LEGAL DOCUMENTATION

Dwolla Privacy Policy

Last Updated: December 30, 2022

Dwolla, Inc. (“Dwolla”) is committed to protecting your privacy and earning your trust. This Privacy Policy discloses our privacy practices for personal information we collect when you use or access our products, services, features, or content through any Dwolla website (including https://www.dwolla.com), collectively the “Dwolla Sites”), any Dwolla application or service (“Dwolla Services”), or when you apply or express interest in employment with or are employed by Dwolla (“Dwolla Employment”).

We may, in our sole discretion, change this Privacy Policy from time to time by posting a revised version at www.dwolla.com/legal/privacy. If we make any material change to this Privacy Policy, we will notify you by posting a notice on www.dwolla.com/legal/privacy prior to the change becoming effective and may also elect to send you an email notifying you of the policy modifications.Your access and use of the Dwolla Sites, Dwolla Services, Dwolla Employment, and submission of data to us, constitutes your acceptance of this Privacy Policy and consent to the uses set forth in this Privacy Policy.

How does Dwolla collect my personal information?

We collect your personal information in the table listed above from various sources. For example, we collect and obtain information:

• Directly from you. We collect personal information you provide to us, such as when you create an account, communicate with us via phone, email, online video, online form, or in any other way in connection with Dwolla Services or Dwolla Employment.
• From third parties. We collect personal information stored with third parties that you choose to provide to Dwolla, such as information you may have provided to a third party application that you authorized to provide information to Dwolla. By linking your third party accounts, you authorize Dwolla to have access to this information and you agree that Dwolla may collect and use this information in accordance with this Privacy Policy. We may also collect your personal information from third parties such as financial institutions, data aggregators, credit bureaus, law enforcement, identity verification and fraud prevention services, pre-employment background check companies, social media platforms, as well as advertising, marketing, and analytics companies.
• When you visit the Dwolla Sites. We use analytics software when you visit the Dwolla Sites. Our analytics providers may also use analytics software to collect information on our behalf. For more information, see how Dwolla uses cookies, web beacons, and similar tracking technology below.

How does Dwolla use the personal information that it collects?

Over the past twelve months, and on an ongoing basis, we may use the information we collect about you to do the following.

• To research, develop, customize and improve your experience with the Dwolla Sites and Dwolla Services as well as to improve our customer database to determine customer demand.
• Provide the Dwolla Services to you.
• Validate your account.
• Notify you about your account activity.
• Process transactions and collect fees.
• Provide customer support and resolve disputes.
• Verify your identity, contact, and account information.
• Identify, prevent, and report potentially prohibited, fraudulent, or illegal activities.
• Notify you about important changes to the Dwolla Services and/or Dwolla’s terms and conditions.
• To promote, market, and advertise the Dwolla Services or Dwolla Employment.
• To notify you about your payment and/or payment request.
• We may also provide you with news, offers, and information about the Dwolla Services based on your communications preferences.
• Comply with legal and regulatory obligations under applicable law or any other purpose that we disclose to you in the course of providing the Dwolla Sites or Dwolla Services.
• We may also merge or otherwise combine your information in furtherance of the purposes above.

If you apply for or are employed by Dwolla, we may also use your information for the following purposes:

• To develop and improve your experience with Dwolla Employment including to generate analytics.
• To process your application, assess your qualifications or to communicate with you about Dwolla Employment.
• To administer pay and other benefits that are a part of your employment package.
• To provide general business management and operation.
• For accounting, financial reporting and business planning.
• To ensure your safety and the security of Dwolla-held information.
• To perform pre-employment background checks where permitted by law.
• To comply with legal and regulatory obligations under applicable law or any other purpose that we disclose to you in the course of providing Dwolla Employment.
• For any purpose as reasonably required by Dwolla in connection with your application for and during the course of your employment with Dwolla.
• We may also merge or otherwise combine your information in furtherance of the purposes above.

How does Dwolla disclose my personal information?

