Last updated November 2021
This Digital Privacy Statement (“Statement”) applies to this BrightFi online site (www.mybrightfi.com) (the “Site”) and the MyBrightFi app (the “Mobile App”). The term “BrightFi” or “we” or “us” or “our” refers to BrightFi LLC and its affiliates. The Site and Mobile App are intended for use by United States residents.
For visitors to this Site, or users of the Mobile App, we may use and share information that we collect on this Site or the Mobile App from or about you in accordance with this Statement and BrightFi’s U.S. Consumer Privacy Notice.
This Statement provides for additional information regarding our privacy practices and your rights and choices. If you are a California resident, please see our California Consumer Privacy Act (CCPA) Notice.
BrightFi is a financial technology company that operates the platform that manages the transactional accounts that run through its Mobile App and Site (“Account”). BrightFi is not a bank. All banking services related to Accounts are provided by Sterling National Bank, Member FDIC. To review Sterling National Bank’s privacy policies, please visit www.snb.com/privacy/.
Personal Information means information that identifies aspecific individual person. This may include provided primarily by you throughforms, applications, or other fields in the Mobile App or on the Site includingname, postal or email addresses, mobile telephone numbers, account numbers,usernames and passwords. We may also collect social security numbers,government ID numbers, and other personally identifiable information when youprovide information while using our online services.
We only collect Personally Information when it is submittedto us voluntarily by the user through our Site and Mobile App in order toprocess applications, onboard applicants, and in connection with completingtransactions you request. We may also collect Personal Information as youinteract with our customer service department or otherwise provide informationto us in connection with your use of a BrightFi account. To use a BrightFiaccount, your identity must be verified. To verify your identity, BrightFi uses an application that collects yourphoto identification, a live “selfie” of you, and also temporarily extracts andcollects certain data from your photograph and your “selfie”, and then usesthat data to conduct a comparison to verify your identity. After the verification, we retain your photoidentification and “selfie” to reverify the account-holder’s identity again ata later date, if necessary.
We share Personal Information with certain affiliates andservice providers in order to maintain and service your account, and tocomplete transactions at your request. We do not share Personal Information withnon-affiliates for marketing purposes. For more information, please review our U.S.Consumer Privacy Notice [linkto BF US Consumer Privacy Notice].
Other Information is any information other than Personal Information that does not reveal your specific identity or does not directlyrelate to an individual, such as browser information, information collectedthrough cookies, pixel tags and other technologies, demographic information,other information provided by you such as your date of birth or householdincome, as well as Aggregated Data and Anonymous Data. Aggregated Data andAnonymous Data is data that we may create or compile from various sources,including but not limited to accounts and transactions. This information, whichdoes not identify individuals or individual account holders, may be used forour business purposes, which may include offering products or services,research, marketing or analyzing market trends, and other purposes consistentwith applicable laws.
Through your browser or device: Certain information is collected by most browsers and/or through your device, such as your IP address, device type, operating system version and internet browser type and version. We use this information to ensure our Site functions properly, for fraud detection and prevention, and security purposes.
Using cookies: Cookies are pieces of information that we store directly on the device you are using. Cookies we use do not contain or capture unencrypted Personal Information. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and your relationship with us. We use Google Analytics and other aggregated analytics tools to track performance and to track visitor sessions, visitors across multiple sessions, and referral sources to our sites. At no time is personally identifiable information passed to Google Analytics. (To understand how Google collects and processes information gathered from this site visit www.google.com/policies/privacy/partners/). Note that Google Analytics stores its data within the United States of America and is subject to United States laws. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize/tailor your experience while engaging with us, and to recognize your device to allow your use of our online products and services. We collect statistical information about the usage of the Site in order to continually improve the design and functionality, to monitor responses to our advertisements and content, to understand how account holders and visitors use the Site and to assist us with resolving questions regarding the Site. We also utilize cookies for advertising purposes. Please see the ONLINE ADVERTISING section below for more information. You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products and services. For example, we will not be able to recognize your device and you will need to answer a challenge question each time you log on. You also may not receive tailored advertising or other offers from us that may be relevant to your interests and needs.
