Effective Date: August 25, 2023
1. About This Policy
2. Information We Collect And Disclose
Dave collects personal information about you for a variety of purposes. During the past 12 months, we have collected the following categories of personal information from individuals:
- Personal Identifiers, such as a full name, postal address, email address, online usernames and passwords for third-party sites and internet services, advertising identifiers, social security number, driver’s license number, or other similar identifiers.
- Internet or other network activity information, such as information regarding how individuals interact with the Site, emails, or marketing materials.
- Professional or employment-related information.
- Commercial information, such as products or services purchased, obtained, used, or transactional data.
- Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics.
- Bank account and debit card information, such as account numbers, card numbers, and transaction histories.
During the past 12 months, we have also disclosed the categories of personal information listed above for our business purposes. We have not, however, sold personal information to third parties. We may also collect information about you from mailing list providers, publicly available sources, identification verification services and other third parties.
2.1 Third Party Credentials, Account Numbers and Other Account Information
2.2 Information Collected by Cookies and Web Beacons
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage, and determine whether an email has been opened and acted upon.
Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs. You can change your preferences on your device.
2.3 Technical and Navigational Information
We may collect your computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.
2.4 Device Data
When you use our mobile applications or the mobile versions of our Site, we may collect the following device information:
- Device-centered Data - Data tied to proper information about linguistic, cultural, and technological conventions for use in formatting data for presentation (calendar type, keyboard language, etc.)
- Locale - Information pertaining to the user's locale (for example: calendar type used, the language used in keyboard, etc.).
- Accessibility - Active accessibility settings.
- Device Motion - Device motion data, such as acceleration and gyroscope.
- Accelerometer - Measures how fast your phone moves & in what direction it points.
- Magnetometer - Measures magnetic fields, and is often used (for example) to detect which way "North" is in mapping applications.
The data above allow app developers, and others to uniquely identify your device for purposes of storing application preferences and for your security.
2.5 Data Collected Through SMS and Short Code Messaging Programs.
Please note that personal data obtained through SMS short code is not shared with third parties and/or affiliates for their own marketing purposes.
3. How We Use Your Information
We may use the information you provide about yourself and about your Dave Banking Account, Dave Card, or Third-Party Sites to fulfill your requests for our products, programs, and Services, to respond to your inquiries about our Services, and to offer you other products, programs, or services that we believe may be of interest to you. We may use your information to complete transactions you request, to verify the existence and condition of your accounts, or to assist with a transaction. For example, we may use the account information you provide or that we collect from Third-Party Sites to confirm your accounts are valid and to access funds from your accounts in connection with the fulfillment of the Services. We may use your information to improve and personalize the Services. For example, we may use your information to pre-fill form fields on the Sites for your convenience.
4. How We Share Your Information
We may share personal information about you as follows:
- With third parties to provide, maintain, service and improve our Services.
- To process transactions that you authorize or to fulfill your requests.
- With participating merchants to determine if you are eligible to receive rewards or promotions.
- In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business.
- To respond to subpoenas, court orders, or legal process.
- the legal rights or physical safety of any person or the security of our network, Sites or Services.
- To respond to claims that any posting or other content violates the rights of third parties.
- In an emergency, to protect the health and safety of our Sites' users or the general public.
- As otherwise required by law.
5. How We Secure Your Information
We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information. We hold ourselves responsible for the security of cardholder data we possess or otherwise store, process, or transmit on your behalf, or to the extent that we could impact the security of your cardholder data environment. Dave will maintain all applicable PCI DSS requirements to the extent we handle, have access to, or otherwise store, process, or transmit the customer's cardholder data or sensitive authentication data, or manage the customer's cardholder data environment on behalf of a customer. Examples of measures we have taken to protect your information include, but are not limited to:
- The use of industry-standard encryption while transmitting and storing information.
- Mobile application session timeouts to ensure your information is protected when you put down your device without logging out.
- Passwords and personal identification numbers (“PINs”) are only known by you. No employee, contractor or Third-Party Site has access to your Dave password or PIN. We will never ask for your password or PIN through our customer service teams.
- Two-factor authentication is provided to ensure your account can only be accessed by the device you register with.
- Our systems are periodically audited for security flaws.
6. Note On Communication
We may provide you with information and summaries of your accounts and Services through email, SMS and mobile notifications. We may also allow you to subscribe to email newsletters and from time to time may transmit emails to you promoting Dave or third-party goods or services. Subscribers have the ability to opt out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end the transmission of service-related emails, such as information and summaries of your accounts and Services.
