Dwolla Privacy Policy

Last Updated: January 10, 2017

Dwolla, Inc. (“Dwolla”) is committed to protecting your privacy and earning your trust. This Privacy Policy discloses our privacy practices for personal information we collect when you use or access our products, services, features, or content through any website, application, or service (“Dwolla Services”), even if you have not opened a Dwolla account or visited our websites www.dwolla.comwww.dwollalabs.com, or our mobile application (“Dwolla Sites”). We may, in our sole discretion, change this Privacy Policy from time to time by posting a revised version at www.dwolla.com/legal/privacy. If we make any material change, we will notify you by email (as listed in your account profile) or by means of a notice on www.dwolla.com/legal/privacy prior to the change becoming effective.

What information does Dwolla collect

If you use or access the Dwolla Services, or open a Dwolla account, we may collect the following personal information:

  • Contact information, such as your name, address, phone, email, and other similar information.
  • Financial information, such as your full bank account number if you choose to use it with the Dwolla Services.
  • Detailed personal information, such as your date of birth or social security number.
  • Other personal information, such as credit information, provided by third parties such as credit bureaus and identity verification services.
  • Your photo or “avatar” if you choose to add one to your Dwolla profile. Other users of the Dwolla Services may be able to view your photo. You may remove your photo or change it at any time in your account settings.
  • Information that you provide to Dwolla when interacting with our customer support team or other team members via phone, email, online form, or other correspondence.
  • Personal information stored with third parties that you choose to provide to Dwolla, such as social media account information and your social media contacts. By linking your third party accounts or using third party sign-in services, you authorize Dwolla to have access to this information and you agree that Dwolla may collect and use this information in accordance with this Privacy Policy.
  • Personal testimonial information or endorsements that you voluntarily provide to us and which we may display with your name on the Dwolla Sites with your consent. To update or delete your testimonial, contact us at privacy@dwolla.com.
  • Email and/or phone number for your contacts that you enter into Dwolla payment flows. We use this information to notify your contacts that you have sent them a payment and/or payment request.

We also collect the following information from your device when you use the Dwolla Services, including your mobile device when you use our mobile application: your IP address, the type of device you use, your device identifier, your operating system version, the type of browser you use, your location, and the URL that you came from and the next URL that you visit.

If you enable location-based services in the mobile application, Dwolla will collect your location-based information in order to show you places that you search for on a map. We will only share this information with our mapping provider for the sole purpose of providing you this service. You can turn off location-based services at any time by editing your settings at the device level.

We use mobile analytics software to allow us to better understand the functionality of our mobile application. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.  We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Services.

How does Dwolla use the personal information that it collects?

We collect your personal information to:

  • Provide the Dwolla Services to you.
  • Notify you about your account activity.
  • Process transactions and collect fees.
  • Provide customer support and resolve disputes.
  • Verify your identity and account information.
  • Identify, prevent, and report potentially prohibited, fraudulent, or illegal activities.
  • Customize and improve your Dwolla experience and the Dwolla Services.
  • Contact you at your telephone number by voice or SMS to validate the telephone number or your Dwolla account.
  • Notify you about important changes to the Dwolla Services and/or Dwolla’s terms and conditions.
  • Provide you with news, offers, and information about the Dwolla Services based on your communications preferences.
  • Any other purpose that we disclose to you in the course of providing the Dwolla Services to you.

How does Dwolla share my personal information?

