Last Updated: April 08, 2018
What Types of Information Does Onward Collect Through the Sites?
The information we collect through the Sites includes certain “Personally Identifiable Information” (or “PII”), which is information that identifies you as an individual. We collect PII through the Sites when you voluntarily provide it, such as by requesting information, completing a user profile to create an Onward account, or using the Onward platform to open an account at our partner bank (Evolve Bank & Trust). To create an Onward account, you will need to provide PII such as your full name, postal address, email address, date of birth, gender, mobile phone number, and profession. To open up an account at our partner bank, you will additionally need to provide your Social Security number and a copy of a government-created identification card, but we do not ourselves retain that information; we merely allow you to transmit it by using our Sites.
How Does Onward Use the Information It Collects?
We may use the PII that we collect about you for any or all of the following purposes:
- Respond to Your Inquiries. To respond to your inquiries, such as those you may submit through our “Contact Us” page or send to us by email.
- Process Your Requests. To enable you to use our platform to open an account at our partner bank, and to transmit your requests for banking transactions (e.g., fund withdrawals, loan requests, disbursements) to our banking partner.
- Send You Information. We may use your contact information to send you various types of information, including information on your transactions, Onward updates, new services, and other related items of potential interest. You may unsubscribe to our commercial emails by using the “unsubscribe” function in any of those emails.
- Improving Our Service and Outreach. We may use PII about you, such as your feedback and comments, to make our communications with you more relevant, including by requesting further feedback, and for related internal purposes such as data analysis, audits, identifying usage trends, and enhancing our services.
- Furthering our Mission. We use PII about you, such as your expressions of interest and your participation in our specific programs, to help inform our decision-making as we proceed to fulfill our mission of fostering personal financial responsibility.
- Other Information. We use your IP address for account verification purposes. To the extent we link your IP address to the PII you provide to us, we treat the IP address as PII in accordance with this Policy.
With Whom Does Onward Share PII Collected Through the Sites?
- Third Party Service Providers and Partners. We share PII with unaffiliated third parties who provide us with services, such as data storage and technology. We also share PII with our partner bank, which handles the financial accounts we enable our Site users to establish. We do not share PII with unaffiliated third parties for their own marketing purposes.
- Acquirers or Assignees. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Onward or its assets, we may transfer any and all information that we collect from Site users to the acquiring party or assignee.
- Entities Entitled Under Law. We may also disclose PII as we believe to be appropriate in the following circumstances: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Sites, including this Policy; (v) to protect and defend our rights and property; (vi) to protect the interests of Onward or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law.
How Can You Manage PII We Maintain?
To keep your PII accurate, current, and complete, please contact us as specified in Paragraph 7 below. We will take reasonable steps to update or correct PII in our possession that you have previously submitted via the Sites. Please note that we are not responsible for correcting, updating or deleting any information in the databases of third parties.
How Does Onward Protect and Maintain PII Collected Through the Sites?
- Data Retention. As noted above, we retain limited PII about you, not including specific financial account information, your Social Security number, or copy of your government-issued identification card. We will retain PII about you for the period necessary to fulfill the purposes of the services you elect to receive and as outlined in this Policy.
- Security. We will take reasonable steps to protect your PII as you transmit it from your computer or mobile device(s) to our Sites and to protect it from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. SSL encryption is enforced on traffic to and from the Sites, we have minimized our storage of PII through reliance on our trusted vendors. However, you should be aware that no Internet transmission is ever fully secure or error-free; in particular, e-mail transmissions may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them from disclosure or misuse.
- Data Retention. We will retain PII about you for the period necessary to fulfill the purposes outlined in this Policy.
- Use of the Sites by Children. The Sites are not directed to children under the age of thirteen (13), and we do not knowingly collect PII from any children under age 13. If you are under age 13, please do not submit any PII to us.
- International Transfers of Information. The Sites are intended for users in the United States. By using any Site, you are deemed to understand and unambiguously consent to the collection and processing of your PII in the United States, with the awareness that the laws of the United States may not provide as much protection for PII as the laws of certain other countries or territories.
Onward Financial, Inc.
3400 Prospect Street, N.W.
Washington, D.C. 20007