Last Updated: January 1, 2023 

Information Collected by Automated Means

When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.

When you use our App, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, battery and signal strength, usage statistics, referring emails and web addresses, dates and times of usage, actions taken on the App, and other information regarding use of the App. In addition, we may collect your device’s geolocation information. Your device’s operating platform may provide you with a notification when the App attempts to collect your precise geolocation. Please note that if you decline to allow the App to collect your precise geolocation, you may not be able to use all of the App’s features.

We may use these automated technologies on our Services to collect information about your equipment, browsing actions and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Services, including our online forms, tools or content; (3) tailor the Services around your preferences; (4) measure the usability of our Services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Services. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

Analytics Services

We may use analytics on our Services. For example, we use Google Analytics to better understand how you interact with our Site. We also use Google Maps to better understand how our Services are used and to provide you with a map of nearby ATMs. The information we obtain through our Services may be disclosed to or collected directly by these third parties. To learn more about Google Analytics and Google Maps, please visit https://www.google.com/policies/privacy/partners/.

Interest-Based Advertising

On our Services, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests.

You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information ad services may collect includes data about your visits to websites that serve SwiftGold advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Services and on third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

To learn how to opt out of interest-based advertising, see our “Your Choices” section below.

For California Consumers

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

• Identifiers. Identifiers such as a real name, postal address, unique personal identifiers (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;
• Additional Data Subject to Cal. Civ. Code § 1798.80. Signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information;
• Protected Classifications. Characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status;
• Commercial Information. Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consumer histories or tendencies;
• Online Activity. Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
• Geolocation Data. We use your IP address to determine your general location (such as city, state, or zip code);
• Sensory Information. Audio, electronic, visual, and similar information;
• Employment Information. Professional or employment-related information;
• Inferences. Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
• Sensitive Personal Information
  • Government ID. Government identification such as social security numbers, driver’s license, state identification card, or passport number;
  • Account access information. Information such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
    
  • Precise geolocation data. Data derived from a device and that is used or intended to be used to locate you within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet;
    
  • Sensitive demographic data. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
  • Biometric information. For the purpose of uniquely identifying an individual.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our SwiftGold Privacy Notice and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you sign up for an account or contact member services, or participate in, sweepstakes, promotions, or research or survey activities;
• Our Bank Partners;
• Your devices, when you use our Site or App;
• Your family or friends, such as when they provide us with your contact information by choosing to share their phone contacts with SwiftGold;
• Payment processors;
• External banks (i.e., banks other than our Bank Partners) if you link a non-SwiftGold bank account;
• Credit reporting agencies;
• Our affiliates and subsidiaries;
• Vendors who provide services on our behalf;
• Our joint marketing partners;
• Our business partners (such as referring websites);
• Online advertising services and advertising networks;
• Data analytics providers;
• Government entities;
• Operating systems and platforms;
• Social networks;
• Data brokers

Categories of third parties with whom personal information was shared

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below. When we share personal information with our Bank Partners, we do so as their service provider. The privacy practices of our Bank Partners are subject to their privacy notices (see The Bancorp Consumer Privacy Notice and the Stride Bank, N.A. Privacy Notice), which we strongly suggest you review. SwiftGold is not responsible for our Bank Partners’ information practices or privacy notices. We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: government entities; other persons to whom we have a legal obligation to disclose personal information (including, for example, in response to a duly issued subpoena or search warrant); and other persons to whom you authorize SwiftGold to disclose your personal information.

California Privacy Rights

Below are rights that are specific to California Residents. California residents also have additional rights as described in the California and Virginia Rights section below. 

