PRIVACY POLICIES
Effective as of September 16, 2024
Banking services made available through ONE are issued by Coastal Community Bank,
Member FDIC. Below are the Privacy Notices and Policies applicable to your ONE account from
ONE and Coastal Community Bank.
ONE GLBA Privacy Notice
Coastal Community Bank U.S. Consumer Privacy Notice
ONE Privacy Policy
ONE GLBA Privacy Notice
Rev. Dec 2023
FACTS
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WHAT DOES ONE DO WITH
YOUR PERSONAL INFORMATION?
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Why?
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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.
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What?
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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 number
- Income
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Account balances and transaction history
- Payment history
- Employment information
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Credit history and credit scores
When you are no longer our customer, we continue to share your information as described in this
notice.
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How?
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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 ONE
chooses to share; and whether you can limit this sharing.
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Reasons we can share your personal information
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Does ONE share?
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Can you limit this sharing?
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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
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Yes
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No
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For our marketing purposes – to offer our products and services to you
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Yes
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No
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For joint marketing with other financial companies
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Yes
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No
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For our affiliates’ everyday business purposes – information about your transactions and experiences
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Yes
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No
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For our affiliates’ everyday business purposes – information about your creditworthiness
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Yes
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Yes
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For our affiliates to market to you
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Yes
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Yes
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For nonaffiliates to market to you
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Yes
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Yes
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Questions?
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To limit our sharing
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Call 1-855-830-6200
Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we
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.
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Questions?
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Call 1-855-830-6200
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Who we are
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Who is providing this notice?
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This notice is provided by One Finance, Inc., and OneProgress Services
LLC (collectively, “ONE”)
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What we do
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How does ONE protect my personal information?
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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.
We restrict access to your personal information to our employees who need to know
that information to provide your products and services.
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How does ONE collect my personal information?
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We collect your personal information, for example, when you:
● Open an account
● Make deposits or withdrawals from your account
● Apply for a loan
● Use your ONE card for debit purchases
● Provide account information
● Provide employment information
● Request or transfer funds
We also collect your personal information from others, such as credit
bureaus, affiliates or other companies.
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Why can’t I limit all sharing?
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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.
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Definitions
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Affiliates
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Companies related by common ownership or control. They can be financial and
nonfinancial companies.
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Our affiliates include nonfinancial companies, such
as a retail company.
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Nonaffiliates
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Companies not related by common ownership or control. They can be financial and
nonfinancial companies.
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Nonaffiliates we share with can include tax preparation companies, insurance
companies, direct marketing companies and banks.
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Joint marketing
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A formal agreement between nonaffiliated financial companies that together market
financial products or services to you.
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Our joint marketing partners can include financial service companies, such as
banks, insurance providers, investment companies, securities broker-dealers and
credit card companies.
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Other important information
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Rights Under State Law: You may have privacy rights under various state laws. We will
comply with these laws to the extent they apply.
For California residents: We will not share information we collect about you
with nonaffiliated third parties, except as permitted by law, including, for example,
with your consent or to service your account.
For Vermont residents: We will not disclose information about your creditworthiness
to our affiliates and we will not share information we collect about you with
nonaffiliated third parties, except as permitted by law, including, for example, with
your consent or to service your account.
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Coastal Community Bank U.S. Consumer Privacy Notice
Revised: June. 2023
FACTS
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WHAT DOES COASTAL COMMUNITY BANK DO WITH YOUR PERSONAL INFORMATION?
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|
|
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Why?
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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.
|
|
|
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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 number and income
• Account balances and payment history
• Credit history and credit scores
When you are no longer our customer, we continue to share your information as
described in this notice.
|
|
|
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How?
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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 Coastal Community
Bank chooses to share; and whether you can limit this sharing.
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Reasons we can share your personal information
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Does Coastal Community Bank share?
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Can you limit this sharing?