7. How To Update Your Information
If you wish to access personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information through our Site. Alternatively, you can send an email that includes your contact information to email@example.com to request any corrections to your personal information. You may also email us if you wish to deactivate your Services, but even after you deactivate your Services, we may retain archived copies of information about you for a period of time that is consistent with applicable law.
8. California Privacy Rights
The California Consumer Privacy Act (“CCPA”) allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents have the right to submit a request for deletion of information under certain circumstances. Dave will not discriminate against you for exercising your rights, such as by denying you services, charging you different prices for services, or providing you a different level or quality of services. Please note that you must verify your identity and request before further action will be taken. As part of this process, we may require you to provide government identification. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We do not sell your personal information to third parties. We do, however, share personal information with third parties for the business purposes described in this Policy. California law also permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to exercise your data protection rights where applicable, including removing or correcting inaccurate information, wait you can submit a request using our online form (available here) or contact us through Dave’s Mobile App or firstname.lastname@example.org. We will consider all requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims. Personal data will be retained by Dave for at least the time period required by applicable laws, depending on the type of products and services you are engaged in. Here is a summary of the CCPA-related categories of Personal Information we may have collected about you over the past 12 months as well as how we use it and with whom we may have shared it.
|Categories of Personal Information we collect:||How we use Personal Information:||Parties with whom your information may be shared:|
|Personal identifiersFinancial informationContact informationTransaction informationGeolocation informationDevice informationInternet or other electronic network activity informationProfessional or employment related informationBank account and debit card informationCommercial information, such as products or services purchased, obtained, or used||Identity verificationCompliance, risk, and fraud detectionProviding, personalizing, and improving our productsTo fulfill your requests for certain products, services, or transactionsContacting you to resolve disputes and help with our ServicesConducting investigations, complying with and enforcing any applicable laws, regulations, legal requirements, and industry standardsResponding to lawful requests for informationTo perform other business purposes||Affiliate partnersIssuing financial institutionsPayment networksPayment card associationsService providers to facilitate:Bank account aggregationFraud detectionIdentity verificationPayment processingCard issuing servicesLaw enforcement or other third parties in response to a legal request|
10. Everything Make Sense?
If you have questions or concerns regarding this Policy, or if you have any questions or suggestions, please contact email@example.com.
Federal Privacy Notice
|FACTS||WHAT DOES Dave Operating LLC (“Dave”) DO WITH YOUR PERSONAL INFORMATION?|
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include:Social Security numberEmployment information and incomeAccount balancesAccount transactions and transaction historyChecking account information|
|How?||All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reason Dave chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Dave 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||Yes||No|
|For our marketing purposes– to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||Yes||No|
|For our affiliates' everyday business purposes –information about your transactions and experiences||Yes||No|
|For our affiliates to market to you||No||Yes|
|For nonaffiliates to market to you||No||Yes|
|To limit our sharing||Email us at firstname.lastname@example.orgPlease note:If you are a new customer, we can begin sharing your information 30 days from the date you sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.However, you can contact us at any time to limit our sharing.|
|Questions?||Email us at email@example.com|
|Who we are|
|What we do|
|How does Dave protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with industry standards. These measures include computer safeguards and secured files and buildings.|
|How does Dave collect my personal information?||We collect your personal information, for example, when youApply for services and accountsGive us your income informationTell us where to send moneyProvide account informationProvide employment information|
|Why can't I limit all sharing?||Federal law gives you the right to limit sharing only for:affiliates from using your information to market to yousharing for nonaffiliates to market to youfor joint marketing with other financial companiesState laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.|
|What happens when I limit sharing for an account I hold jointly with someone else?||Your choices will apply to everyone on your account.|
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.Dave Operating LLC|
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.Nonaffiliates we share with can include consumer loan brokers, lenders and direct marketing companies.|
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.Our joint marketing partners can include institutions such as consumer lenders or marketers|
|Other important information|
|FOR VERMONT RESIDENTS: We will not share information we collect about you with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account.FOR CALIFORNIA RESIDENTS: We will not share information we collect about you with nonaffiliated third parties, except as permitted by California law, such as to process your transactions or to maintain your account. We will limit sharing among our companies to the extent required by California law.FOR NEVADA RESIDENTS: We are providing this notice to you pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by writing to us at Dave Operating LLC 1265 S Cochran Ave, Los Angeles, CA 90019. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protections, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101, phone number (702) 486-3132, email BCPINFO@ag.state.nv.us.State laws may also provide you with specific privacy protections. We will comply with applicable state laws with respect to our use of your information.|