Privacy Policy

Introduction

Verify my Account LLC d/b/a Verify my Banks (“VMB” or “We”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website www.verifymybanks.com, or use VMB’s services and applications (collectively referred to as our “Website“). This Privacy Policy also details our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using the Website or continuing to be enrolled in our services, you agree to this Privacy Policy. By using the Website, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy).

Your use of the Website is also governed by the End User Agreement. Do not use the Website if you do not agree to the End User Agreement or this Privacy Policy.

Information We Collect About You and How We Collect It

We collect two basic types of information—personal information and —and we may use personal and anonymous information to create a third type of information, aggregate information. For example, we collect:

  • Enrollment and Profile Information. When you enroll as a user or update your information on the Website, we collect personal information from you, such as your name, postal address, email addresses, name of the financial institution where you hold accounts, the credentials for your financial institutions, and information about financial transactions you engage in. We also collect any other information you enter into or associate with your profile.Your Financial Institution may require you to link your VMB profile to your financial account. In doing so, we will access and display information about each of the financial accounts you hold at that Financial Institution that is eligible for use with the VMB service (as determined by the Financial Institution), including but not limited to the transactions for each of those accounts, and your email address(es) on file with the Financial Institution.
  • Information About Your Transactions. When you use the VMB Website, we collect information such as when and where your financial account transactions occur, the names of the transacting parties, the mobile phone numbers or email addresses of the transacting parties, a description of the transactions (including text you put in the memo field), and the transaction amount. This information is aggregated and used to help us provide more useful information to our customers. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.
  • Information to Respond to Your Requests. You may give us your personal information when you contact us for assistance and to sign up for communications. See the section titled “Your Choices” for information on how you can opt-out of receiving communications from us.
  • Information from Other Sources.In addition, we may collect personal information from third party services in order to process your registration, verify your identity, verify your financial account information, and protect against or prevent actual or potential fraud or unauthorized use. The information we collect may be combined with information from outside records (e.g., demographic information, additional contact information) that we have acquired in accordance with the law.
  • Non-Personal Information. We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it: occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where the VMB Website is accessed so that we can better understand customer behavior and improve our products and services.
  • Technical Usage Information. When you visit our Website, we collect usage information sent to us by your computer, mobile phone, or other access device which may include your browser type and language; country and language setting on your device; Internet Protocol (“IP”) address; the domain name of your Internet Service Provider, mobile device and operating system; content you view on the website; features you use; the date and time of your visit to or use of the Site; and data about how you interact with our Site. During some visits, we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information. To learn more about how we use tracking technologies and cookies, see Cookies and Tracking Technologies.

Our goal is to collect only that information that we believe is required for our legitimate business interests, which include but are not limited to collecting, de-identifying, aggregating and selling information related to your financial transactions, operating the Site, authenticating and verifying your identity, preventing fraud, and improving your experience of using the Site.

How We Use Your Information

Data collected or accessed will only be used for the purposes specified in the Privacy Policy. If the data will be used for other purposes, we will notify you of those additional purposes, and obtain your consent where necessary. We may use the data we collect for a number of purposes, including:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To verify the existence and status of your financial accounts.
  • To verify your identity.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To prevent, detect, investigate, and report fraud, security breaches, potentially prohibited or illegal activities, or otherwise to protect our services or Users.
  • In any other way we may describe when you provide the information.
  • To enforce our terms and conditions.
  • For any other purpose with your consent or after notice to you.

We may also use anonymous, statistical or aggregated information (in other words, information that does not identify you) collected on or through the use of the Website, for any purpose. Some examples of how we use this information are: to properly operate the Website, to improve the quality of the Website, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and/or for further internal, commercial, and statistical purposes.

