Privacy Policy
Last updated: 03/21/2023
If you visit our website, download our app, or use our system in any other way (collectively, “Services”), Cashli Funds LLC, an Illinois limited liability company, DBA Cashli (“Cashli,” “we,” “us,” and “our”) will ask for, collect, and store personal information about you (your “Personal Data”).
This document (“Privacy Policy”) describes:
• the types of personal information we collect,
• how we use the information,
• with whom we may share it, and
• the choices available to you regarding our use of the information.
We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.
If you do not want us to collect Personal Data from you or share Personal Data with any third parties or otherwise disclose your Personal Data, you should not use the Services.
1. How We Protect Personal Information
To protect your personal information from unauthorized access and use, we use AES-256 encryption, that the U.S. Army and U.S. banks use, in compliance with federal law. These measures include computer safeguards and secured files and buildings. We restrict our employees’ access to your information so that it is only accessible when they need it to do their work, and we require companies that provide services for us to protect your information. We also have safeguards designed to protect the personal information you provide from unauthorized access, destruction, loss, alteration, disclosure or use.
2. Information We Obtain
We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with any of our representatives. The types of personal information we may obtain about you may include:
● Identifiers such as your full name, postal and email address, and phone number (U.S. numbers only);
● Debit card number;
● Login credentials for your Cashli account;
● Device ID and IP number;
● Data on how you use the Services, such as which reports you view and how long you view them; ● Information you provide through member services interactions and that you provide about your experience with Cashli, including via questionnaires, surveys, participation in user research or other feedback; and
● Other information you choose to provide, such as through emails or other communications (such as with our representatives), referrals, on social media pages, or in registrations and sign-up forms.
Cashli uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Cashli and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy. Plaid will store your bank account number, and will access data about your bank-account use that we will use in our underwriting process. Cashli does not store your account number or routing number.
Cashli uses Stripe to facilitate payments to and from your debit card.
3. How We Use the Information We Obtain
We may use the personal information we obtain for purposes such as the following:
● Provide the Services;
● Process and fulfill transactions;
● Establish and manage your account;
● Personalize your experience on our Services;
● Respond to inquiries, provide member support and resolve disputes;
● Advertise and market our products and services, and send information about third-party products and services we think may interest you;
● Provide member support and quality assurance, and conduct customer service training;
● Collect fees and other amounts owed in connection with your Cashli account;
● Operate, evaluate and improve our business;
● Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
● Exercise our rights and remedies and defend against legal claims; and
● Comply with and enforce applicable legal requirements, relevant industry standards and Cashli policies.
We also may use the information in other ways for which we provide specific notice at the time of collection.
4. Information We Share
We don’t share the information we obtain about you with our affiliates and subsidiaries and our business partners. We don’t share your information for marketing purposes.
We also may share the information we obtain about you with third-party vendors and other entities we engage to perform services on our behalf, such as payment processors, risk detection and mitigation tools, and modeling and analytics tools. This information is shared to facilitate our everyday operations and not for marketing purposes, and you may not opt out of it.
We also may share your Personal Data:
• to comply, as necessary, with applicable laws and regulatory requirements;
• for legal process;
• to respond to mandatory legal or governmental requests or demands for information;
• to enforce our agreements, policies, procedures, and terms of use; and
• to protect ourselves, our customers, or the general public from illegal activities.
We reserve the right to transfer any personal information we have about you to a successor company if we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
5. Third-Party Analytics Services
We may use third-party analytics on our Platform.
6. Your Rights & Choices
You may exercise certain choices in connection with the personal information we collect from you. Federal law lets you limit our sharing of data for marketing purposes, but not for everyday business purposes.
To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the “How to Contact Cashli” section of this Privacy Policy. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.
If you are a Cashli user, you may update, correct, or delete some of your account information by logging into your account on our Services or by emailing us at support@cashli.io.
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
7. Children’s Privacy
Our Services are designed for a general audience and are not directed to children. We do not knowingly collect, use, sell, or share any Personal Data from anyone under the age of 18. If we become aware that a child under the age 18 has provided Personal Data to us, we will delete it.
8. Links to Third-Party Services and Features
For your convenience and information, our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third party features are not owned or controlled by Cashli, we are not responsible for these third parties’ information practices.
9. Updates to this Privacy Policy
We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the policy when it was most recently updated.
10. How to Contact Cashli
You can update your preferences, ask us to remove your information from our mailing lists, submit a request, or ask us questions about this Privacy Policy by writing to us at support@cashli.io.
11. California Consumer Privacy Rights
As a California resident and consumer, you have certain choices regarding your personal information under the California Consumer Privacy Act (CCPA), as described below:
● Right to Access. You may request, up to twice in a 12-month period, information about the Personal Data we have collected, used, disclosed or sold about you during the past 12 months, including:
o the categories and specific pieces of Personal Data we have collected about you; o the categories of sources from which we collected the Personal Data;
o the business or commercial purpose for which we collected the Personal Data; o the categories of third parties with whom we shared the Personal Data; and
o the categories of Personal Data about you that we disclosed for a business purpose and sold to third parties, and the categories of third parties to whom the information was disclosed or sold.
● Right to Delete. You may request that we delete the Personal Data we have collected from you, subject to certain limitations under the CCPA.
● Right to opt-out from sale of Personal Data. You have the right to opt-out of the sale of your Personal Data. Cashli does not sell your Personal Data.
● Right to non-discrimination. If you choose to exercise any of your rights under the CCPA, we may not discriminate against you. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
To submit a request to exercise any of the rights described above, you may email us at support@cashli.io. We will verify your identity before responding to your request by either verifying that the email address from which you send the request matches your email address that we have on file, or by requiring you to log into your account.
Consumer Request by an Authorized Agent
If any authorized agent submits a consumer request under the CCPA on your behalf, we require the authorized agent to submit the following information so that we can confirm their authority to act on your behalf:
● Evidence of authorization to act on behalf of the California consumer: (1) California Secretary of State authorization, (2) notarized written permission from the California consumer, or (3) power of attorney.
● Evidence of identity of the California consumer: (1) first and last name, (2) email address, and (3) password.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83):
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL DATA TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING SUPPORT@CASHLI.IO. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.