GLBA Privacy Notice

Rev. Oct. 24

FACTS	WHAT DOES BVNK 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 income account balances and account transactions transaction history and payment history
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 BVNK chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does BVNK share?	Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s), 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	Yes
For joint marketing with other ﬁnancial companies	No	We don't share
For our afﬁliates’ everyday business purposes— information about your transactions and experiences	Yes	Yes
For our afﬁliates’ everyday business purposes— information about your creditworthiness	No	We don't share
For our afﬁliates to market to you	Yes	Yes
For nonafﬁliates to market to you	No	We don't share

To limit our sharing

Call 888-315-0331 – our menu will prompt you through your choice(s) or
Visit us online: https://help.bvnk.com/hc/en-us

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.
However, you can contact us at any time to limit our sharing.

Questions?

Call 888-315-0331 or visit https://help.bvnk.com/hc/en-us.

Who we are
Who is providing this notice?	BVNK

What we do
How does BVNK protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you.
How does BVNK collect my personal information?	We collect your personal information, for example, when you open an account or provide account information make deposits or withdrawals from your account or tell us who receives the money give us your contact information We also collect your personal information from other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes—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. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with a BVNK and/or System Pay Services name; financial companies such as BVNK Holdings Ltd, BVNK Services Ltd and BVNK Technology (UK) Ltd.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. BVNK does not share with nonaffiliates so they can market to you.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. BVNK does not engage in joint marketing.

Other important information

Vermont: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at https://help.bvnk.com/hc/en-us/articles/7662076884882-Privacy-Policy or 888-315-0331.

California: Accounts with a California mailing address are automatically treated as if they have limited the sharing with nonaffiliates as described on page 1, unless and until you authorize us to make those disclosures.