When any of these activities occur, your Personal Information may be collected, processed, and/or shared by Affiniti. This Policy is designed to explain how we collect, use, store, retain, disclose by transmission, disseminate or otherwise make available (collectively “Process”) your Personal Information and related information. Please be aware that the Affiniti Service is integrated with certain third parties (“Third-Party Service Providers”).
What Is Personal Information?
“Personal Information” is any information that relates to, and can be used to identify, you. It includes, but is not limited to, name, date of birth, home address, billing and shipping address, email address, photograph, government-issued identification information (such as driver’s license number, social security number or passport number), financial information (such as bank account details, payment card numbers, credit reports), authentication details, and IP address or other device information. Personal Information does not include information that does not identify a specific person or information that is publicly available through open databases.
Personal Information We Collect.
Our ability to provide all features on the Site and Affiniti Service to you may be conditioned on you providing us with your Personal Information. This Personal Information may be sensitive in nature.
When you apply for an Account, Personal Information we collect may include your legal name, social security number, phone number, home and/or business address, employment information, and other identifying information. When your Company applies for an Account, we may collect additional information such as ownership, employment information, phone numbers, contact information, financials, spending, organizational documents and details, banking information, including real-time financial accounting information provided to and by third parties and linked accounts; credit information about the Company; and any information related to the compliance and/or enforcement with respect to federal and state anti-money laundering and Know Your Customer/Business laws, banking laws, and regulations (collectively “Application Information”).
In addition to collecting information about your identity, we may also collect information about your Transactions, such as amount, location, entity, and payment status (“Transaction Information”).
When you interact with our support email, provide Feedback, or communicate with us, we collect any other Personal Information you submit (“Support Information”).
An Admin User may be granted administrative rights in your Account, including the right to allow more than one individual User from your organization to access your Affiniti Account. The Admin User may view all your Transactions and deactivate your Account in its sole discretion without recourse to you.
When you or your Company ask us to integrate your third-party accounts into the Affiniti Service, we use Third-Party Service Providers to access, process, and collect information about your and the Company’s financial and purchase activity. Any time you link an account from a Third-Party Service Provider, we receive real-time data and information associated with the linked accounts including account names, transactions (and transaction history), account balances, bank routing numbers, and unique identifiers (“Account Information”).
When you interact with our Site, you will submit or create data, passwords, usernames, PINs, other login information, materials, rewards, and other content through our Site (“User Content”).
Why We Collect Information.
In General, the Personal Information we collect from you is reasonably necessary to provide you with the Affiniti Services. We use your Personal Information to: comply with relevant financial regulations; process applications and onboard you; prevent or mitigate financial crimes such as fraud or anti-money-laundering; manage our products and Services, including product and service testing and modeling; conduct a comprehensive risk analysis and risk report; communicate information about your Affiniti Account to Third-Party Service Providers and vendors; communicate information about any of your transactions; assess creditworthiness and evaluate whether you have the ability to make payments owed to us on time; and investigate inquiries or complaints.
We also collect your Personal Information to customize offers to you, tailor our services or products for you, conduct marketing functions, maintain complete and accurate contact information, and fulfill our legal obligations with respect to the Bank Secrecy Act, anti-money laundering, counterterrorism, and other regulations. Specifically, we use your email and phone number to send you email marketing, text updates, and to respond to your queries on our Site, as applicable. We may share this Personal Information with hosting, CRM, email marketing, and SMS service providers.
We also anonymize your Personal Information as part of and for our own processes and procedures for market research and new product development. To the extent permitted by law and without your express permission, we may also permit our Third-Party Service Providers or affiliates to use your Personal Information as set forth below. We do not sell or share your Personal Information, as such term is defined by the California Consumer Privacy Act.
We collect Application Information to determine whether you qualify for access to the Affiniti Services and to administer your Account. We also use your Application Information to inform you about new products or services.
We collect Account Information as you direct to provide services and integrations that leverage the support of Third-Party Service Providers and to determine your eligibility for an Account.
We collect User Content to authenticate your access to the Site and Affiniti Service, and to provide integrations with Third-Party Service Providers.
We collect Transaction Information to administer and secure the Affiniti Service, to improve our Site, and to fulfill our contractual obligations with your Company and our Third-Party Service Providers (such as providing you with rewards and rebates).
We collect Support information to assist you in using the Affiniti Service, and to improve, secure, and otherwise provide the Site.
How We Collect Personal Information.
Directly From You. Before you open an Account, we collect Application Information. When you use the Affiniti Services, you provide us with Support Information and User Content.
We collect this information either (1) in person; (2) through documentation you provide to us; (3) telephone calls with you or Third-Party Service Providers; (4) e-mails with you or Third-Party Service Providers; (5) the access provided to you on our websites and/or applications; (6) research using Third-Party Service Providers and (6) ongoing communications with you or your Company’s employees or associated persons. We may also collect your Personal Information from individuals who are listed as associated with your Affiniti Account, public sources, yours or our advisor(s), introducers, referrers, brokers, credit reporting agencies, and other reporting organizations or exchanges that serve the financial services industries.
From Third Parties. When utilizing an integration, we collect Account Information from Third-Party Service Providers. If you request access to the Affiniti Service, we also obtain credit information from a credit checking service provider.
Automatically. We automatically collect Transaction Information and some User Content when you use the Affiniti Service and your card. Your Device may provide us the IP address of the computer or Device you use to connect with us online.
Disclosure Of Your Personal Information.
