GLBA Privacy Notice
FACTS: What Does Banrox Do With Your Personal Information?
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social Security number and date of birth
- Account balances and transaction history
- Credit history and credit scores
- Contact information and payment history
When you are no longer our customer, we continue to share your information as described in this notice.
How?
All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information, the reasons Banrox chooses to share, and whether you can limit this sharing.
Reasons We Can Share Your Personal Information
| Reasons we can share your personal information | Does Banrox share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes, such as to process your transactions, maintain your account, respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes, to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | No | We do not share |
| For our affiliates' everyday business purposes, information about your transactions and experiences | No | We do not share |
| For our affiliates' everyday business purposes, information about your creditworthiness | No | We do not share |
| For our affiliates to market to you | No | We do not share |
| For nonaffiliates to market to you | Yes, only the providers you ask to be matched with | Yes |
Two of the reasons printed above do not apply to Banrox. Federal law requires Banrox to print the wording in the left column of that table word for word, and that wording lists the reasons a financial company can share information. Two of the reasons in it are not things Banrox does. Read the table with the two notes below.
Banrox does not report anything to a credit bureau. Banrox does not furnish any information about you, about your Banrox account, or about your subscription to Equifax, Experian, TransUnion, or to any other consumer reporting agency, for inclusion in a consumer report or for any other purpose. Banrox has never done so and does not intend to. Banrox is not a furnisher. The first row is answered "Yes" because Banrox shares information to process your payments, to maintain your account, and to respond to court orders and legal process, and for no other reason in that row.
Banrox does not use your Social Security number, your credit history or your credit score for marketing. Not for marketing of any kind, its own included. The marketing row is answered "Yes" because Banrox writes to you about Banrox products using your name and your contact details. Nothing else in the "What?" list above is used for that.
Plain reading of the last row. The only time your information goes to another company that may market to you is when you ask Banrox to match you with that company or to get you a quote from it. Banrox does not send your information to companies you did not ask about. The transfer never includes your Social Security number, a government ID number, a financial account number, or anything taken from your credit report or your credit score, including anything derived from either.
To Limit Our Sharing
You can tell us not to share your information with nonaffiliated companies that may market to you. Any of these works:
- Email [email protected] with the subject line "Privacy Choices"
- Call (888) 888-6401
- Use the privacy settings inside your Banrox account
- Mail the form at the bottom of this page
Please note: if you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. You can contact us at any time to limit our sharing, and your choice stays in force until you change it.
What the thirty days means, and does not mean. The sentence above is wording federal law requires Banrox to print. It does not describe a queue your request sits in. When you ask Banrox to match you with a specific company or to get you a quote from it, Banrox passes your request straight through, because that is the thing you asked for, and federal law treats it as a transaction you authorised. It happens whether or not you have limited sharing, and it happens the day you ask. Your limit choice stops Banrox sharing with any company you did not ask about. Banrox does not do that kind of sharing at all today, and if it ever starts, this notice will be updated and sent to you before it does.
How fast a limit takes effect. Banrox applies your choice as soon as it receives it, and in every case within 15 business days. A Global Privacy Control signal is applied immediately.
Questions?
Call (888) 888-6401 or write to [email protected], or Banrox Inc., Attn: Privacy, 40 N Altadena Dr, Ste 105, Pasadena, CA 91107.
When you get this notice. Banrox gives you this notice when you open an account, before Banrox shares anything about you with a company you have not asked about. Because Banrox offers you a choice about sharing with nonaffiliated companies, federal law requires Banrox to send this notice again every year for as long as you have an account. Banrox sends it by email to the address on your account, and you can ask for it on paper at any time by writing to [email protected]. If Banrox changes what this notice says, you get the new version before the change takes effect.
Who We Are
Who is providing this notice? Banrox Inc., a Delaware corporation with its principal place of business at 40 N Altadena Dr, Ste 105, Pasadena, CA 91107.
What We Do
How does Banrox protect my personal information?
To protect your personal information from unauthorised access and use, we use security measures that comply with federal law. These measures include computer safeguards, encryption of personal information in transit and at rest, multi factor authentication for administrative access, access limited to employees who need the information to do their job, secured files and buildings, vendor security review, and a tested incident response plan.
How does Banrox collect my personal information?
We collect your personal information, for example, when you:
- open an account or create a profile
- give us your contact information
- ask us to obtain your credit report or credit score
- connect a bank account or provide income information
- pay for a subscription or use a payment method
- ask to be matched with a lender, card issuer, bank, or insurer
We also collect your personal information from others, such as consumer reporting agencies, identity verification services, and monitoring vendors that work on our behalf.
Why can't I limit all sharing?