Disclosure of Your Information

To provide you with the services, as described in this Privacy Policy, we need to share some information about you with others. Information collected or accessed on the Site may be shared with entities both within and outside of our corporate family. Please note that any third party with whom we share your personal information will be legally and/or contractually required to provide the same or equal protection to your personal data as we outline in this Privacy Policy. We may share your information with the following entities:

  • Our subsidiaries and affiliates.
  • Your financial institution(s) and affiliates.
  • Our contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).
  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of VMB’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by VMB about our Website users is among the assets transferred.
  • With parties necessary to fulfill the purpose for which you provide it. For example, when you give us your banking history, we will transmit the information to authorized lenders at your request.
  • Other business partners to provide aggregated and anonymized information relating to financial transactions to allow those partners to assess and analyze aggregate usage information and market trends.
  • With any other third parties for any other purpose disclosed by us when you provide the information, or with your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VMB, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Cookies and Tracking Technologies

When you visit the Website, you consent to the use of cookies and tracking technologies as well as the corresponding processing of your personal information. We and our third parties may use cookies and other tracking technologies for a variety of purposes, as outlined in this Privacy Policy and as described below. You can withdraw your consent at any time by deleting placed cookies and disabling cookies in your browser. If you reject cookies, you may still use the Website, but your ability to use some areas of the Website may be limited.

  • Operationally Necessary. We may use tracking technologies required for system administration, to prevent fraudulent activity and improve security. We are not required to obtain your consent for tracking technologies that are operationally necessary.
  • Performance-Related. We may use cookies or other tracking technologies to assess the performance of the online services, including as part of our analytic practices to improve the content offered through the online services.
  • Functionality-Related. We may use tracking technologies to tell us, for example, whether you have visited the website before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.

During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.

The technologies we use for data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit VMB, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and/or service providers use cookies to make it easier for you to navigate the Website. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Do Not Track

VMB does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browsing platform allows you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not what to be tracked.

User Access and Choice

We strive to provide you with choices regarding the personal information you provide to us. However, you may not opt-out of administrative emails, messages, or phone calls (for example, about your transactions or policy changes) for your enrolled profile.

You may access your account on the Website and edit, delete or amend your personal information. You can review and change your personal information by logging into the Website and visiting your account profile page. You can update your User profile and registration information, including your financial account, personal information and email addresses/mobile numbers.

If you find that the personal information in your account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from registering with the Website and impair our ability to provide you with services through the Website. If you are unable to edit, delete or amend any personal information via your Website account, you may submit an access request to us by sending an email to info@verifymybanks.com. Your email should include adequate details of your request.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. VMB has not and does not transfer information to third parties for direct marketing purposes. In the event we decided to do so in the future, we would provide further information.

Data Retention

At all times we may review, retain and disclose any information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request. However, by doing so we do not either expressly or impliedly endorse, affirm or in any manner assume any responsibility for such information.

When your account is terminated, VMB will delete your personal information and discontinue any connection with your financial institution regarding your account. Naturally, once disconnected, you will no longer have access to your VMB account. However, due to periodic backups and safety mechanisms meant for your information protection and/or for our administrative and legitimate business purposes, certain aggregated data and/or personal information from your account may remain in our systems for as long as commercially necessary. We will not knowingly keep this information in a way that could identify you. If you have a query about any such personal information that we may be storing, please email us at info@verifymybanks.com. Your email should include adequate details of your query.

Data Security

To help us protect the privacy of your data, we maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and profile registration information are secure and not shared with third parties.

Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

European Territory Citizens

In compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR), VMB provides specific additional rights for citizens of the European Territories, such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically:

  • the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended.
  • under certain circumstances, the right to request that personal data should be deleted.
  • under certain circumstances, the right to demand that the processing of personal data should be restricted.
  • the right to withdraw your consent to the processing and use of your data completely or partially at any time with future application.
  • the right to obtain your personal data in a common, structured and mechanically readable format.
  • the right to contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.
  • the right to complain to the responsible supervisory authority if you believe that the processing of your personal data is in violation of the legislation.

