Checkless, Inc. Privacy Policy

Last Updated: October 28, 2019


Checkless, Inc. (“Checkless”, “us”, “we”, or “our”) operates the https://checkless.com website (the “Site”) through which we provide payment facilitation services (the “Services”). “You” are an individual using the Site or Services as an authorized representative of your organization or in your individual capacity. The “Customer” is an organization using the Services. This Privacy Policy, along with our Terms of Service which are hereby incorporated into this Privacy Policy, govern your interaction with the Services. An additional service-level agreement with the Customer may also govern the Customer’s relationship with Checkless. 

We collect and process information that relates to identified or identifiable individuals (“Personal Information”) as set forth below. Specific Personal Information elements listed in each category are only examples and may change. We will not use or share your Personal Information except as described in this Privacy Policy; however, the Services interact with various other third parties, each of which have their own privacy policies. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

  1. Information You Provide on the Site
    1. Login Information: Name, email, avatar or password
    2. Verification Information: Address, EIN, birthday, legal name, last 4 digits of SSN. We may request additional information to verify your identity, including full passport or social security numbers (“Additional Verification Information”).
    3. Business Information: Business website, avatar, and description, DBA
    4. Bank Information
      1. Bank Authorization Information: Bank name, account name, partial account number
      2. Bank Payment Information: Account number, routing number, card number, bank address, login credentials
    5. Job Information: Information you include if you apply for a position at Checkless, like email, resume, personal and contact information, social profiles, and any additional information you submit
  2. Information We Collect Automatically in the Services
    1. Log and Device Information
      We collect information about the device you use to access our Services, e.g. device type, its software version, or carrier. We also collect information that your browser sends whenever you visit our Site. This Log Information may include information such as your computer’s IP address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
    2. Activity Information
      We collect information about your activity on the Services, like sends, requests, failures, amounts, payment ID, and date and time stamps.
    3. Cookies
      We use Cookies stored in the user browser to identify users of the Services. We may also use third-party services like Google Analytics that collect, monitor, and analyze this type of information in order to enhance our Site’s functionality. These third-party service providers have their own privacy policies addressing how they use such information. For more information, see our “Cookies” section below.
  3. How We Use Your Personal Information
    Subject to your Rights and Choices below, we generally use your Personal Information in the following ways:
    1. To provide, maintain, and improve our Site, including analytics, marketing, support, and job applications
      1. Email: If you provide your email address for marketing purposes, we may use it to contact you with newsletters, marketing, or promotional materials and other information that may be of interest to you. You may opt out of receiving these communications from us by following the unsubscribe link or instructions provided in any email we send. We will also use your email to send you updates about transactions; you may not opt out of receiving these emails. If you contact us for help, we may use your email to communicate with you.
      2. Login Information: We use your Login Information to enable you to securely access the Services and to identify your activities in the Services.
      3. Job Information: If you apply to work at Checkless, we use your Job Information to evaluate your application and contact you about it.
      4. Log and Device Information: We use Log and Device Information to help improve our Site and Services, internal operations, and systems. We also use Device Information to understand your engagement in an activity or feature, for example which pages or tools you interacted with or data about any crashes during use.
    2. To provide, maintain, and improve our Services
      1. Verification Information: We use Verification Information to verify your identity. We store as little of this information as possible, and we never store Additional Verification Information. 
      2. Business Information: If you choose to provide Business Information, we will store it and use it to enhance our Services. Other users may see some of your Business Information. 
      3. Bank Information: We store Bank Authorization Information to verify your account for payment purposes. We do not store Bank Payment Information, instead we pass it through to a third-party service provider that performs the transfer of funds. Users may only see their own Bank Information. Any and all collection, processing, storage, and sharing this of this Personal Information is performed as permitted by law.
      4. Activity Information: We use Activity Information to provide useful information to you about our Service and to improve our offerings; we do not share your Activity Information with users that are not part of the same Customer unless you have transacted with that user.
      5. Log and Device Information: We use Log and Device Information to secure and  improve our Services, internal operations, and systems. We also use Device Information to understand a user’s engagement in an activity or feature, for example which pages or tools you interacted with or data about any crashes during use.
    3. Behavioral Advertising
      We and certain third parties operating on or through our Site (e.g. Facebook or LinkedIn) may engage in online behavioral advertising. This form of advertising includes various parties and service providers engaged in the processing of cookies and other online identifiers, in connection with advertising. We may place cookies on your device, then provide it directly to a third party for targeting on a third-party platform. The parties that control the processing of Personal Information for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. See the “Rights and Choices” and “Cookies” sections below for information about how you can limit or opt out of this processing.
    4. To create anonymized data about use of our Services
      We use Personal Information to create anonymized data about the use of our Services; we may use this data for any legally-permissible purpose, including without limitation benchmarking and other research & development purposes. We may retain this data after you or the Customer no longer uses or has an account on the Services.
    5. To comply with legal obligations or pursuant to a transaction
      If Checkless is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy. Under certain circumstances, Checkless may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Finally, we may disclose your Personal Information in the good faith belief that such action is necessary to:
      1. comply with a legal obligation;
      2. protect and defend the rights or property of Checkless;
      3. prevent or investigate possible wrongdoing in connection with the Service;
      4. protect the personal safety of users of the Service or the public; or
      5. protect against legal liability.
  4. Information Sharing
    We may share Personal Information we collect with a variety of parties, depending upon the purpose for and context in which you provided that information. We generally share Personal Information with the following types of recipients:
    1. Customers
      Users that control the accounts of a Customer may see Activity Information for users associated with that Customer; we do not share Login Information or Verification Information for individual users with other users in the same Customer. 
    2. Third-Party Service Providers
      The below third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose your Personal Information for any other purpose.