Over the past twelve months, and on an ongoing basis, we may share identifiers, government issued identifiers, demographic data, geolocation data, inferences, financial information, commercial information, audio, electronic, visual information, internet activity, and professional or employment-related information for the following business purposes:

• When you send or receive money using the Dwolla Services, we will provide the other party to the financial transaction appropriate details about the transaction.
• If your payment to another Dwolla user fails, we may provide that user with details of the unsuccessful payment.
• With financial institutions and other partners that are part of the payment process.
• With our service providers to provide, maintain, and improve Dwolla Services and Dwolla Employment, including for fraud prevention, identity verification, auditing, marketing, advertising, analytics, maintenance, security, or for other related business purposes as determined appropriate by Dwolla. We strive to contractually prohibit these service providers from retaining, using, or disclosing your personal information for any purpose other than performing agreed upon services for us.
• To the extent analytics software is used to improve the functionality of the Dwolla Sites, analytics providers may receive information about your use and interaction with the software in order to assist Dwolla with providing and improving the Dwolla Sites and the Dwolla Services.
• If you are offered or accept Dwolla Employment we may share your information with credit bureaus, pre-employment background check providers.

Other than as stated in this Privacy Policy, Dwolla does not disclose, share or sell any of your personal information to third parties without your consent. Please note that third parties, such as merchants that you pay and third party websites that you visit, have their own privacy policies. Dwolla is not responsible for the policies and practices of such third parties and we encourage you to review their privacy policies.

What are other circumstances when Dwolla may disclose my personal information?

• Dwolla may release information to third parties upon your request. For example, you may authorize a Dwolla integrating partner to access your personal and business information.
• Dwolla may release your information to governmental, legal, or regulatory authorities if we believe disclosure is reasonably necessary to comply with any applicable law, legal process, or government request; to investigate or bring legal action against someone who may be violating our rights, our terms and conditions, or the rights of others; or to protect the safety and security of Dwolla, our users, or the public.
• Dwolla may also share individual personal information and aggregated, non-personally identifiable information with third parties who provide analytics, marketing and advertising services. For more information, see how Dwolla uses cookies, web beacons, and similar tracking technology below.
• Dwolla may also release your information to an acquirer if we are involved in a merger, acquisition, or sale of all or a portion of our stock or assets. If this occurs, you will be notified of any change to this Privacy Policy, as well as any choices you may have regarding your personal information.
• Dwolla also uses Track Technologies, Inc. dba Abound (“Abound”) to provide tax or financial related services and are for informational purposes only and provided to you AS IS and without warranty or guarantee. Consult a tax or legal professional or provider before filing your annual tax returns. By using the Dwolla Services, you grant Dwolla and Abound the right, power, and authority to access and transmit your personal and financial information that you provide to Dwolla. You agree to your personal and financial information being transferred, stored, and processed by Abound in accordance with the Abound Privacy Policy.

Does Dwolla sell or share my personal information?

Dwolla does not “sell” or “share” any of your sensitive personal information (e.g. social security number, driver’s license number, financial information, etc.). Dwolla only uses your sensitive personal information to the extent necessary to provide the Dwolla Services or Dwolla Employment.

Over the past twelve months, and on an ongoing basis, we and our third party providers use cookies and similar tracking technologies that allow us and our social media, marketing, analytics, and advertising partners to collect certain personal information, such as identifiers, inferences, and internet activity, about visitors to the Site. This information may be used for various purposes, including analytics, marketing, advertising, and to provide you with customized content and experiences. Some transfers of such personal information are considered “selling” or “sharing” under applicable law (e.g. CCPA). This may include the use of cookies and similar tracking technologies.

Will Dwolla refuse service, charge me a different rate, or provide different quality service if I decline to provide certain data?

In order to use Dwolla Services to transfer funds through the U.S. monetary system, a user must comply with applicable federal laws and rules. These applicable laws and rules may require the disclosure and retention of information regarding the identity of senders and recipients of funds.

Dwolla will not discriminate against you for exercising any rights you may have under the California Consumer Privacy Act (“CCPA”) or any other applicable law or rule. Dwolla does not base its prices or the quality of its services on the exercise or non-exercise of legal privacy rights.

How does Dwolla use cookies and web beacons?

As reflected above, Dwolla and its advertising, marketing, analytics and fraud prevention providers (e.g. Google Analytics) use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, track users’ movements around the website, and to gather information about Dwolla’s user base, and we may receive such information on an individual and aggregated basis from such providers.

We use cookies to provide you with a personalized experience by recognizing you when you return to the Dwolla Sites; better understand our users by tracking how they use the Dwolla Services; improve the design and content of the Dwolla Sites by tracking how users interact with the Dwolla Sites; and identify and prevent fraudulent activity. You can change your browser settings, send an opt out preference signal, or select the “Do Not Sell or Share My Personal Information” link at the bottom of the webpage.

We may gather certain information about our website visitors automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Services.

