Last Updated: October 29, 2018
When you use, visit, or otherwise interact with the Greenlight Services, the Website, and/or the Application, you will sometimes give information directly to us or to our third-party service providers, including your name, account information, email address, mailing address, phone number, date of birth, or other Personal Information.
Additionally, when you use, visit, or otherwise interact with the Greenlight Services, the Website, and/or the Application, we and our third-party service providers may use technology that stores or collects information sent to us by your computer, browser, mobile phone, or other device. This information may include your IP address, unique device identifiers, or other unique identifier; your device functionality, such as the type of browser, operating system, or hardware used; your device location, which may include a street name and city or GPS-location; mobile network information; your activities within the Greenlight Services, the Website, and the Application; your email address and mobile phone number; and other information. When you use the Greenlight Services, we also collect information about your transactions and your activities, including financial and payment information.
We may also obtain information about you from third parties, including, but not limited to, credit bureaus and identity verification services.
When you use the Greenlight Services, the Website, and/or the Application, we (including our service providers) may place “Cookies” (small data files, including cookies, pixel tags, and/or other local storage provided by your browser or associated applications) on your computer, browser, mobile phone, or other device. We use these technologies to improve Greenlight Services, including to: recognize you as a customer; customize Greenlight Services; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across the Greenlight Services.
We use both session Cookies, which expire and no longer have any effect when you log out of your account or close your browser, and persistent Cookies, which remain on your device until you erase them or they expire. We encode our Cookies so that we or our third-party service providers can interpret the information stored in them. You are free to decline Cookies if permitted by your computer, browser, mobile phone, or other device, although doing so may interfere with your use of the Greenlight Services.
We may use your Personal Information to:
We may share your Personal Information with third parties for the purposes of providing Greenlight Services to you. Third parties may include partner banks and financial institutions; credit bureaus, identity verification services, and collection agencies, as permitted by law; other business entities, in the event of any business reorganization, merger, sale, joint venture, or other disposition of some or all of Greenlight’s business; and law enforcement, government officials, or other third parties as required by subpoena, court order, or other legal requirement or process.
We may also share your Personal Information with the Primary Accountholder and any Sub-Account Cardholder that has been authorized to use Greenlight Services by the Primary Accountholder. A Sub-Account Cardholder’s Personal Information, including but not limited to established spending parameters, pending transactions, approved purchases, and transaction history, will be shared with the linked Primary Accountholder and with the designee of the Primary Accountholder, if applicable.
Greenlight will not share any of your Personal Information with third parties for the third parties’ marketing purposes and only shares your Personal Information with third parties as described in this policy. Greenlight may share aggregated customer information with third parties for the third parties’ marketing purposes, including so that Greenlight may offer you merchant promotions; such aggregated information does not identify a specific individual and does not contain Personal Information.
Greenlight maintains the preferences you have provided to us regarding the use, collection, and sharing of information, including how we may contact you. Some federal and state laws allow you to restrict information sharing in certain instances. You can indicate your preferences regarding information sharing and marketing communications by signing into your Primary Account. A Sub-Account Cardholder may only prevent information sharing with the Primary Accountholder or the designee of the Primary Accountholder by closing the Sub-Account Cardholder’s Sub-Account.
Your Personal Information can be reviewed and edited at any time by logging in to your Primary Account and reviewing your account settings and profile. The Primary Accountholder can also close the Primary Account or Sub-Account by calling Greenlight Customer Service at 1-888-483-2645. If you close your account, we will mark the account in our database as “Closed,” but may retain Personal Information from the account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Cardholder Agreement and Terms of Service, or take other actions as required or permitted by law. If a Sub-Account is closed, the Sub-Account Cardholder’s Personal Information may still be accessible by the linked Primary Accountholder or the designee of the Primary Accountholder if such Primary Account remains open after the Sub-Account is closed.
We store and process your Personal Information on our servers in the United States. We use administrative, technical, and physical security measures to protect the security of your Personal Information against loss, misuse, unauthorized access, disclosure, or alteration. It is your responsibility to make sure that your Personal Information is accurate, and you should promptly update your Personal Information on the Website or Application if your Personal Information changes or becomes inaccurate. We retain information as long as it is necessary and relevant for our operations, typically for as long as a user has an account, though in some instances information may be stored after an account is closed. As noted above, we may retain some information from closed accounts to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Cardholder Agreement and Terms of Service, or take other actions as required or permitted by law. Likewise if your account or membership is terminated or suspended, we may maintain some information to prevent re-registration. We take reasonable steps to securely destroy Personal Information in our possession that is no longer required.
Section 1798.83 of the California Civil Code permits customers who are California residents to request certain information regarding the disclosure of Personal Information to third parties for the third-parties’ direct marketing purposes. If you are a California resident, you may request such information by sending an email request to firstname.lastname@example.org.
We comply with the U.S. Children’s Online Privacy Protection Act (Act) and the regulations implementing it, to the extent the Act and the regulations apply to Greenlight and to Greenlight Services. Greenlight does not knowingly collect personal information, as defined in the Act’s implementing regulations, directly from users in this age group.
If a Primary Accountholder creates a Sub-Account for an individual under the age of 13, only the Primary Accountholder, not the Sub-Account Cardholder, provides information to Greenlight necessary to establish the Sub-Account for the minor Sub-Account Cardholder. Subsequent to the creation of the Sub-Account, Greenlight will only collect and use personal information related to the minor for the limited purpose of providing the Greenlight Services, and such information will never be shared with third parties for any purpose not required or permitted by law, including marketing.