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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
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Yes
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No
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For our marketing purposes – to offer our products and services to you
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Yes
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No
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For joint marketing with other financial companies
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No
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We don’t share
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For our affiliates’ everyday business purposes – information about your transactions and experiences
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No
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We don’t share
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For our affiliates’ everyday business purposes – information about your creditworthiness
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No
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We don’t share
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For nonaffiliates to market to you
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No
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We don’t share
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Questions?
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Call (425) 257-9000 or go to www.coastalbank.com or email [email protected]
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What we do
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How does Coastal Community Bank protect my personal information?
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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.
Our Customer Information privacy policy serves as a standard for all Coastal
Community bank employees for collection, use, retention and security of individual
customer information.
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How does Coastal Community Bank collect my personal information?
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We collect your personal information, for example, when you
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Open an account or pay your bills
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Apply for a loan or make deposits or withdrawals from your account
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Provide account information
We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies.
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Why can’t I limit all sharing?
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Federal law gives you the right to limit only
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Sharing for affiliates’ everyday business purposes – information about
your creditworthiness
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Affiliates from using your information to market to you
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Sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit
sharing.
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Definitions
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Affiliates
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Companies related by common ownership or control. They can be financial and
nonfinancial companies.
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Coastal Community Bank does not share with affiliates
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Nonaffiliates
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Companies not related by common ownership or control. They can be financial and
nonfinancial companies.
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Coastal Community Bank does not share with nonaffiliates so they can market to
you
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Joint marketing
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A formal agreement between nonaffiliated financial companies that together market
financial products or services to you.
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Coastal Community Bank doesn’t jointly market
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ONE PRIVACY POLICY
Last Updated: September 16, 2024
This Privacy Policy describes how One Finance, Inc., and OneProgress Services LLC
(collectively, “ONE”, or “we”, “our”, and “us”), receives, uses, shares and otherwise processes Personal Information (as defined
below) in connection with the content, platform, services, products, and other functionality
offered on or through our services (collectively, the “Services”), including our websites (www.one.app) and mobile applications (collectively, the
“ONE Apps”).
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GRAMM-LEACH-BLILEY ACT COVERED DATA
- PERSONAL INFORMATION WE RECEIVE
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HOW WE USE YOUR PERSONAL INFORMATION
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THIRD PARTIES WHO MAY RECEIVE PERSONAL INFORMATION
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U.S. STATE RESIDENTS’ PRIVACY RIGHTS AND CHOICES
- RETENTION
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CHILDREN'S PERSONAL INFORMATION
- THIRD-PARTY PRIVACY PRACTICES
- UPDATES TO THIS PRIVACY POLICY
- CONTACT US
1. GRAMM-LEACH-BLILEY ACT COVERED DATA
If you apply for or have a financial product or service with us, we will use and share any
Nonpublic Personal Information (“NPI”), as defined by the Gramm-Leach-Bliley Act (“GLBA”), that we collect from or about you in connection with your use of that product or
service in accordance with our GLBA Privacy Notice, which offers you certain choices with respect to our collection, use, sharing, and
processing of your NPI.
When you obtain or use financial products or services from ONE that are issued by Coastal
Community Bank, those products or services are further subject to Coastal Community Bank’s GLBA Privacy Notice. Coastal Community Bank’s use of NPI that it receives is subject to its GLBA
Privacy Notice.
2. PERSONAL INFORMATION WE RECEIVE
“Personal Information” means any data that identifies, relates to, describes, is capable of being
associated with, is linked to or could reasonably be linked, directly or indirectly, with a
person or household or any other data or information that constitutes “personal
data,” “personal information,” or “personally identifiable
information” under applicable privacy laws. When you use our Services we receive
Personal Information in a variety of ways, including directly from you and/or your devices,
from third parties (including our affiliates, banking partners, your employer, and other
users), from publicly available sources, and through information that we collect
automatically. We may receive the following categories of Personal Information:
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Identifiers: We receive identifiers, such as name, email, login credentials, address, phone number,
password, date of birth, Social Security number, taxpayer identification number, military
status, driver’s license or other government issued identification and numbers, and
country of citizenship.