We may partner with a third party to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you do not want your information to be used for the purpose of serving you interest-based ads, you may opt-out by selecting the “Do Not Sell or Share My Information Link below. This does not opt you out of being served ads and you will continue to receive generic ads.

The Dwolla Sites may include social media features that allow you to “Like” or share content on third party sites. These features may be hosted by the third party sites or the Dwolla Sites, and may collect your IP address, the Dwolla Site page you are visiting, and may set a cookie to enable the feature to function. This Privacy Policy does not apply to third party cookies, web beacons, social media features and widgets (such as the Facebook Like button), or other tracking technologies used by third parties without connection to Dwolla or websites you may travel to upon following hyperlinks on Dwolla’s Sites. Dwolla is not responsible for the privacy policies and practices of such third parties.

How do I opt out of receiving promotional emails from Dwolla?

If you prefer not to receive promotional emails from Dwolla, click on the unsubscribe link at the bottom of any promotional email that we send you to remove your email address from future promotional email campaigns. If you have difficulty with the unsubscribe process, contact us at privacy@dwolla.com.

What security precautions does Dwolla take to protect me?

We have security measures in place to protect your personal information, including the use of industry-standard data encryption technology and internal policies and restrictions regarding the storage of and access to your personal information. Please note that no data transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. Dwolla’s servers and business operations are entirely located in the United States. If you have any questions about the security of your personal information, you can contact us at security@dwolla.com.

How do I update my information?

Dwolla Clients should notify Dwolla immediately of a change in your information by contacting support@dwolla.com. If you access your Dwolla account through a Dwolla Client, you must contact the Dwolla Client to update your account information. Due to regulatory requirements, Dwolla is unable to accept direct requests to modify your data related to your Dwolla account.

How long does Dwolla maintain my personal information?

We retain your personal information for so long as we are providing the Dwolla Services to you or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Dwolla Services directly to you, and even if you close your Dwolla account, we retain some of your personal information in order to comply with legal and regulatory obligations of Dwolla and its Financial Institution Partners. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep personal information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep personal data, including, data involving Dwolla Employment, we do so in accordance with any limitation periods and record retention obligations that are in line with recommended practices and imposed by applicable law.

What about the privacy of children?

Dwolla is a general audience website. Dwolla does not knowingly collect any personal information from anyone under the age of 13. Dwolla does not knowingly sell or share personal information from anyone under the 16 years of age.

Rights for Certain Consumers

If you are a resident of a state that has adopted privacy regulation, you may have additional certain rights regarding your personal information. This includes:

• Right to Know – You may have the right to know what personal information we collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
• Right to Access and Data Portability – You may have the right to request a copy of the personal information that we collected about you during the 12 months before your request.
• Right to Deletion – You may have the right to request that we delete information that we collected from you and retained.
• Right to Opt Out of Selling or Sharing – You may have the right to opt-out of having your personal information sold or shared. To opt-out, click the “Do Not Share My Personal Information” link on the bottom of the webpage. Some web browsers allow consumers to automatically exercise their right to opt-out of sale/sharing with all businesses they interact with online by initiating an opt-out preference signal. We will honor such opt-out preference signals.

In order to request, deletion or a copy of your personal information, you may forward verifiable consumer requests to Dwolla through one of the following methods:

• Calling Dwolla at 1-888-289-8744;
• Submitting a written request using this form.

Only you, or someone legally permitted to act upon your behalf, may make a verifiable consumer request. For example, you may make a verifiable consumer request on behalf of your minor child.

In order to submit a verifiable consumer request to Dwolla, the request must both provide sufficient detail for Dwolla to be able to appropriately ascertain your identity and give sufficient clarity for Dwolla to understand the nature of the request. Dwolla will determine the criteria for a verifiable consumer request based upon the nature of the request and account.

If you have submitted a verifiable consumer request, Dwolla will respond in a timely manner consistent with applicable law. If Dwolla is unable to verify or denies your request, Dwolla will submit an appropriate response. If you would like to appeal our decision to deny your request, please do so by using the secure messaging portal that we emailed to you after you submitted a data subject rights request. If you have any questions or concerns please email us at privacy@dwolla.com.

Do Not Track Disclosure

Do Not Track signals are a web browser setting or mechanism used to indicate to web sites that a visitor does not want their online activity tracked. As of the effective date of this Privacy Statement, Dwolla does not currently respond to Do Not Track signals.