Third-Party Service Providers, Subprocessors, and Consultants. Affiniti engages certain third-party service providers, subprocessors, and consultants to carry out certain data processing functions to provide the Services. These third parties are limited to only accessing or using your Personal Information to provide services to us and must execute agreements to appropriately safeguard your Personal Information. We do not disclose your Personal Information to non-affiliated service providers. We disclose your Personal Information to the following categories of Third-Party Service Providers:
- Analytics: User Content, Account Information, Cookies, Transaction Information
- Security: All
- Customer Service, Payment Processor, OFAC, Rewards: Account Information, Transaction Information, Support Information, User Content
- Credit Checking, Customer Identification, Know Your Customer, Know Your Business: Application Information
- CRM: Application Information, Account Information
- Sponsor Bank: Account Information, Application Information, Transaction Information
- Hosting: All
Compliance with Legal Obligations. We may disclose your Personal Information to a third party if (i) we reasonably believe that disclosure is compelled by applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other Users, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing a death or serious bodily injury. If Affiniti is required by law to disclose any Personal Information of you or your end-user, we will notify you of the disclosure requirement, unless prohibited by law. Further, we may object to requests we do not believe to be valid.
Aggregated or De-Identified Data. Affiniti may share de-identified and/or aggregated Personal Information and Transaction Information with third parties for a number of purposes, including research, internal analysis, analytics, and any other legally permissible purpose.
By supplying your Personal Information to Affiniti either directly or indirectly, you consent to your information being transferred across international borders to Affiniti and its affiliates, Third-Party Service Providers, and agents. Vendors and other outside contractors we engage are subject to our contractual requirements for safeguarding Personal Information.
Affiniti strives to ensure that any information collected from you or gathered about you is complete, accurate and up to date. We take reasonable steps to ensure we meet this goal by, among other things, requesting information from you on an ongoing basis, conducting research through third party services, researching publicly available information and searching for media associated with your Company.
We use certain physical, organizational, and technical safeguards designed to protect Personal Information submitted to us, and we employ appropriate measures to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. These measures may include, among others, physical access security, administrative security measures, data encryption, firewalls, and other appropriate technologies. Affiniti reviews and enhances its security systems as necessary.
Notwithstanding Affiniti’s efforts, no security measure is perfect or impenetrable and no method of transmission over the internet or electronic storage is 100% secure. Therefore, Affiniti cannot guaranty complete security of the transmission or storage of your Personal Information. It is important that you maintain the security and control of your account credentials, and not share your password with anyone. We offer our Users two-factor authentication which is designed to protect their account.
Cookies are small data files that are stored in your device memory or on your hard drive when you visit a website. Cookies, including beacons, pixels, or trackers, may be used as a mechanism to recognize you, record behavior, and/or customize your experience with the Site. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, location data, and information about your usage of the Service and Site, including pages viewed and interactions. Cookies can also be used to monitor Site activity, mitigate risk, measure the effectiveness of promotions and prevent potential fraud. If you choose to disable cookies, your use of the Site may be limited or otherwise affected. By using this Site, you permit us to collect and use your information related to Site access and device activity.
We place two kinds of cookies on the Site: essential and non-essential. Essential cookies help us operate the Site by authenticating you, tracking your session, and other essential Site functions. You cannot opt out of Essential cookies and the Site may not work if you disable them. We use information from essential cookies, for example, to ensure that the Service functions properly, to determine how many Users have visited certain pages or opened messages, or to prevent fraud.
You may stop or restrict the placement of non-essential cookies and other similar technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. Alternatively, for some devices you may use your Device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each Device. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site or Service.
By using the Site, you consent to the placement of cookies, beacons, pixels, trackers, and similar technologies in your browser and on emails in accordance with this Policy.
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the All About Do Not Track website: http://allaboutdnt.com.
Our Website May Be Linked To Other Websites.
We may use third party analytics vendors to evaluate and provide us with information about your use of the Site and/or the Affiniti Service. We do not share your information with these third parties, but these analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Site.
You may also access certain third party services through our Site, including, but not limited to Patriot Bank, N.A., or Finicity. The privacy policies or your agreements with these Third-Party Service Providers will govern their collection, use, disclosure and processing of your Personal Information; read more about Patriot Bank’s Privacy Practices here and Finicity’s Privacy Practices here.
The Site And Affiniti Service Are Not Directed At Persons Under The Age Of 18 Years Old.
The Affiniti Service is intended for business use only and is not directed at persons under the age of 18. If you are a parent or guardian and believe we may have collected information about a person under the age of 18, please contact us at the email address or phone number set out at the beginning of this Policy. If we determine that we have inadvertently collected Personal Information from a person under the age of 18, we will promptly delete such information from our records to the extent permitted by applicable law.
The "Last Updated" date at the top of this page indicates when this Policy was last revised. From time to time, Affiniti may make changes to this Policy, so we encourage you to check back and review it regularly to ensure you are aware of current practices. If you disagree with the changes, you must stop your use of the Affiniti Service and discontinue use of our Site. Your continued use of the Affiniti Service and/or the Site following the effective date of any change, constitutes your consent to any modification to this Policy.
If you have any questions about this Policy, or you want to make a complaint regarding any breach of your privacy by us, you want to correct or update your Personal Information in our possession, or you want to opt out of collection of Personal Information if such right is provided by applicable law, you may contact us at firstname.lastname@example.org. You may also write us at:
Affiniti Finance, Inc.
222 Broadway Ave
New York, NY 10038