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Demographic Information: We may receive demographic information, such as marital status, language preferences,
citizenship status, race and gender, when such information is included in documents, such
as government issued identification and tax forms and returns, that you share with
us.
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Biometric Information: As part of verifying your account, we may ask you to upload to one of our service
providers, Persona Identities, Inc. (“Persona”) a live selfie and a photo of your driver’s license or other government
issued identification. Persona processes these images, including by generating data about
your facial geometry (which may be considered biometric information in some jurisdictions)
for the purposes of verifying your identity and preventing fraud. This may involve
comparing the biometric information generated from your selfie to the biometric
information generated from your ID, as well as comparing the biometric information
generated from your images to the biometric information generated from other images.
Persona stores the biometric information and uses it to perform ongoing
identity-verification and fraud-prevention screenings and permanently deletes the data
when it is no longer needed to fulfill those purposes, or within three years of the
initial creation of the data, whichever is sooner. Persona relies on service providers to
process the biometric information and other information for these purposes. For more
information on Persona’s policies, please visit Persona’s Privacy Policy
(https://withpersona.com/legal/privacy-policy). Persona sends One the results of these screenings, but not the biometric information
used to perform them. One does not have access to the biometric information generated by
Persona to perform these services.
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Geolocation Information: We may receive geolocation information, which may include your precise geolocation, if you have location services enabled
in the ONE Apps (and with your consent, where required by applicable law), which we use
for certain features such as allowing you to find nearby ATMs and providing you with local rewards and deals. You can withdraw your consent at any time by
disabling location permission for the ONE Apps within your device settings.
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Financial Information: We receive financial information, such as bank account and routing numbers, debit and credit cards details, direct deposit
status, credit score and credit history, as well as, in certain circumstances, the
information described in each of the below sub-bullets, depending on the Services you
use.
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Linked Account Data: When you link your bank account to ONE, we receive financial information from your bank
or financial institution, such as your account balance, transaction history, and
information about the account owner.
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Financial Institution Information: When you apply for and use a third-party financial institution’s product or
service that we make available to you through the ONE Apps, we receive information related
to your account with the financial institution, such as your account balance, transaction
history, purchase history, and account status.
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Transaction Information: We may receive information about your transaction data, including payments into and out
of your ONE accounts, the date and time of the transaction, merchant or beneficiary
details, or ATMs associated with the transaction.
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Third Party Purchase Information: When you use ONE to pay for or finance purchases made with third parties, we receive information about your purchases and relationship with that third party, such as the products purchased (including SKU number), whether and how long you have been a
customer of such third party, and your purchase history with that third party.
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Employment Information: When you use certain Services, we receive information about your employment, such as
your employee identification number, employment status, employee benefits, start and end
dates, location of your workplace, payroll information, pay period, pay rate, shift
schedule, and job title, and you may choose to provide us with your username and password
for various payroll, time and attendance, or other human resources information systems,
which will enable us to receive information about your employment from such third
parties.
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Communications With Us: We receive the contents of your communications with us, such as when you provide survey
responses, questionnaire answers, participate in promotions, provide referrals, submit
inquiries on our Services, engage with customer support (e.g., through phone or automated
chat, which may be recorded for customer service, training and quality assurance
purposes), or participate in research.
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Social Media Information: When you interact with us through social media networks, we may receive information
about you such as your username or handle, the contents of your posts, comments and direct
messages you send to us. The data we receive is dependent upon your privacy settings with
the social media network.
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Job Applicant Information: We may receive certain information, such as personal identifiers, employment history, education history, skills, language
abilities, work permit status and sponsorship requirements, physical limitations and
special accommodations needed, and other information provided, by you and/or third
parties, such as job application platforms, your current employer, references, background
check providers and recruiters, when you apply for a job with us.