We may share your personal information as follows:

  • When you send or receive money using the Dwolla Services, we will provide the other Dwolla user with your registered name, city and state, and your avatar photo (if any).
  • If your payment to another Dwolla user fails, we may provide that user with details of the unsuccessful payment.
  • With third parties to provide, maintain, and improve the Dwolla Services, including fraud prevention, identity verification, analytics and marketing services, and financial institutions and other partners that are part of the payment process.  These companies are authorized to use your personal information only as necessary to provide these services to us.
  • With third parties upon your request. For example, you may ask Dwolla to confirm your status as a Dwolla user with a third party merchant.
  • If we believe disclosure is reasonably necessary to comply with any applicable law, legal process, or government request; to investigate or bring legal action against someone who may be violating our rights, our terms and conditions, or the rights of others; or to protect the safety and security of Dwolla, our users, or the public.
  • With a third party if we are involved in a merger, acquisition, or sale of all or a portion of our stock or assets. If this occurs, you will be notified of any change to this Privacy Policy, as well as any choices you may have regarding your personal information.
  • We may share aggregated, non-personally identifiable information with third parties.

Other than as stated in this Privacy Policy, Dwolla does not disclose or sell any of your personal information to third parties without your consent. Please note that third parties, such as merchants that you pay and third party websites that you visit, have their own privacy policies. Dwolla is not responsible for the policies and practices of such third parties and we encourage you to review their privacy policies.

How does Dwolla use cookies and web beacons?

Dwolla and its marketing, analytics and fraud prevention service providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about Dwolla’s user base, and we may receive such information on an individual and aggregated basis from such providers.

We use cookies to provide you with a personalized experience by recognizing you when you return to the Dwolla Sites; better understand our users by tracking how they use the Dwolla Services; improve the design and content of the Dwolla Sites by tracking how users interact with the Dwolla Sites; and identify and prevent fraudulent activity. You can change your browser settings to refuse cookies, but this may interfere with your use of the Dwolla Sites.

We gather certain information about our website visitors automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Services.

We may partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you do not want this information to be used for the purpose of serving you interest-based ads, you may opt-out by clicking here. This does not opt you out of being served ads and you will continue to receive generic ads.

We use Local Shared Objects, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website also use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here.

The Dwolla Sites include social media features that allow you to “Like” or share content on third party sites. These features may be hosted by the third party sites or the Dwolla Sites, and may collect your IP address, the Dwolla Site page you are visiting, and may set a cookie to enable the feature to function. This Privacy Policy does not apply to third party cookies, web beacons, social media features and widgets (such as the Facebook Like button), or other tracking technologies used by third parties. Dwolla is not responsible for the privacy policies and practices of such third parties.

How do I opt-out of receiving promotional emails from Dwolla?

If you prefer not to receive promotional emails from Dwolla, click on the unsubscribe link at the bottom of any promotional email that we send you to remove your email address from future promotional email campaigns. If you have difficulty with the unsubscribe process, contact us at privacy@dwolla.com.

What security precautions does Dwolla take to protect me?

We have security measures in place to protect your personal information, including the use of industry-standard data encryption technology and internal policies and restrictions regarding the storage of and access to your personal information. Please note that no data transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. Dwolla’s servers and business operations are entirely located in the United States. If you have any questions about the security of your personal information, you can contact us at security@dwolla.com.

How do I update my information?

If your personal information changes, you can update or correct it in your account settings by logging into your account at www.dwolla.com.

We will retain your information for as long as your account is active or as needed to provide you the Dwolla Services. If you wish to close your account or request that we no longer use your information to provide you the Dwolla Services, contact us at privacy@dwolla.comand we will respond to you in a reasonable timeframe. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our terms and conditions.

What about the privacy of children?

Dwolla is a general audience website. Dwolla does not knowingly collect any personal information from anyone under the age of 13.

Public Forums

The Dwolla sites may offer publicly accessible blogs or community forums, which may require creation of an account with a third party. Any information you provide in these areas may be visible to the public, so we recommend that you avoid disclosing personal information. To request removal of your personal information from these areas, contact us at privacy@dwolla.com and we will respond to you in a reasonable timeframe. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Contacting Us

If you have any questions regarding the Dwolla Privacy Policy, please contact us at privacy@dwolla.com or write to us at Dwolla, Inc., Attention: Privacy, 909 Locust Street, Suite 201, Des Moines, IA 50309.