Other technologies including pixel tags, web beacons, and clear GIFs: These may be used in connection with some Site pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving account holders’ questions regarding use of our Site. Please see our ONLINE ADVERTISING section below for more information regarding our use of other technologies.
IP Address: Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, to personalize/tailor your experience while engaging with us online and offline, for compliance and security purposes, for advertising, and administering the Site. Please see the Online Advertising section below for more information.
Mobile Applications: BrightFi’s Mobile App allows you to access your account and perform transactions. This Statement applies to any Personal Information or Other Information that we may collect through the Mobile App. Some mobile devices come with a non-permanent advertising identifier or ID which gives companies the ability to serve targeted ads to a specific mobile device. In many cases you can turn off mobile device ad tracking or you can reset the advertising identifiers at any time within your mobile device privacy settings. In addition, if you have enabled location services on your mobile device, we may collect geolocation data from your device or contact information. You may also choose to turn off location tracking on your mobile device. By turning off ad tracking or location tracking on your mobile device, you may still see the same number of ads as before, but they may be less relevant because they may not be based on your interest. BrightFi does not sell your data for purposes of allowing other companies to serve ads to you on the internet.
Third party widgets – We may allow certain widgets (e.g., social share buttons) on our Sites that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your browsing on pages of our Sites where these widgets are placed. You may wish to review information at the third-party site, such as social media platforms where you have an account, to determine how these third parties collect and treat such information. Also, see LINKING TO OTHER SITES and SOCIAL MEDIA SITES sections below.
BrightFi may use information described in this Statement to help advertise our products and services in a variety of ways, including to present tailored banner and splash ads that appear as you sign on or off your online accounts on our Site, or within our Mobile App; to develop e-mail campaigns; to advertise on third-party sites and mobile apps; and to analyze the effectiveness or our advertisements.
Opting Out of Online Behavioral Advertising: You may opt out of receiving behavioral ads from many sites through the Network Advertising Initiative’s Opt-Out Tool or other tools provided by the publishing platform that produces the advertisement. Please note that if you opt out, you may still receive untailored online advertising from BrightFi or Sterling National Bank. Opting out from a specific third-party site means that the ads you receive will not be tailored based on your choices or behavior.
We may provide links to third party sites, such as credit bureaus, service providers or merchants. Our Privacy Notices and this Statement do not apply to third party sites. If you follow links to sites not affiliated or controlled by BrightFi, you should review their privacy and security policies and other terms and conditions, which may be different from BrightFi’s. BrightFi does not guarantee and is not responsible for the content, privacy or security of these sites, including the accuracy, completeness or reliability of their information.
We may participate in Facebook.com’s Custom Audience or LinkedIn’s Audience programs, which enables us to display personalized ads to persons on our email list when they visit Facebook or LinkedIn, respectively. We provide Personal Information, such as your email address and phone number, to the social media provider to enable it to determine if you are a registered account holder. You may opt-out of receiving these ads from the social media network(s) directly.
To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. We will use reasonable organizational, physical, technical and administrative measures to protect Personal Information within our organization. These measures may include device safeguards and secured files and facilities security to ensure information remains confidential and secure. BrightFi maintains customer authentication procedures to protect your Personal Information and accounts from identity theft.
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative at a banking center or account representative.
The Site and Mobile App are not intended for use by individuals under the age of thirteen (13). We request that these individuals do not provide Personal Information through the Site or Mobile App. We do not knowingly collect information from children under 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).
This Statement is subject to change. Please review it periodically. If we make changes to this Online Privacy Statement, we will revise the “Last Updated” date at the top of this Statement. Any changes to this Statement will become effective when we post the revised Statement on the Site or Mobile App. Your use of the Site or Mobile App following these changes means that you accept the revised Statement.