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Device and Usage Information: We receive information about the computers, phones, and other devices you use to
interact with our Services, including IP address (which may be used to determine general
location), hardware model, operating system information, mobile network information,
device performance information, device identifiers, cookie IDs, browser type, browser
language, internet service provider, and your network connection. We also receive
information regarding your use of our Services, including the electronic path you take to
our Services, through our Services and when exiting our Services, as well as your activity
information on our Services, including how long you spent on a page, access time,
information about your use of and actions on our Services, and your interaction with our
chat feature. This information is typically collected through tracking technologies, such
as cookies (both session cookies and persistent cookies), web beacons, embedded scripts,
and location-identifying technologies. To learn more about cookies and your ability to opt
out of certain advertising cookies, please visit the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. You may also use your browser settings to manage your cookie preferences. Please note
that if you disable certain cookies, you may not be able to receive or take full advantage
of the Services.
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Device Content: With your consent, we may access your device camera, photos and files. We do so to
scan or capture images, which may be used to provide Services, such as depositing checks,
peer to peer transactions, other transactions, and for fraud detection and prevention
purposes.
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Contacts: With your consent, we may receive information about your phone contacts, which may be
used to provide Services, such as peer to peer transactions, for fraud detection and
prevention purposes and to protect users’ accounts. You can update your
phone’s settings to stop sharing phone contacts information at any time.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use Personal Information for the following purposes depending on which Services you
use:
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To Provide and Customize Our Services To You: We use your Personal Information to provide our Services to you and personalize your
experience, including to assess your eligibility for and recommend new Services to you, to
manage your account(s), provide an integrated user experience across our Services, to
process transactions or payments, to operate and administer our rewards programs and other
promotions that may be made available to you through our Services (including to customize
your rewards and promotions), and to carry out our obligations arising from any
transactions you enter into with us (e.g., bank transfers, electronic money exchanges, ATM
withdrawals, and card purchases). We may link or combine your activities on our Services
with information from you or other parties to provide you with a personalized
experience.
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To Communicate With You: We use Personal Information to communicate with you about your account or use of our
Services, including about product updates, security alerts, technical notices, changes to
our policies and terms, to respond to you when you contact us, and to provide customer
service and support.
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To Advertise and Market Services: We use Personal Information to advertise and market our Services, as well as the
services of our affiliates and our partners, such as banks or financial institutions,
including through third-party advertising companies to serve you personalized
advertisements and offers, through SMS text with your consent, and through emails,
messages, and push notifications. You may unsubscribe from such emails and text messages
at any time: just follow the unsubscribe instructions contained in any such
communications. The advertisements, including rewards and deals, you see in the ONE Apps,
may be presented based on your geolocation information. We will your telephone number,
with third parties for their own marketing purposes.
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To Improve our Services and Perform Administrative Activities: We use Personal Information to operate, maintain, and improve our Services, including to
research and develop new products and services; enhance, improve, debug and analyze our
products and Services; manage our business relationships; and perform accounting,
auditing, marketing and other functions.
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Authentication, Integrity, Security, and Safety: We use Personal Information to verify your identity, to protect against fraud, to detect,
investigate, and prevent malicious conduct, fraudulent activity or unsafe experiences, to
address security threats, protect public safety, and to secure the Services.
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Job Applications: We may use Personal Information to assess job applications, including to communicate with
you about your employment application, to verify your information and carry out reference
checks and/or background checks and to assist you with obtaining an immigration visa or
work permit when requested by you.
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Legal Reasons: We may use Personal Information as needed, or when otherwise we deem it necessary
or appropriate, to comply with applicable laws, such as financial crime laws; respond to, investigate, or participate in valid legal
process and proceedings, including from law enforcement or government agencies; to enforce
or investigate potential violations of our Terms of Service, Privacy Policy, and other
policies; to detect, prevent, or investigate potential fraud, abuse, or safety and
security concerns, including threats to the public; to protect our, your or others’
rights, privacy, safety or property; and to resolve disputes.
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With Your Consent: We may also use your Personal Information for other purposes, with your consent.