Federal law gives you the right to limit only:
- sharing for affiliates' everyday business purposes, meaning information about your creditworthiness
- affiliates from using your information to market to you
- sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. Yours are set out at State Privacy Rights, and they go further than this federal notice. Several state privacy laws would let a financial institution put the information described here outside their reach altogether. Banrox does not use that exemption to take a right away from you. Every right on the State Privacy Rights page covers every category of information listed in this notice.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies. Banrox has no affiliates that market to consumers. If that ever changes, this notice will be updated and sent to you before any affiliate sharing begins.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Banrox shares with nonaffiliates only the providers you ask to be matched with, and the service providers listed at Service Providers and Data Recipients, which are contractually barred from marketing to you.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Banrox does not engage in joint marketing.
Other Important Information
Consumer report information. Information we obtain from a consumer reporting agency at your request is regulated by the Fair Credit Reporting Act as well as by this notice. We show it to you. We do not sell it, we do not furnish it to anyone else, and we do not use it to market to you. See Credit Data and Your FCRA Rights.
Banrox is not a lender or a bank. This notice is given because Banrox handles consumer financial information as a financial institution under the Gramm-Leach-Bliley Act. It does not mean Banrox extends credit, takes deposits, or is a bank. It does not.
After you close your account. This notice says twice, in wording federal law requires Banrox to print, that Banrox continues to share your information when you are no longer a customer. In practice Banrox does not share anything about a former customer with any company. When you close your account Banrox stops all sharing that day, and you can also ask Banrox to delete what it holds, at State Privacy Rights. What Banrox keeps after that, and for how long, is in Section 2 of the Privacy Policy.
California residents. Banrox will not share personal information with nonaffiliates for their marketing purposes except at your request or with your consent, and it limits sharing among any Banrox companies to what California law allows. California gives you more than this federal notice does. The section headed "California Residents: Important Privacy Choices" below sets out what, and how to use it.
Vermont residents. We will not share personal information about your creditworthiness with nonaffiliates for their everyday business purposes without your authorisation.
Nevada residents. You may request to be placed on our internal do not call list by writing to [email protected]. Nevada law requires this notice: Nevada Attorney General, Bureau of Consumer Protection, 100 North Carson Street, Carson City, NV 89701, telephone (775) 684-1100, email [email protected].
California Residents: Important Privacy Choices
California controls what a financial institution may do with your information more tightly than federal law does, under the California Financial Information Privacy Act at California Financial Code sections 4050 to 4060. Banrox is a California company and a financial institution under the Gramm-Leach-Bliley Act, so that Act applies to Banrox and these are your choices under it.
Companies Banrox is not related to
Banrox may not disclose your nonpublic personal information to a nonaffiliated company unless you have agreed to it in writing first. Federal law would let Banrox share and leave you to object afterwards. California does not. Banrox needs your yes before, not your objection after. The one thing that does not need a separate signature is a disclosure needed to carry out something you asked for: when you ask to be matched with a lender, a bank, a card issuer or an insurer, that request is your instruction and Banrox acts on it. Banrox discloses your information to no other nonaffiliated company for any other reason.
Companies related to Banrox
For sharing among companies under common ownership with Banrox, California gives you an opt out rather than an opt in, after a clear written notice once a year, and you may change your mind at any time. Banrox has no affiliates and shares with none, so there is nothing to opt out of today. If that ever changes, Banrox will send you the annual notice and the opt out before any affiliate sharing begins.
The form, and what exists today. California requires this choice to be offered on a standalone form headed "IMPORTANT PRIVACY CHOICES FOR CONSUMERS", separate from every other notice, which you sign and return. Banrox will send you that form on request today. Email [email protected] or call (888) 888-6401 and Banrox will email or post it to you. Banrox is adding the form to account settings so that you can complete it without asking anyone. Until that is live, asking is the only route, and this page says so rather than send you to a page that does not exist yet.
Two things that follow from this. Banrox never treats your silence as consent. Until Banrox holds your signed consent, the answer for a nonaffiliated company is no. And the mail in form at the bottom of this page is a different form: it records your federal choice and your state opt outs, and it is not the California consent form.
Mail In Privacy Choices Form
Complete, print and mail to: Banrox Inc., Attn: Privacy, 40 N Altadena Dr, Ste 105, Pasadena, CA 91107
- Name: _______________________________________________
- Email address on the Banrox account: ___________________
- Mailing address: ______________________________________
- [ ] Do not share my personal information with nonaffiliated companies so they can market to me.
- [ ] Do not sell or share my personal information for any purpose that state law lets me stop.
- [ ] Remove me from all Banrox marketing calls, texts and email.
- Signature: ______________________ Date: _______________
You do not need to use this form. Email, phone, and your account privacy settings are faster and are honoured the same way.
