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Ennoble Finance, LLC Privacy Policy

Effective Date: 12/31/2019
Last Updated: 12/31/2019

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 account balances

Overdraft history

Transaction history and account information

When you are no longer our customer, we continue to share your information as described in this notice.

Please note: If you are a new customer, we can begin sharing your information 30 days from the date you complete your first transaction.

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 Ennoble Finance, LLC Revolve Finance (hereinafter "Revolve Finance") chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Revolve Finance 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 No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes - information about your transactions and experiences Yes No
For our affiliates' everyday business purposes - information about your creditworthiness Yes Yes
For our affiliates to market to you Yes Yes
For non-affiliates to market to you No Yes

Questions? Call 1-855-587-7858 or visit www.revolvefinance.com

Who We Are

Who is providing this notice?

You are receiving this notice from Revolve Finance. Revolve Finance provides services for the purpose of establishing, maintaining, and managing your electronic demand deposit account at Republic Bank of Chicago ("Account").

What We Do

How does Revolve Finance protect my personal information?

To protect your personal information from unauthorized access and use, we take reasonable precautions and use security measures that comply with federal law. As examples, these measures include computer safeguards and secured files and buildings. We use encryption software to protect the security of your personal information during transmission of such information through our website (for example, the information you provide when submitting an application for your Account). Additionally, we educate all employees about the importance of confidentiality and customer privacy.

How does Revolve Finance collect my personal information?

We collect your personal information, for example, when you:

Open an account or deposit money

Pay your bills

Use your debit card

We collect personal information on individuals only as allowed by law. We limit the collection of personal information to what is relevant and necessary to accomplish a lawful purpose. We collect your personal information from others, such as credit bureaus, affiliates, other companies and information provided by you, including information we collect when you visit our website, transaction information, and information we collect about you from third-party sources.

We do not collect home, business or email addresses, or account information from persons who simply browse our internet website. The information we do automatically collect includes the domain name or Internet Protocol address that relates to the machine or device used to access our website, the type of browser and operating system used, the date and time when the website is visited, device ID if you are on a mobile device, and web pages displayed.

Like many websites, our website uses “session cookies” and “persistent cookie” technology. Persistent cookies are small text files that our website places within your browser so that it can remember you when you show up again later – like cookie crumbs. None of these cookies store any of your personal information. We use persistent cookies to enhance your experience on our website while also protecting your privacy, as well as enhancing the functionality and performance of our website, and for analytical purposes. On our website, temporary cookies, also called session cookies, may be placed within your browser and expire as soon as you exit our website. Typically, session cookies are used to facilitate interactions between you and the fields in forms on our website.

Managing cookie preferences differs from browser to browser. Please refer to your web browser for further information. If you would like to disable cookies from www.revolvefinance.com, please use the help function in your web browser to restrict cookies from our website.

We use Google Analytics to see how visitors are using www.revolvefinance.com. Google Analytics reports traffic patterns anonymously. We may collect non-identifying information, such as the type of browser and browser version you are using to access our website, the day and time you access our website, the referring website that linked you directly to our website (if you arrived at our website by clicking a link on another website), and limited geographic information. No personally identifiable information is collected for this purpose.

We partner with companies that deliver ads for financial products and services on sites that you visit on the web. In order to provide you with a more appropriate online experience, some of our ads that you may see are based on your previous online activity on our website and other websites. Information about your online activities, combined with other information, may be used to select an ad for a product or service that better matches your interests – which is called online behavioral advertising ("OBA") or interest-based advertising.

You can opt out from receiving ads based on your online behavior by visiting the Digital Advertising Alliance (DAA) opt-out page at http://www.aboutads.info/choices/. If you elect to opt out of OBA, you will still see ads but they may not be as pertinent to you. Please keep in mind that opting out is cookie-based and will only affect the specific computer and browser on which the opt-out cookie is applied. If you delete your browser cookies, or if you use a different computer or a different browser and want to continue to be opted out of OBA, you will need to opt out again. Revolve Finance does not currently have the capability to recognize "Do Not Track" signals or mechanisms from different web browsers.

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 credit worthiness

Affiliates from using your information to market to you

Sharing for non-affiliates to market to you; we do not share with non-affiliates

State laws and individual companies may give you additional rights to limit sharing.

To limit our sharing please email us at customersupport@revolvefinance.com or call 1-855-587-7858.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and non-financial companies. Revolve Finance shares with our Affiliates so they can market to you.

Non-affiliates

Companies not related by common ownership or control. They can be financial and non-financial companies. Revolve Finance may share with non-affiliates so they can market to you.

Joint Marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you. Revolve Finance may enter into formal joint marketing agreements with others from time-to-time.

Other Important Information

For Alaska, Illinois, Maryland and North Dakota Customers

We will not share personal information with non-affiliates either for them to market to you or for joint marketing - without your authorization, unless required by law or regulation.

For California Customers and Residents. Please see below to understand your privacy rights.