4. THIRD PARTIES WHO MAY RECEIVE PERSONAL INFORMATION
We may share any of the categories of Personal Information set out in Section 2,
including for business purposes, with other brands, affiliates, subsidiaries or other
entities in our family of companies and to the following categories of third
parties:
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Vendors: We work with service providers to provide services to us, such as identity verification, risk detection and fraud prevention, customer service, email
delivery, processing and authorizing payments, facilitate ownership of account transfers,
and to support and improve our Services and technical infrastructure, and may share
Personal Information with such service providers.
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Authorized Third Parties: We may share Personal Information with third parties who you authorize us to share your
Personal Information with, such as your bank or ONE users who you have designated for
purposes such as customer referrals or managing shared pockets.
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Other Users: We may share Personal Information, such as your name, contact information or
relationship with us, with other ONE users to facilitate peer to peer transfers. We
will never share your payment card information or account numbers with other ONE
users.
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Your Employer: We may share your Personal Information, such as your name, employee identification
number, employee benefits, place of employment, and information related to your paycheck,
with your employer to facilitate providing the Services. We do not share information about
your purchases or spending, the transactions to or from your bank account, the balance of
your account, or information regarding your individualized financial situation with your
employer.
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Financial Services Partners. We partner with third-party financial services companies whose services or products may
be accessed through our Services. If you choose to accept their services, we may share
your Personal Information with such third-party financial services companies. This
exchange of information is necessary to maintain business operations and to provide the
ongoing services you've requested.
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Credit Bureaus: When you use certain Services, we share Personal Information with credit
bureaus.
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Marketing, Advertising, and Analytics Partners: We may use third-party marketing, advertising, and business analytics partners,
including Google Analytics, to deliver customized advertising on other websites or
services you may use, as well as to provide advertising-related services such as
reporting, attribution, analytics and market research. Click here to learn more about Google Analytics. We participate in interest-based advertising
and use third-party advertising companies to serve you targeted advertisements based on
your browsing history. Typically, though not always, the information used for
interest-based advertising is collected through third-party tracking technologies, such as
cookies, web beacons, embedded scripts, and location-identifying technologies, which
recognize the device you are using and collect information, including device and usage
information, as described in Section 2. We and our third-party partners use this
information to make the advertisements you see online more relevant to your interests, as
well as to provide advertising-related services such as reporting, attribution, analytics
and market research. We may permit third-party online advertising networks, social media
companies and other third-party services, to collect information about your use of our
Services over time so that they may provide services to us, play or display ads on our
Services, on other websites or services you may use, and on other devices you may use. We
may also allow third parties, such as social media platforms, to collect information from
our website visitors through a first-party pixel and such collection of information would
be governed by the privacy policies of the company who provides the pixel.
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Change of Control: We may also share Personal Information with actual or prospective acquirers, their
representatives and other relevant participants in the event of a corporate restructuring
(e.g., merger, sale, joint venture, or other disposition) or change in control involving
all or a portion of our business or assets, including in connection with bankruptcy or
similar proceedings.
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Legal Reasons: We may share Personal Information as needed, or when otherwise we deem it necessary or
appropriate, to comply with applicable laws, including financial crime laws; respond to,
investigate, or participate in valid legal process and proceedings, including from law
enforcement or government agencies; to enforce or investigate potential violations of our
Terms of Service, Privacy Policy and other policies; to detect, prevent, or investigate
potential fraud, abuse, or safety and security concerns, including threats to the public;
to protect our, your or others’ rights, privacy, safety or property; and to resolve
disputes.
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With Your Consent: We may also share your Personal Information with other third parties, with your
consent.
5. U.S. STATE RESIDENTS’ PRIVACY RIGHTS AND CHOICES
If you are a resident of certain U.S. states, you may have certain rights to manage your
Personal Information (other than Personal Information that we collect and process subject to
GLBA) under U.S. state laws, including the California Consumer Privacy Act of 2018 as
amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), as set forth below:
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Transparency: The CCPA requires that we notify consumers at or before the collection of their
Personal Information of the categories of Personal Information we have collected about
consumers in the preceding 12 months, the categories of sources from which such Personal
Information is collected, our purposes for collecting such Personal Information, whether
such Personal Information is “sold” or “shared”, and the length of
time we intend to retain each such category of Personal Information, or if that is not
possible, the criteria we use to determine our retention periods, among other information.
