2.0 Customer Privacy Rights
Customers have rights and choices when it comes to how customer personal data is collected, stored, used, and shared.
Customers have the right to request a copy of the personal data we have collected about customers. customers also have the right to ask us to delete personal data we have collected about them. We will not deny customers services, charge customers different prices, or provide customers with a different level of service solely for exercising privacy rights.
If a request is made to see or delete personal data, we will need to verify who customers are prior to doing so. If we cannot verify a customer’s identity, we will not be able to fulfill the request.
If customers request that we delete personal data or close their account, we will still need to keep some personal data on file so we can:
- Provide goods or services customers requested, complete a transaction or comply with our promises to customers in the User Agreement or other contract customers have with us
- Detect and prevent fraudulent or illegal activity
- Comply with laws
3.0 Collecting Personal Data and How It Is Shared
Customers may choose to limit the personal data customers provide when our apps or services request it. To help make choices that are right for customers, it is important to understand that personal data helps us provide a richer, more personalized experience for customers. Also, some personal data is required for our services to function at all.
For example, creating an account with us. If customers choose not to provide information that is required for an account to function, like a customer’s name and email address, we will not be able to create an account for customers.
Customers may be able to manage how personal data is collected, used, and shared by any third-party source. Read the third parties’ privacy policies to see the choices they offer customers. We share customer information for a number of business purposes: With the biller of the application customers are using and as directed by that biller (such as with another third party if directed by customers); To enforce any contract with customers; With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or developers; With a customer’s connected financial institution(s) to help establish or maintain a connection they’ve chosen to make; If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena); In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy); Between and among Highline and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership; As we believe reasonably appropriate to protect the rights, privacy, safety, or property of customers, developers, our partners, Highline, and others; or For any other notified purpose with customer consent.
We may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify customers personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.
We do not sell or rent personal information that we collect.
4.0 How and Why We Share Personal Data
We do not sell customers’ personal data. However, we may share personal data with third-party service providers of Highline. Sometimes we share the personal data we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations.
We may share personal data with:
- Service providers that help us with processing payments, identity validation, marketing, research, compliance, audits, corporate governance, communications, and security
- Financial institutions, such as banks we partner with to offer joint products
- Courts, governments, regulators and law enforcement when accompanied by a subpoena or other legal documentation that requires Highline to respond
- People involved in a transaction, such as other users or billers and their service providers.
- Third parties that customers asked us to connect with, such as other financial services
- Other third parties to:
- Comply with laws
- Investigate or enforce violations of our user agreement
- Facilitate a merger, purchase, or sale of part or all of our business
- Comply with card association rules
- To prevent physical harm or illegal activity
5.0 How We Use Tracking Technologies
Customers can disable or decline some cookies for our sites and services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.
Some web browsers have an optional setting called “Do Not Track” (DNT) that lets customers opt-out of being tracked by advertisers and some third parties. Because many of our services will not function without cookies or similar tracking technologies, we do not respond to DNT settings.
6.0 Security of Personal Data
Helping to keep customers’ personal data safe against loss, misuse, unauthorized access, disclosure, and alteration is our top priority.
To protect customer personal data, we use technical, physical, and administrative security measures that include:
- Data encryption
- Physical access controls at our data centers
While we protect our systems and services, customers are responsible for keeping password(s) and account information private. Customers are also responsible for making sure personal information is accurate and up to date.
If a customer’s account is closed, we may keep personal data and other information as required by law and according to our data retention policy. If we do, we will continue to handle it as we describe in this statement.
7.0 Changes to This Statement
Changes will be made to this privacy statement to help us stay up to date with changes to our business and the most current laws. After a new version is published, we will collect, store, use, and protect customers personal data as we outline in that revised statement.
If the new version reduces customer rights or increases customer responsibilities, we will post it on the Policy Updates or Privacy Statement page of our website at least 21 days before it becomes effective.
We may notify customers about these changes through email or other communications.
8.0 Privacy Notice
|FACTS||WHAT DOES HIGHLINE 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 number and Date of BirthFull Name and AddressEmailWhen you are no longer our customer, we continue to share your information as described in this notice.|
|How?||All financial companies need to share Highline personal information to run their everyday business. In the section below, we list the reasons financial companies can share their personal information; the reasons chooses to share; and whether you can limit this sharing|
|Reasons we can share your personal information||Does Highline share this information?||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
|For our marketing purposes —|
to offer our products and services to you
|For joint marketing with other financial companies||No||No|
|For our affiliates’ everyday business purposes —|
information about your transactions and experiences
|For our affiliates’ everyday business purposes —|
information about your creditworthiness
|For nonaffiliates to market to you||No||No|