October 29, 2020
OUR COMMITMENT TO PRIVACY
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.
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:
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.
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.
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:
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.
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:
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.
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.
HOW TO CONTACT US
WHAT DOES TEND
Reasons we can share your personal information
Does TEND share?
Can you limit this sharing?
For our everyday business purposes–
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes–
to offer our products and services to you
For joint marketing with other financial companies
For our affiliates' everyday business purposes–information about your transactions and experiences
For our affiliates' everyday business purposes–
information about your creditworthiness
For our affiliates to market to you
For nonaffiliates to market to you
Who we are
Who is providing this notice?
This notice is provided by Tend, a service of GlobeOne LLC., and its affiliates.
What we do
How does TEND protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does TEND collect my personal information?
We collect your personal information, for example, when you
§ open an account or deposit money
§ pay your bills or apply for a loan
§ use your credit or debit card
We also collect your personal information from others, such as credit bureaus or other companies.
Why can't I limit all sharing?
Federal law gives you the right to limit only
§ sharing for affiliates' everyday business purposes – information about your creditworthiness
§ affiliates from using your information to market to you
§ sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
§ Tend does not share with our affiliates.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
§Tend does not share with nonaffiliates so they can market to you.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
§Our joint marketing partners include Marketing companies and banks that are our banking partner.
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 residents only.
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.).
[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:
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.
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.
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
© 2020 TEND MONEY
^ The Tend debit card can be used for free at over 37,000 ATMs in the MoneyPass Network. Tend does not charge ATM fees, but some ATM providers may charge fees of their own, which are not reimbursed.
^^ Cashback deals on Tend purchases, including categories, merchants, and percentages, will vary and must be selected in the app. Cashback will be applied automatically after the travel dates or final transaction posts, which may be up to 90 days after the qualifying purchase or travel event.