you've been involved.

In addition to any public information, your Tend friends list may be seen by any logged-in Tend user.

We may share your personal information with:

• Our parent company, GlobeOne LLC, Inc. and affiliates and subsidiaries it controls, but only for purposes allowed by this document and in accordance with our Privacy Notice (Appendix A).
• Companies that GlobeOne LLC, Inc. plans to merge with or be acquired by. We will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice and the opportunity to close your account before the information is used.
• Law enforcement, government officials, or other third parties if GlobeOne LLC is compelled to do so by a subpoena, court order or similar legal procedure, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Tend User Agreement, or as otherwise required by law.
• Third party service providers who assist us in providing services to you that you requested or who provide fraud detection or similar services on our or any vendor’s behalf.
• Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
• Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
• For the purposes of this privacy policy, an "account connection" with such a third party is a connection you authorize or enable between your Tend account and a non-Tend account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Tend and the third-party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your Tend account to a social media account or social messaging service; connecting your Tend account to a third-party data aggregation or financial services company, if you provide such company with your Tend account log-in credentials; or using your Tend account to make payments to a merchant or allowing a merchant to charge your Tend account.
• If you connect your Tend account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Tend account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.
• Information that we share with a third-party based on an account connection that you have authorized will be used and disclosed by the third-party in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that Tend shares with a third-party account or platform such as a social media account (per your specific authorization) may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

Tend does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of Tend and is outside of this policy and is subject to the terms of use and privacy policies of such third parties.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your account settings at any time by logging in to your account.

LINKS TO OTHER SERVICES OR SITES

The Services may contain links to (or allow you to link to) other third-party services or websites. Tend does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information. You will be warned whenever using a link that you are leaving the Tend website.

CALIFORNIA RESIDENTS

As noted in the Reg P Privacy Notice in Appendix A and as detailed in the California Consumer Privacy Act (CCPA) Notice in Appendix B, California residents have the right to request certain information. Upon request submitted to the phone number or email address listed, we will provide the information as specified in the CCPA Notice in Appendix B.

We do not sell any personal information, regardless of age. We have not sold Personal Data of any California residents 15 years of age and younger or of any other consumer.

CHANGES TO OUR PRIVACY POLICY

Tend is always improving. As the Services evolve we may occasionally update this privacy policy. If we modify this privacy policy, we will post the revised privacy policy to the website, and we will also revise the "last updated date" stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our mobile application or website or by sending you an e-mail. However, if the changes we make change the Privacy Notice below, we will notify you in advance of the effective date of the change.

HOW TO CONTACT US

If you have questions or concerns regarding this privacy policy, or any feedback pertaining to your privacy and the Services that you would like us to consider, please email us at privacy@Tend.money.

Rev. 10/2020

WHAT DOES TEND

Other important information

You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.

For California residents: In accordance with California law, we will not share information we collect about you with companies outside of our corporate family, except as permitted by law, including, for example with your consent or to service your account. We will limit sharing among our companies to the extent required by California law. Please see the separate notice you are receiving entitled California Consumer Privacy Act for a full description of your rights.

For Vermont residents: In accordance with Vermont law, we will not share information we collect about you with companies outside of our corporate family, except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness within our corporate family except with your authorization or consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.

California Consumer Privacy Act (CCPA) Privacy Policy

California residents only.

Tend, a service of GlobeOne, LLC (“we”, “our”, or “us”) takes your privacy seriously and makes safeguarding your personal information a priority. This California Consumer Privacy Act (“CCPA”) Privacy Policy applies to California residents and is in addition to the information contained in our general Privacy Policy.

Applicability. The CCPA does not apply to certain information covered by other regulations, such as the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), and regulations issued by the Consumer Financial Protection Bureau (“CFPB”). We collect personal information in connection with financial services that are for personal, family, or household purposes that are provided by our financial institution partners (information subject to the GLBA – our financial institution partners provide separate GLBA notices).

SALE OF PERSONAL INFORMATION

We do not sell, rent, transfer, disclose, or otherwise provide consumers’ personal information to third parties or other businesses for monetary or other valuable consideration. It is not our policy to sell personal information, and we have not done so in the past 12 months.

INFORMATION WE COLLECT

We may collect personal information when you enter data into an application for new products or services or when you use our products and services. Under the CCPA, personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information may include your name, physical or mailing address, tax identification number, date of birth, contact numbers, e-mail address(es), biometric information, education, employer, occupation, employment history, identification (i.e., driver’s license, state ID, passport, employee ID, etc.), commercial information (records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) account numbers, account activity/history, or other financial information needed by our financial institution partners. Through the use of our website and other services, we may gather browsing history, device location, Internet Protocol (IP) addresses, and visual, audio, or electronic recordings, and inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

HOW INFORMATION IS COLLECTED

We obtain the categories of personal information listed above from the following sources:

• Directly from you – through our website and mobile apps, or by telephone, email, or text – when you interact with us and provide information to request products or services.

• From service providers we use – to authenticate your identity.

• Indirectly from you – through our website and mobile apps.

• Credit reporting agencies and public record sources (federal, state, or local government).

• Other third parties you consent to during the use of our website, mobile apps, or otherwise to request products or services from us (family, employer, etc.).

INFORMATION SHARING

We only share your information in accordance with our general Privacy Policy.

[HOW WE USE INFORMATION

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

• provide the services and customer support you request;
• process transactions and send notices about your transactions or your network activity;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
• create an account connection between your Tend account and a third-party account or platform;
• customize, personalize, measure, and improve our services and the content and layout of our website;
• send you updates about new products and services that we are offering to customers;
• compare information for accuracy and verify it with third parties;
• perform other duties as required by law; and
• if you elect to share your Geolocation Information, we may use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.]

YOUR RIGHTS UNDER THE CCPA

1. The right to request we disclose to you the following information covering the 12 months preceding your request (“request to know”). This information is hereby provided to you to eliminate the need for you to request it.

• The categories of personal information about you that we collected;
• The categories of sources from which the personal information was collected;

• The business purpose for collecting personal information about you;

• The categories of third parties with whom we disclosed personal information, the categories of personal information disclosed, and the purpose for disclosing it; and
• The specific pieces of information we collected about you.

2. The right to request we delete personal information from you, subject to applicable exceptions (“request to delete”).

3. The right to be free from unlawful discrimination for exercising your rights under the CCPA.

You also have the right to designate an authorized agent to make a request under the CCPA on your behalf. If you wish to designate an authorized agent, we will require a valid power of attorney with express powers under the CCPA. In some instances, we may not be able to honor your request. We will not honor your request if we cannot verify your identity or confirm that the personal information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we may not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights of others or where the personal information that we maintain about you is not subject to the CCPA. If we are not able to honor your request, we will advise you in our response. We will not provide any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

MAKING REQUESTS

As a California resident you or your authorized agent may request details about personal information collected and/or shared by calling us, emailing us, or submitting a request through our website or mobile app. Contact information is below. We will take necessary steps to verify your identity once a request is received, which may vary based on your relationship with us. We will work to process all verified requests within 45 days. If we need an extension in order to process your request, we will provide you with an explanation for the delay.

CCPA Contact Information:

By Telephone: 1-833-836-3439

By Email: privacy@Tend.money

This policy may change from time-to-time. Any changes will be posted on our website.

Last Revised: October 29, 2020