Right to Opt-Out / “Do Not Sell or Share My Personal Information”. The CCPA requires us to describe the categories of personal information we sell or share to third parties and how to opt-out of future sales. It is important to know that the definition of “sale” and “share” is very broad and the common flow of information for advertising and analytics may be considered a sale or sharing. SwiftGold does not provide information that you might typically think of as personal information to third parties in exchange for money; however, under the CCPA, personal information includes unique identifiers, including things like IP addresses, cookie IDs, pixel tags, and mobile ad IDs. The law defines a “sale” broadly to include simply making such personal information available to third parties in some cases. “Share” is defined as providing personal information to a third party to target advertising to a consumer based on information about their activity on multiple websites across the internet. In the last 12 months, when you access our online services, we may let advertising and analytics providers collect IP addresses, cookie IDs, advertising IDs, and other unique identifiers, which may be collected along with device and usage data, and information about your interactions with our online services and advertisements. Learn more about this opt-out on our FAQ page here.

We do not knowingly sell or share the personal information of minors under 16 years of age.

Learn more about how to opt-out in the “how to submit a request” section below.

Notice of Financial Incentive

SwiftGold may offer rewards or prizes for participation in certain activities that may be considered a “financial incentive” under California law. These activities may involve the collection of personal information. The categories of personal information we collect is limited to what information you provide us, but may include: identifiers, protected class/demographic information, commercial information, online activities, geolocation information (general and precise), sensory information, employment information, and inferences. 

Activities we engage in that may be considered a financial incentive include surveys where we may provide compensation such as a gift card or SpotMe bonus in exchange for your time and responses, or a prize through your participation in promotions and sweepstakes. Participation in these programs may be subject to separate terms and conditions. Your participation in these programs is voluntary and you can terminate at any time as explained in any applicable terms.

When we offer gift cards in exchange for your participation in a survey or when we engage in promotions or sweepstakes, the amount provided is reasonably related to the value of the data you provide, which takes into account a number of factors, including, the anticipated benefit we receive such as product improvement, better understanding how you use our products, to enhance our understanding of consumer and market trends, increased consumer engagement, and the anticipated expenses we incur in relation to the collection, storage, and use of the information we receive. The value may vary across surveys, promotions, and sweepstakes.

For California and Virginia Consumers

If you are a California or Virginia resident, you have rights regarding your personal information, as described below (for California residents, these are in addition to the choices described in the California section above). 

Access. You have a right to request that we disclose to you, twice in a 12-month period, the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information, which is also provided in this privacy statement.

Right to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions.

Right to opt-out of targeted advertising (Virginia residents). To opt-out from or otherwise control targeted advertising, you have several options:

• • You can utilize any of the options in the “cookie and similar technologies” section under “Your Choices.”
  • You can use the controls available through our website to decline advertising-related cookies, which includes by clicking “do not sell or share my personal information”
  • You can use the Global Privacy Control setting in a web browser or browser extension as described below.

These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.

Shine the Light Request. You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access, correction, or deletion request, please email info@swiftgolsfidubciary.com, submit a request through our webform. To submit a Shine the Light request, email us at info@swiftgolsfidubciary.com. If you designate an authorized agent to make an access or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Privacy Notice.

How to Submit a Sale or Share Opt-Out Request. If you’d like to tell us not to make your personal information available in ways that we’ve identified may be a sale or sharing under the CCPA, toggle off the setting your App settings. Alternatively, you can click on our “Do Not Sell or Share” link at the bottom of our homepage or use the Global Privacy Control signal described below, but these options will only be saved to your browser for the session which you are currently active in and will not change your account settings. Further, using these choices will not stop all interest-based advertising and will opt you out of sales and sharing only after the point in time at which you make your selection. 

• Global Privacy Control. You can also use the Global Privacy Control (GPC). Some browsers and browser extensions support the GPC or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect this signal, we will make reasonable efforts to respect your choices indicated by the GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (with the exception of a request to opt-out of sales). We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your SwiftGold account, one or more recent transactions, and the last four digits of one or more SwiftGold-branded cards associated with your account. If you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Retention of Personal Data. We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. 

Additional Information. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us. Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal to info@swiftgoldfidubciary.com. Please provide the state that you are writing from and include any documentation you may have regarding the matter that you are appealing.