Pursuant to the GDPR, citizens from “European Territories” mean the European Economic Area (EEA) and Switzerland. For the purpose of this Privacy Policy, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.

Please email info@verifymybanks.com with any questions about exercising any of the above rights.

Data Controller for Personal Data

The Data Controller for the personal data processed by us is the Client Company of VMB (the financial institution of the person whose data is collected, or data subject). The Data Controller will pass personal data of their users to VMB to manage financial transaction data on behalf of those users. VMB, as Data Processor acting on the instructions of the Data Controller under a written contract with them, will subsequently use that personal data to manage financial transaction data. It is this contract which forms the “Legal Basis””for the processing of personal data carried out by VMB in these circumstances.

VMB will also become a Data Controller if, and when, it collects additional personal data directly from a data subject. In these circumstances VMB will be acting under a “Legitimate Interest” to legally process the data for the management of the data subject’s financial account and to fulfil the contractual requirements for its Client.

Grounds for Processing

The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds.  As described below, VMB processes the information of EU users based on one or more of the grounds specified under the GDPR:

  • The processing is necessary to provide the services and features you request:
    • VMB must collect and use certain information in order to provide its services. This includes:
      • User profile information that is necessary to establish and maintain your account, including to verify your identity; and to enable communications with you about your connected financial institution accounts;
      • Transaction information, which is necessary to collect, refresh and maintain in connection with your use of VMB’s website.
      • Usage information, which is necessary to maintain, optimize and enhance VMB’s services.
    • Collection and use of this information are a requirement for using VMB’s Website.
  • The processing is necessary to protect the vital interests of our users or of others
    • VMB may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.
  • The processing is necessary for VMB’s legitimate interests
    • VMB collects and uses personal information to the extent necessary for its legitimate business interests. This includes collecting and using information:
      • To provide customer support.
      • To optimize our service and develop new services.
      • For commercial research and analytical purposes. This includes, for example, analyzing financial transaction trends to aggregate and sell resulting data to our business partners.
  • The processing is necessary for the legitimate interests of other persons or parties
    • VMB may also process personal information when necessary in regards to a substantial public interest, on the basis of applicable laws.
  • The processing is necessary to fulfill VMB’s legal obligations
    • VMB may be subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data.
    • VMB may also share information with law enforcement, or requests by third parties pursuant to legal processes.
  • Consent
    • VMB may collect and use your information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you may not be able to use VMB’s Website or related services that require collection or use of the information we collected or used on the basis of consent.
    • VMB relies on consent in connection with data collections or uses that are necessary to enhance your experience, to enable services or features, such as linking your financial account, or to communicate with you.

Children’s Privacy

The End User Service Agreement defines eligibility requirements to use the VMB Website and related services. Our Site is not intended for children. For information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.

Links to Third Parties

Our website may contain links to other third-party websites, such as your Financial Institutions. When you leave our website and visit those websites, you are bound by the privacy policies of those websites. We are not responsible for the privacy practices of these third-party websites, which are governed by their own privacy policies and practices.

Territorial Scope and Processing

We are located in the United States. Our operations use a network of computers, cloud-based services, and other infrastructure and information technology that are based in the United States. Additionally, we may use third-party service providers that may be located in and process or store your personal information in the United States, the European Union, and other countries. If you create a profile, you consent to the collection and/or processing of your personal information and tracking technologies/cookies as described in this Privacy Policy.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page, by sending you an email, and/or by any other viable means of contact. Please note that if you have not provided us with your email address, or if you do not update your account with necessary changes, our notices will still govern your use of the Website, and you are still responsible for reading and understanding our revised Privacy Policy.  You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes. If you access or use the Website or continue to be enrolled in our services after any changes to the Privacy Policy have been posted, you agree to the changes as listed. The date the Privacy Policy was last revised is identified at the top of the page.

Contact Information

If your questions are not answered in this Privacy Policy, you may email us at, info@verifymybanks.com.