1. About This Policy
2. Information We Collect and Disclose
Viva First collects personal information about you for a variety of purposes. We work to collect 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, 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, or used.
- 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.
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
When you use certain Services, we may collect usernames, passwords, account numbers, and other account information for third-party websites and Internet banking services (“Third-Party Sites”). We also collect account information from you when you open a Viva First Banking Account and obtain a Viva First Card through our mobile application or online banking website. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf in order to display the information to you or to fulfill your requests for certain products, services, or transactions through a Service. We use third-party service providers, such as Plaid Inc. (“Plaid”) and MX (“MX”), to obtain this 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.
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 ID
When you use our mobile applications or the mobile versions of our Site, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”). Device IDs allow app developers, and others to uniquely identify your device for purposes of storing application preferences and other data.
3. How We Use Your Information
We may use the information you provide about yourself and about your Viva First Banking Account, Viva First 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 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.
- 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.
- 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. 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 Viva First 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 Viva First 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 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 firstname.lastname@example.org 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 also have the right to submit a request for deletion of information under certain circumstances. Viva First 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 make any of these requests, please submit your request to email@example.com.
WHAT DOES VIVA FIRST 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:
When you are no longer our customer, we continue to share your information as described in this notice.
|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 reasons Viva First chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information:||Does Viva First 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||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||No||We don’t share|
|For our affiliates’ everyday business purposes information about your creditworthiness||No||We don’t share|
|For nonaffiliates to market to you information about your creditworthiness||No||We don’t share|
What we do
|How does Viva First protect my personal information?||To protect your personal information from unauthorized access and we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.|
|How does Viva First collect my personal information?||We collect your personal information, for example, when you open an account or use your debit card. We also collect your personal information from others, such as credit bureaus and other companies.|
|Why can’t I limit all sharing?||Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing.
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.|
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies. We do not share with non-affiliates so they can market to you.|
|Joint Marketing||A formal agreement between nonaffiliated financial companies that work together to market financial products or services to you.|