We will not share personal information with non-affiliates either for them to market to you or for joint marketing - without your authorization, unless required by law or regulation. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Massachusetts, Mississippi and New Jersey Customers

We will not share personal information from deposit or share relationships with non-affiliates either for them to market to you or for joint marketing - without your authorization, unless required by law or regulation.

For Vermont Customers

We will not share personal information with non-affiliates either for them to market to you or for joint marketing without your authorization, and we will not share personal information with affiliates about your creditworthiness without your authorization, unless required by law or regulation.

Califonia Privacy Rights

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). Ennoble Finance, LLC (“Revolve Finance”, “We”, or “Us”) reserves the right to limit these rights where permitted under applicable law, including where the Personal Information collected about you is subject to the Gramm Leach Bliley Act (GLBA) or the California Financial Information Privacy Act (CalFIPA), where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information

When California Consumers access the Revolve Finance website(s), we collect the following Personal Information.

Internet or other electronic network activity information

  • Browsing history
  • Search history
  • Information regarding a consumer's interaction with an Internet Website, application, or advertisement
  • Internet Protocol address
  • Device ID
  • Cookies
  • Beacons
  • Pixel Tags
  • Mobile Ad Identifiers

The foregoing pieces of Personal Information have been collected about our consumers in the past 12 months. All other Personal Information collected about you by Revolve Finance is in connection with the furnishing financial services and related transactions. Such Personal Information is collected and handled pursuant to the GLBA and/or CalFIPA and is, therefore, exempt from the requirements of the CCPA, including the disclosure requirements.

Sources from which Personal Information is Collected

  • We collect your internet or other electronic network activity information and geolocation information from your interactions with our website.

Business or Commercial Purposes for which Personal Information is Collected

Your Personal Information is used for the following purposes:

  • Authenticate your identity;
  • For marketing purposes;
  • Respond to court orders and legal investigations;
  • Safeguard against potential fraud;
  • Protect data from unauthorized parties and comply with legal requirements;
  • Enforce this Privacy Policy, Terms of Use, and any other agreements you have entered into with us;
  • Provide you with targeted advertising based on your activity on our sites;
  • Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality; and
  • Investigate and prevent activities that may violate our policies.

Third Parties with whom Personal Information is Shared

Revolve Finance shares your Personal Information with affiliates, analytics providers, service providers, IT vendors, and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

In the preceding 12 months, we have disclosed the following Personal Information about consumers to third parties for business or commercial purposes:

  1. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
    1. Internet or other electronic network activity information
  2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
    1. Internet or other electronic network activity information
  3. Debugging to identify and repair errors that impair existing intended functionality.
    1. Internet or other electronic network activity information
  4. Performing services on behalf of the business or service provider, including providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
    1. Internet or other electronic network activity information
  5. Undertaking internal research for technological development and demonstration.
    1. Internet or other electronic network activity information

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold

California Consumers have the right to request that Revolve Finance disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

  1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
    1. Categories of Personal Information collected;
    2. Categories of sources from which Personal Information collected;
    3. Business or commercial purpose for collecting or disclosing Personal Information; and
    4. Categories of third parties to whom Personal Information is disclosed for a business or commercial purpose.

Revolve Finance does not sell any Personal Information of California consumers. If we did sell your Personal Information you would have the right to know the categories of Personal Information Revolve Finance sells, the business or commercial purpose of the sale, and the categories of businesses to whom we sell the Personal Information.

  1. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
    1. Specific pieces of Personal Information collected about you.

This information will be provided to you free of charge, unless Revolve Finance determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

Right of Deletion

You have the right to request that Revolve Finance and our service providers delete any Personal Information about yourself that Revolve Finance has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Submitting Requests

You can submit your request by calling us at 1-855-214-3711. You may also submit a request via email at privacy@revolvefinance.com.

Personal Information Collected Pursuant to GLBA and/or CalFIPA

Much of the Personal Information collected about you by Revolve Finance is in connection with the furnishing of financial services and related transactions. Such Personal Information is collected and handled pursuant to the GLBA and/or CalFIPA and is therefore exempt from the requirements of the CCPA, including the consumer request requirements described in this section. If you have sought or received financial services and related transactions through Revolve Finance, you do not have a right to know or deletion and Revolve Finance will not fulfill such request.

Verifying Requests

Revolve Finance provides California Consumers with the ability to submit requests through our telephone number, and our email address. Revolve Finance must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to five (5) pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity. Revolve Finance reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Please note that Revolve Finance does not have the ability to verify California consumers who have visited the Revolve Finance website, but have not otherwise sought or obtained financial services and related transactions through Revolve Finance. If you have only visited the Revolve Finance website, we will not be able to satisfy your consumer request.

Authorized Agent

You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Revolve Finance requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Revolve Finance. Failure to do so may result in Revolve Finance denying your request.

Right to Equal Service

Revolve Finance will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

  • Denying goods or services to you.
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  • Providing a different level or quality of goods or services to you.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Us

If you have any questions, you can contact us at:

Phone: 1-855-214-7311

Email: privacy@revolvefinance.com