Provider

Function

Privacy Notice

Information Shared

AWS

Hosting Provider

Amazon Web Services Privacy Policy

Storage of Personal Information

Google

Infrastructure provider; SSO provider

Google Cloud Privacy Policy

Log and Device Information for Single Sign-On

Plaid

Verification services

Plaid Privacy Policy

Bank Verification & Authorization

Intercom

User support

Intercom Privacy Policy

Email; query information

Mailchimp

Mail and marketing management platform

Mailchimp Privacy Policy

Email; business information

Dwolla

Payment processing & identity verification

Dwolla Privacy Policy

Bank Information

  1. Your Rights and Choices
    Subject to the rights granted to other individuals, and our rights to limit or deny access/disclosure under applicable law, you have the following rights in your Personal Information. We may require that you provide additional Personal Information to exercise these rights, e.g. information necessary to prove your identity. For data collected or processed by the Site, you may contact us directly regarding these rights at help@checkless.com. We will assist you or the Customer as appropriate in the fulfillment of your request.
    1. Access & Rectification
      You may receive a list of your Personal Information that we process to the extent required and permitted by law. You may access and change most Personal Information that we store about you through your account settings.
    2. Deletion
      You may request erasure of any Personal Information that we hold to the extent required and permitted by law. You may delete your account and associated data by contacting help@checkless.com or by following prompts in your account settings. Third parties may retain information about you or your transactions; deleting your account may not delete all such third party records.
    3. Portability
      To the extent required by applicable law, we may allow you to download data from your Checkless account or export it to external services. Please recognize that any data you transfer from Checkless in this manner will no longer be under Checkless’ control and thus will not be governed by this policy.
    4. Your Choices
      You have the following choices regarding the Personal Information we process:
      1. Direct Marketing
        You may opt out of or withdraw your consent to direct marketing communications. You may cease direct marketing from us by clicking the unsubscribe link in any promotional email we send you.
      2. Do Not Track
        Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser, however we do not currently support Do Not Track.
  2. Cookies
    Cookies are small files that may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies on our Services to collect information in order to improve our services for you. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies, or notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Services. Please note that turning off cookies does not necessarily opt you out of being delivered advertising. You may continue to receive generic ads. You must opt out of third-party services directly via the third party. You may view a list of other third-party service providers who collect information, and/or opt out of such collection of information about you, by visiting https://www.networkadvertising.org/choices/ or https://www.aboutads.info/choices.
  3. Security
    The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. Our third-party service providers that handle your Bank Information and Verification Information are bound by applicable law and agreements with us to encrypt and otherwise secure your information in transit and at rest. Whenever possible, Bank and Verification Information are processed for the purposes specified above and then discarded. Checkless does not store or handle your money. No method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you. 
  4. Children’s Privacy
    Only persons age 18 or older have permission to access our Service. Our Service does not address or target anyone under the age of 16 (each a “Child”). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you learn that your Child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a Child without appropriate consent, we take steps to remove that information from our servers.
  5. Changes to This Privacy Policy; Contact Us
    This Privacy Policy is subject to occasional revision. If we make any changes to this Privacy Policy, we will change the “Last Updated” date above. If you have any questions about this Privacy Policy, please contact us at help@checkless.com or at:

Checkless, Inc.
Attn: Privacy
798 Berry Rd #40374
Nashville, TN 37204