Last Updated: 01/10/2020
The privacy and security of your information is a top priority. This policy is to help you understand how CFSI collects, stores, secures, and shares your information. This policy does not cover what our Clients or third parties might do with your information and you should review their privacy policies to find out more information on their privacy practices.
Personal Information Collected by CFSI and the Sources of Personal Information
CFSI collects information from your financial institution when you provide your financial institution credentials and if required security and multi-factor authentication answers to us. All information is stored in a secure and encrypted environment. In some cases, depending on the client’s needs, a token will be issued so that they are able to make future balance checks and/or pull transaction history from the account you granted access to.
In general, we collect the following types of information:
- The type of institution that you bank with;
- Username, password, security and multi-factor authentication answers;
- Account information such as routing number, account number and account type;
- Account balance information both available and current;
- Account holder names, addresses, phone numbers, and email addresses; and
- Account transaction history including transaction type, transaction amount, transaction date and transaction description.
CFSI’s technology is usually embedded in our client’s websites or mobile applications. When using the technology, we may collect information on your device such as hardware model, operating system type, operating system version, IP address and any other technical information needed for usage analytics and to help improve our services. This information is stored in cookies or similar tracking technologies.
CFSI’s clients may send us information about you directly from their websites, mobile applications or other platform technologies that they use to sell you products and/or services. This information might have come from information that they have on you or third parties that they may use and have passed that information on to us. This information includes your full name, email address, phone number, Social Security number, driver’s license number, date of birth, and transactions that you may be processing or processed with the client.
How CFSI, Our Clients, and Our Partners Use Your Information
CFSI, Our Clients, and Our Partners use your information for the following business purposes:
- To process a Same Day ACH, Next Day ACH, RTP or other type of payment for products or
services that you have purchased through a client or us;
- To verify that your accounts are valid, open and have a positive balance;
- To verify the identity of your contact information.
- To monitor and review account transaction history based on business needs;
- To provide customer support to you and our clients that you do business with using our technology;
- To review the usage and operations of the CFSI site and app and to address any problems;
- To help improve, maintain and develop new products and services;
- To protect you, our clients, our partners, or CFSI from fraud, malicious activity, and other privacy and security related concerns;
- To investigate misuse or unauthorized access of our services or our client’s services.
- To provide you with customized site and app content.
We also may use the information collected from and about you for the following additional purposes:
- To use your data in an aggregated, non-specific format for analytical and demographic purposes; and
- For any other purpose for which you have given consent.
Security and Storage of Your Information
We work hard to protect your information that we collect and store. CFSI uses commercially reasonable standards to protect your information. All data that you provide to us is encrypted and stored in a secure environment that is monitored on a continuous basis. We also review our security practices on a regular basis to make sure we are protecting your information effectively.
Retaining and Sharing of Your Information
We collect the information on you and retain the information until it has fulfilled its purpose and is no longer needed, and as permitted under applicable laws. If our client no longer uses our services or no longer uses your information, we may still retain, process and use your information as permitted under applicable laws or in accordance with this policy.
We share your information for the following business purposes:
- With our services providers, our partners, or contractors in connection with the services they perform for us or clients;
- With requests to comply with applicable laws, regulations, court orders, or subpoenas; or
- As reasonably appropriate to protect rights, privacy, safety, or property of you, our clients, our partners, or CFSI.
We will also share your personal information under the following circumstances:
- With your consent; or
- In connection with a change in ownership or control of all or parts of our business which includes but not limited to mergers, acquisitions, reorganization, bankruptcy, current or future parents, affiliates, subsidiaries, and other companies under common control or ownership.
We do not sell your personal or account information to third parties. We may collect, use, and share information in an aggregated or anonymized manner for the purposes permitted under applicable law.
If you are a California resident, in addition to any other rights described in this policy, you have the following rights:
- You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information that we sold about you, the categories of third parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
- You may request that we delete any personal information that we have collected from you.
To exercise the foregoing rights, please contact us at the email or mailing address in the “Contact Us” section below. You also may contact us at the following toll-free number: (800) 736-5123 If you exercise any of the foregoing rights, we will not discriminate against you, such as by denying you access to our products or restricting your access to products of certain price or quality.
For purposes of compliance with the California Consumer Privacy Act, we make the following disclosures:
- We collect the following categories of personal information: Identifiers, personal information described in Cal. Civ. Code 1798.80, commercial information, and internet or other electronic network activity information.
- We disclose the following categories of personal information for a business purpose: Identifiers, personal information described in Cal. Civ. Code 1798.80, commercial information, and internet or other electronic network activity information.
Changes to this Policy
CFSI reserves the right to change this policy at any time. Any updates to the policy will be found by going to https://portal.followthefrog.com/Home/PrivacyPolicy. Since our client has the relationship with the end user, it will be the responsibility of our client to notify you about changes to this policy, as appropriate. If you have any questions or complaints regarding this policy, please contact us at by using one of the following methods:
Cash Flow Solutions, Inc.
5166 College Corner Pike
Oxford, OH 45056