Last updated: March 11, 2022
For individuals residing in the United States, you may also refer to the Sequin U.S. Consumer Privacy Notice, which provides additional details about our collection, use, and sharing of your personal information in connection with the financial services that Sequin provides to individuals, and rights you may have under federal law.
Please read this Policy carefully to understand our policies and practices regarding your information. By continuing to interact with our Services, you are consenting to the practices described in this Policy. This Policy may change from time to time (see Changes to this Policy). Your continued use of this Website or our other Services after we make changes is deemed acceptance of those changes, so please check the Policy periodically for updates.
TYPES OF INFORMATION WE COLLECT
We collect several types of information that may identify or be reasonably associated with you (called “personal information”) when you use our Services. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
When you visit our Website, or use our App, we may collect information about your connection and the equipment you use to access our Website and other Services, such as IP address and device-specific identifiers.
If you open a Sequin account or otherwise use our Services, we may collect the following personal information about you:
Identification information, such as your name, email address, zip code, phone number, signature, and authentication credentials (for example, information you use to log in to your Sequin account), full mailing address; date of birth; government-issued identification, including Social Security number, driver’s license information; and photograph, if you choose to share such information in order to access our Services.
Financial information, such as bank account information and payment card numbers you add to your Sequin account, income information, the age of your account(s), as well as any card information issued to you in connection with your use of our Services.
Transaction information, when you use our Services to make, accept, or request payments. This information may include when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, and the devices and payment methods used to complete the transactions.
When you interact with us in other contexts, such as by contacting customer service, engaging with marketing content, or interacting with our Website or App, we may collect other information, such as survey responses, if you choose to provide them; any information that you voluntarily provide in connection with participation in our contests, or other prospective marketing forms or devices; suggestions for improvements or referrals that you may submit; information you provide to our customer support representatives; or any other information that you may voluntarily provide.
We may also collect information about you from third parties and publicly available sources, including from third-party identity verification services.
COOKIES AND OTHER TECHNOLOGIES
The technologies we use for this automatic data collection may include:
Third Party Browser Cookies. Third-party cookies enable us and the third parties we work with to track our Website visitors and their interests.
Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Some content or applications on the Website or our other Services are served by third-parties, including (a) service providers, such as Plaid, and Stripe, that we integrate with to verify your banking information, confirm your identity, or to otherwise provide or facilitate our Services; (b) analytics providers, such as Google Analytics; and (c) advertisements which may appear on our Website, in our App, or elsewhere throughout our Services. These third parties may collect information about you when you use our Services or when you interact with their content. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to, among other things, provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices About Your Information, below.
HOW WE USE YOUR INFORMATION
We may use information about you for the following reasons:
Providing, improving, and developing our Services
Complying with our legal obligations, such as by determining whether the Services are available in your country and recording payment transactions or money transfers
Conducting investigations and responding to lawful requests for information from authorities
Ensuring compliance with our Terms of Service or other applicable agreements or policies
Preventing, investigating, and reporting fraud or other potentially prohibited, malicious, or illegal activities, as determined at our discretion
Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services
Carrying out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
Communicating with you about our Services and other information we think you may find useful or which you have requested from us. If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.
Fulfilling any other purpose for which you provide us with information about you.
HOW WE SHARE YOUR INFORMATION
We may share aggregated and anonymized information that does not specifically identify you or any individual user of our Services without restriction. We may share your personal information with the following categories of service providers and third parties:
With our affiliates. For example, we may share your information internally to understand how you engage with Sequin Services to help make them better for you and for everyone, and to help us build Services tailored to your preferences.
With our business partners, service providers, and payment processors who help us provide, maintain, and improve our Services as necessary, for example, to open a Sequin account, verify your identity, link your bank account(s), prevent and detect fraud, obtain a Sequin Card, and complete the transactions that you have requested.
With service providers that help us contact you, run our advertising campaigns, contests, special offers, or other events or activities.
As is reasonably necessary, determined at our discretion (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.
OTHER IMPORTANT INFORMATION
Sequin applies commercially reasonable technical, administrative and organizational security measures to prevent against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access to its systems and environment. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain of our Services, you are responsible for keeping the password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. 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.
Use by minors
Our Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to us through our Services, including on our Website. If you are under the age of 13, you may not have a Sequin Account or use our Services. We do not knowingly process any information from, or direct any of our products or services to, children under the age of 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
YOUR CHOICES ABOUT YOUR INFORMATION
Tracking technologies and advertising
If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. To opt-out of targeted advertising involving our Website, you may do so by visiting the Network Advertising Initiative opt-out page.
For opt-outs from interest-based advertising related to our mobile application, please refer to instructions provided by your mobile operating system provider. You may also you may download and use an opt-out application, such as DAA's AppChoices App or the Truste Privacy App.
Deletion or closure of a Sequin account
Closure or deletion of your Sequin account will mean that you permanently lose access to the personal information and data associated with the Sequin account. Certain personal information or de-identified information associated with your Sequin account may nonetheless remain on systems owned or maintained by Sequin where required to comply with the law, our contractual obligations, or in carrying out legitimate business functions. To comply with legal and regulatory obligations, we may also retain certain personal information associated with rejected applications for Sequin accounts.
Exercising your choices
To exercise your choices about your personal information, please contact our Customer Experience team at email@example.com. We may need to verify your relationship to the Sequin account and verify your identity. We will not discriminate against you for exercising any of your rights.
CHANGES TO THIS POLICY
Sequin Financial, Inc. Anchor Suite 100
1540 Market Street
San Francisco, CA 94102