Pinwheel Terms & Policies
Last Updated: April 14, 2020
1. Personal Data We Collect
When you sign up for or use the Service, we collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
We collect your name, email address, mailing address, log on credentials, and social security number.
We collect information related to the payroll accounts you link through the Service, including the bank name, bank account type (i.e., checking or savings), bank routing number, bank account number, and your login credentials to such payroll accounts. We also collect your salary/hourly wage rate and information from documents such as your paystubs, W-2s, W-4s, and 1099s.
We collect your job title, start date, termination data, and your employer’s name, address, and government identification number.
Internet Activity Data
We automatically collect information about the way your interact with the Service. For example, we monitor the number of people that use the Service, peak hours of use, how you navigate/browse the Service, the domains you come to the Service from, the browser you use to access the Service, and your search history. In particular, the following information is created and automatically logged in our systems:
- Log Data: Information that your browser automatically sends whenever you use the Service, including your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Service.
- Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Data: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
- Location Data: We derive a rough estimate of your location from your Internet Protocol address.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
- Internet Explorer
- Mozilla Firefox
- Google Chrome
- Apple Safari
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
2. How we use personal data
We may use Personal Data for the following purposes:
- To provide the Service and allow you to connect your payroll accounts to Customers and modify the recipient of your direct deposits;
- To uniquely identify and authenticate End Users;
- To provide Customers with access to your Financial Data and Employment Data where you consent to such access;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
- To analyze how you interact with our Service;
- To maintain and improve the content and functionality of the Service;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
3. Sharing and Disclosure of Personal Data
In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of [hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services]. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
With your consent we will also disclose your Personal Data to our Customers.
4. Update your Information
Please contact us if you need to change or correct your Personal Data.
5. California Privacy Rights Disclosures
Collection, Disclosure, and Use of Personal Data
The categories of Personal Data we have collected in the preceding twelve months are described above in the “Personal Data We Collect” section. In the preceding twelve months, we have disclosed for business purposes each of the categories identified in that section to the categories of third parties identified in the “How We Share and Disclose Personal Data” section. The business and commercial purposes for collecting Personal Data are described in the “How We Use Personal Data” section. We collect Personal Data directly from you and from the financial institutions at which you maintain accounts you link through the Service.
Where provided for by law and subject to any applicable exceptions, California residents may have the following rights under the California Consumer Privacy Act of 2018 (“CCPA”):
- To know the categories of Personal Data that Pinwheel has collected about you, the business purpose for collecting your Personal Data, and the categories of sources from which the Personal Data was collected;
- To access the specific pieces of Personal Data that Pinwheel has collected about you;
- To know whether Pinwheel has disclosed your Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data;
- To have Pinwheel, under certain circumstances, delete your Personal Data; and
- To be free from discrimination related to the exercise of these CCPA rights.
Pinwheel does not sell your Personal Data.
If you would like to exercise any or all of these rights, you may do so by contacting us. Your authorized agent may submit requests in the same manner. Once we receive your request, we will verify your identity by sending an email to the email address you provide to us.
Our Service is not directed to children who are under the age of 16. Pinwheel does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Pinwheel through the Service please contact us and we will endeavor to delete that information from our databases.
7. Links to Other Websites
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Pinwheel via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
9. Your Choices
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.
What does Underdog Technologies, inc. d/b/a Pinwheel ("Pinwheel") do with your personal information?
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.
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 bank account routing and account numbers.
- Salary and/or hourly wage rate.
- Paystub and Form W-2, W-4, and 1099 information.
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 Pinwheel chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does Pinwheel 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.
For our marketing purposes — to offer our products and services to you.
For joint marketing with other ﬁnancial companies.
For our affiliates' everyday business purposes — information about your transactions and experiences.
We don't share
For our affiliates' everyday business purposes — information about your creditworthiness.
We don't share
For our afﬁliates to market to you.
We don't share
For nonafﬁliates to market to you.
We don't share
What we do
How does Pinwheel 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.
How does Pinwheel collect my personal information?
We collect your personal information, for example, when you
- Create an account with us or provide one of our customers with access to your financial accounts.
- Give us your contact information or contact us with questions.
- Use the service.
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.
Companies related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.
- Pinwheel has no affiliates.
Companies not related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.
- Create an account with us or provide one of our customers with access to your financial accounts
A formal agreement between nonafﬁliated ﬁnancial companies that together market ﬁnancial products or services to you.
- We may engage in joint marketing activities with our customers.
Other important information
California Residents Only: We will not share information we collect about you with nonaffiliates, except as permitted by law, including, for example, with your consent or to provide financial services you have requested.