This Privacy Policy contains such information. Please read it, as well as any other terms
that are provided to you at or before the collection of your Personal Information,
carefully.
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Access: Right to request access to the categories of your Personal Information that we have
collected, disclosed, or “sold”, as well as the specific pieces of your
Personal Information that we have collected, the categories of sources from which we have
collected such Personal Information, the categories of third parties to whom we have
disclosed, “sold” or “shared” such Personal Information, and our
purposes for collecting, “selling” or “sharing” such Personal
Information.
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Correction: Right to correct inaccurate or incomplete Personal Information in certain
circumstances. Please note, however, that information related to your
creditworthiness is maintained by the credit bureaus. If you find that there is an error
or you want to dispute the information found in your credit report, please contact the
credit reporting bureaus: Experian, Transunion, and Equifax.
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Deletion: Right to delete Personal Information about you, subject to certain exceptions.
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Opt Out of Processing (“Sales”, “Sharing” and Targeted
Advertising): We do not sell your Personal Information in the conventional sense (i.e., for money).
However, as is common practice among companies that operate online, we may use advertising
and analytics services that are intended to analyze your interactions with our Services,
based on information obtained from cookies or other trackers, including for delivering
advertising to you (such as interest-based, targeted, or cross-context behavioral
advertising). With respect to your interactions on www.ONE.app and the One Apps we may disclose certain of this information, including device and usage
information, to third parties, and such disclosure may be considered a “sale”
and/or “sharing” of Personal Information under various state laws. You can opt
out of the processing of your Personal Information for purposes of targeted advertising
and the “sale” or “sharing” of your Personal Information in a
frictionless manner by implementing the Global Privacy Control (“GPC”) in your
browser. For instructions on how to download and use GPC, please visit https://globalprivacycontrol.org. You can also opt out of the processing of your Personal Information for purposes
of targeted advertising and the “sale” or “sharing” of your
Personal Information by clicking “Your Privacy Choices”on www.One.app. Your opt-out decision is specific to a particular device and browser. If you use a
different browser or device, you will need to opt out on each. Additionally, if you clear
your cookies you will need to opt out again. Please note that even if you opt out of the
“sale” and “sharing” of your Personal Information, we may still
use essential cookies to track your use of our Services, including for purposes of
operating the Services and for legal and security reasons, such as detecting and
preventing fraud. We do not have actual knowledge that we “sell” or
“share” the Personal Information of consumers under 16 years of age.
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Limit the Use and Disclosure of Sensitive Personal Information: We may receive certain information that is considered sensitive under the CCPA,
such as Social Security and driver’s license numbers, race and citizenship status,
biometric information and precise geolocation, as described in more detail in Section 2
above. We only process such sensitive Personal Information in order to provide the
Services, or as otherwise permitted by the CCPA, such that we are not required to provide
the right to limit the use or disclosure of sensitive Personal Information.
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Non-Discrimination: The right to not be discriminated against for exercising any of these
rights. However, please note that if the exercise of these rights limits our ability
to process Personal Information (such as in the case of a deletion request), we may no
longer be able to provide you our products and Services or engage with you in the same
manner.
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Shine the Light: California residents who have an established business relationship with us have the
right to know how their information is disclosed to third parties for their direct
marketing purposes under California’s “Shine the Light” law, (Civ. Code
§1798.83). We do not share Personal Information with third parties for such purposes.
To exercise your rights, please submit a request by contacting us
at [email protected], 1-855-830-6200 or writing to us at: ONE Finance, Inc.,
P.O. Box 513717, Los Angeles, CA 90051. We will acknowledge your request within 10 business
days of receipt, and within 45 calendar days of receipt we will either provide a substantive
response or notify you of an extension period of up to an additional 45 calendar days and a
reason therefor. You can also correct and delete certain information directly in the ONE
Apps.
