Last Updated: December 27, 2019
What information does Dwolla collect?
- Identifiers, such as a real name, postal address, phone number, email address, account name, or other similar identifiers.
- Internet activity, including IP address, type of device, operating system, browser, UR data, and similar data.
- Inferences about preferences from cookies and site usage, including those used to gauge interest in obtaining Dwolla Services.
- Financial information, such as your full bank account number if you choose to use it with the Dwolla Services.
- Detailed personal information, such as your date of birth or social security number, as may be required by law or rule.
- Other personal information provided by third party service providers such as credit bureaus and identity verification services.
- Information that you provide to Dwolla when interacting with our customer support team or other team members via phone, email, online form, or other correspondence.
- Email and/or phone number for your contacts that you enter into Dwolla payment flows. We use this information to notify your contacts that you have sent them a payment and/or payment request.
- If you use a device to access the Dwolla Sites or Dwolla Services, we may also collect your IP address, the type of device you use, your device identifier, your operating system version, the type of browser you use, your location, and the URL that you came from and the next URL that you visit.
- Dwolla uses analytics software to allow us to better understand the functionality of the Dwolla Sites. This software may record information such as how often you use the Dwolla Sites, the events that occur with such use, aggregated usage, and performance data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Sites and the Dwolla Services.
- Detailed personal information, such as your date of birth or social security number, and protected legal characteristics, such as your membership in a protected class. We may collect this information if you apply for or accept a job at Dwolla, to the extent required by law.
- Credit information and criminal record information from third party vendors performing pre-employment background checks as authorized by law.
How does Dwolla use the personal information that it collects?
Over the past twelve months, and on an ongoing basis, Dwolla collects your personal information to do the following:
- Customize and improve your Dwolla experience with the Dwolla Sites and the Dwolla Services.
- Provide the Dwolla Services to you.
- Validate your account.
- Notify you about your account activity.
- Process transactions and collect fees.
- Provide customer support and resolve disputes.
- Verify your identity and account information.
- Identify, prevent, and report potentially prohibited, fraudulent, or illegal activities.
- Notify you about important changes to the Dwolla Services and/or Dwolla’s terms and conditions.
- Provide you with news, offers, and information about the Dwolla Services based on your communications preferences.
- Process your application for Dwolla employment, or the award of employment with Dwolla, in accordance with law.
- Any other purpose that we disclose to you in the course of providing the Dwolla Sites, Dwolla Services, or Dwolla Employment to you.
How does Dwolla share my personal information?
Over the past twelve months, and on an ongoing basis, we may share your personal information as follows:
- When you send or receive money using the Dwolla Services, we will provide the other party to the financial transaction appropriate details about the transaction.
- If your payment to another Dwolla user fails, we may provide that user with details of the unsuccessful payment.
- With third parties to provide, maintain, and improve the Dwolla Services, including fraud prevention, identity verification, analytics and marketing services, and financial institutions and other partners that are part of the payment process. These companies are authorized to use your personal information only as necessary to provide these services to us.
- To the extent third party analytics software is used to improve the functionality of the Dwolla Sites, the providers of the software may receive information about your use and interaction with the software in order to assist Dwolla with providing and improving the Dwolla Sites and the Dwolla Services.
What are other circumstances when Dwolla may disclose my personal information?
- Dwolla may release information to third parties upon your request. For example, you may authorize a Dwolla integrating partner to access your personal and business information.
- Dwolla may release your information if we believe disclosure is reasonably necessary to comply with any applicable law, legal process, or government request; to investigate or bring legal action against someone who may be violating our rights, our terms and conditions, or the rights of others; or to protect the safety and security of Dwolla, our users, or the public.
- Dwolla may also share aggregated, non-personally identifiable information with third parties for auditing, analytics, maintenance, security, or other related business purposes as determined appropriate by Dwolla.
Does Dwolla sell my personal information?
No. Dwolla does not sell your personal information.
Will Dwolla refuse service, charge me a different rate, or provide different quality service if I decline to provide certain data?
In order to use Dwolla Services to transfer funds through the U.S. monetary system, a user must comply with applicable federal laws and rules. These applicable laws and rules may require the disclosure and retention of information regarding the identity of senders and recipients of funds.
Dwolla will not discriminate against you for exercising any rights you may have under the California Consumer Privacy Act (“CCPA”) or any other applicable law or rule. Dwolla does not base its prices or the quality of its services on the exercise or non-exercise of legal privacy rights.
As reflected above, Dwolla and its marketing, analytics and fraud prevention service providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about Dwolla’s user base, and we may receive such information on an individual and aggregated basis from such providers.
We may gather certain information about our website visitors automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Services.
We may partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you do not want this information to be used for the purpose of serving you interest-based ads, you may opt-out by clicking here. This does not opt you out of being served ads and you will continue to receive generic ads.
We use Local Shared Objects, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website also use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here.
How do I opt-out of receiving promotional emails from Dwolla?
If you prefer not to receive promotional emails from Dwolla, click on the unsubscribe link at the bottom of any promotional email that we send you to remove your email address from future promotional email campaigns. If you have difficulty with the unsubscribe process, contact us at firstname.lastname@example.org.
What security precautions does Dwolla take to protect me?
We have security measures in place to protect your personal information, including the use of industry-standard data encryption technology and internal policies and restrictions regarding the storage of and access to your personal information. Please note that no data transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. Dwolla’s servers and business operations are entirely located in the United States. If you have any questions about the security of your personal information, you can contact us at email@example.com.
How do I update my information?
If your information changes, you can correct it in your account settings by contacting your organization’s Account Manager at www.dwolla.com.
If you wish to close your account or request that we no longer use your information to provide you the Dwolla Services, contact us at firstname.lastname@example.org and we will respond to you in a reasonable timeframe. We will retain your information for as long as your account is active or as needed to provide you the Dwolla Services, or to the extent required by applicable law or rule.
What about the privacy of children?
Dwolla is a general audience website. Dwolla does not knowingly collect any personal information from anyone under the age of 13.
Rights for California Residents
If you are a California resident, you have the right to request disclose of the specific pieces of personal information that Dwolla may have collected regarding you. California residents also have the right to request deletion of personal information that Dwolla may have collected regarding you.
In order to request a copy of personal information or to request deletion of personal information, California residents can forward verifiable consumer requests to Dwolla through one of the following methods:
·Emailing us at email@example.com;
·Calling Dwolla at 1-888-289-8744.
Only you, or someone registered with the California Secretary of State in order to act upon your behalf, may make a verifiable consumer request. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for data access, transport, or deletion twice within a twelve-month period.
In order to submit a verifiable consumer request to Dwolla, the request must both provide sufficient detail for Dwolla to be able to appropriately ascertain your identity and give sufficient clarity for Dwolla to understand the nature of the request. Dwolla will determine the criteria for a verifiable consumer request based upon the nature of the request and account.
If you have submitted a verifiable consumer request to Dwolla, Dwolla will respond in a timely manner consistent with applicable law. If Dwolla is unable to verify your request, or if Dwolla is unable to ascertain that you are a California resident subject to the rights in this Section, Dwolla will submit an appropriate response.