Before processing your request, we will need to verify your identity and confirm your
residency. To do so, we will generally either require the successful authentication of your
account, or the matching of sufficient information you provide us to the information we
maintain about you in our systems. This process may require us to request additional
Personal Information from you, including, but not limited to, your email address and phone
number.
In certain circumstances, we may decline a request to exercise the rights described above,
particularly where we are unable to verify your identity or locate your information in our
systems or where no U.S. state laws apply to our processing of your Personal Information
because it is collected and processed subject to GLBA. If we are unable to comply with all
or a portion of your request, we will explain the reasons for declining to comply with the
request in our substantive response.
You may designate an authorized agent to submit your verified consumer request by providing
written permission and verifying your identity, or through proof of power of attorney. The
authorized agent must provide a letter signed by you confirming the agent has permission to
submit a request on your behalf or must provide sufficient evidence to show that the
authorized agent has been lawfully vested with power of attorney. For security purposes,
where authorized agent does not have power of attorney, we may need to verify your identity
and confirm directly with you that you have provided the authorized agent permission to
submit the request. We may deny a request in the event we are not able to verify the
authorized agent’s authority to act on your behalf. Please note that for privacy and
security reasons, we will direct future communications to the consumer on whose behalf the
request was made.
If we deny your request, some states afford you the right to appeal our decision. You may
do so by contacting us at [email protected], 1-855-830-6200 or writing to us at: ONE Finance, Inc., P.O. Box 513717, Los Angeles,
CA 90051. Within 45 days of receipt, we will notify you in writing of our decision and the
reasons therefor.
6. RETENTION
We may retain Personal Information for as long as necessary for the purposes described in
this Privacy Policy, or as otherwise permitted or required by law. In determining our
retention periods, we use the following criteria: our relationship with you, the choices you
have made with respect to your Personal Information, the permissibility of retention
(including for backup and archival purposes), our legal and regulatory rights and
obligations (including with respect to the prevention of fraud and abuse).
We do not delete your Personal Information upon deactivation of your account. Although your
deactivated status is reflected promptly in our user databases, we may retain your Personal
Information for a variety of purposes, including legal compliance, backups and archiving,
prevention of fraud and abuse, and analytics. Upon deactivation of your account, you will no
longer receive emails from us and links to third-party financial accounts and services will
automatically terminate. If you have a money transfer transaction pending at the time you
deactivate your account, your link to this service from us will terminate but your pending
transfer will continue to completion and your bank account will remain open.
7. CHILDREN’S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit
Personal Information from children under the age of 16. If you believe that a child under
the age of 16 may have provided us with Personal Information without parental consent,
please contact us.
8. THIRD-PARTY PRIVACY PRACTICES
This Privacy Policy covers our privacy practices only. This Privacy Policy does not apply
to the practices of third parties, including third parties with whom we partner. Third-party
websites, services and applications are governed by each such third party's privacy
policy, which we encourage you to read carefully. We are not responsible for the privacy
policies and practices of third parties, and we are not responsible for the failure of third
parties to honor their privacy obligations. By including a link to a third-party website or
application, we do not endorse or recommend any products or services offered or information
contained therein. If you decide to visit a third-party website or application via a link
contained on the Services, you do so at your own risk.
9. UPDATES TO THIS PRIVACY POLICY
When we make changes to this Privacy Policy, we will change the date at the beginning of
this document. If we make material changes to this Privacy Policy, we will notify
individuals by either email to their registered email address, by prominently posting within
the ONE Apps, or through other appropriate communication channels. All changes shall be
effective from the date of publication unless otherwise provided.
10. CONTACT US
If you have any questions or requests in connection with this Privacy Policy or other
privacy-related matters, or if you need assistance exercising any of the choices described
in this Privacy Policy, contact us at [email protected], call us at:
1-855-830-6200 or write to us at: ONE Finance, Inc., P.O. Box 513717, Los Angeles, CA 90051