- E-Sign Consent for Electronic Communications and Disclosures
- California Resident Rights Under the California Consumer Privacy Act (“CCPA”)
E-Sign Consent for Electronic Communications and Disclosures
Ingo Money is required by law to provide certain disclosures to consumers who enroll in and use the Ingo Money Service. We can only provide these disclosures and other information electronically if you consent. Upon acceptance of this Agreement, you confirm that you have read, understood, and consent to electronic delivery of disclosures and notices as defined below. You agree that Ingo Money can provide disclosures and notices required by law and other information about Ingo to you electronically by posting it on our website at www.ingomoney.com, or by emailing it to the email address listed in your Ingo customer account profile. You also agree that electronic disclosures and notices have the same meaning and effect as if we had provided you with paper copies. Such disclosures and notices are considered received by you within 24 hours of the time posted to our website at www.ingomoney.com, or within 24 hours of the time emailed to you unless we receive notice that the email was not delivered.
In this Consent for Electronic Communications and Disclosures, the following definitions apply: “you” means the person to whom an eligible prepaid card, debit card, or other eligible account has been issued and who is applying to enroll in and/or has been accepted to use Ingo. “We,” “our,” and “us” mean Ingo Money, Inc. and First Century Bank, N.A. and any person, company, bank or financial institution that is an assignee of Ingo Money or First Century Bank’s rights.
2. Consumer Consent.
By checking the “I agree to have the Terms and Conditions presented electronically,” which you hereby adopt as your electronic signature, you consent and agree that:
A. We can provide disclosures required by law and other information about your legal rights and duties to you electronically.
B. Your electronic signature on agreements and documents has the same effect as if you signed them in ink.
D. If you want a paper copy, you can print a copy of the Disclosures or download the information for your records from the Ingo website at www.ingomoney.com.
E. This consent applies to your use of Ingo, to all future Disclosures associated with Ingo, to all future transactions in which you use Ingo, at any time, and to other Disclosures that we provide to you by email, unless you have, prior to such transaction, withdrawn your consent by the procedure mentioned below.
3. Hardware and Software Requirements.
You understand that in order to access and retain the electronic Disclosures you will need the following:
A. A computer or mobile device with an Internet connection.
B. A current web browser that includes 128-bit encryption. (Minimum recommended browser standards are Microsoft Internet Explorer version 6.0 and above, Firefox version 1.5 and above, or Safari 2.0 and above.) The browser must have cookies enabled.
C. A valid email address.
D. Sufficient storage space to save past Disclosures and/or an installed printer to print them.
E. If you use a spam filter that blocks or re-routes emails from senders not listed in your email address book, you must add Ingo’s email to your email address book.
4. Requesting Paper Documents and Withdrawing Consent.
You understand that you may request paper copies of the Disclosures within 180 days of the date of the Disclosure, and that we will provide them to you by mail at no charge. You understand that you have the right to receive these Disclosures in paper form and that you may withdraw your consent by calling (229) 276-3990. You can also request paper copies and/or withdraw consent by contacting us at:
Ingo Money Customer Support
11545 Wills Road
Alpharetta, GA 30009
Any withdrawal of your consent to receive electronic Disclosures will be effective only after we have a reasonable period of time to process your withdrawal. You understand and agree that if you withdraw your consent to receive electronic Disclosures we may – though we are not obligated to – cancel your enrollment in Ingo.
5. Updating Email Address.
At any time, you can update the email address to which we will send alerts that your Disclosure is available. You can change your email address by calling (229) 276-3990. It is your responsibility to keep your primary email address and contact information up to date so that we can communicate with you. Any communication we send to your contact information on file will be deemed received by you. You agree to provide us with and maintain a valid e-mail address. You can update your information through the Ingo App.
6. Legal Effect.
By consenting, you agree that electronic Disclosures have the same meaning and effect as if we provided paper Disclosures to you. When we send you an email or other electronic notification alerting you that the Disclosure is available electronically and make it available online, that shall have the same meaning and effect as if we provided a paper Disclosure to you, whether or not you choose to view the Disclosure, unless you had previously withdrawn your consent to receive Disclosures electronically. You understand and agree that Disclosures are considered received by you within 24 hours of the time posted to our website at www.ingomoney.com, or within 24 hours of the time emailed to you unless we receive notice that the email was not delivered.
Information we collect
Our website, mobile apps and services collect the information you voluntarily provide including:
- Your username and password
- Your name, physical address, e-mail address, phone numbers and other contact information
- Information that you provide to verify your identity such as your social security number
- The card or account number for any prepaid or debit cards, or other eligible accounts you use with our services
- The amount, payee and other details of checks that you capture using our mobile apps
- Information stored on your mobile device that you permit our mobile apps to access, such as images or contacts
Our website, mobile apps and services may also automatically collect certain information including:
- Technical details about your computer and browser or mobile device
- The location and unique ID of your mobile device
- The sequence of links that you follow across our site or to or from our site
- The screens and features that you use in our mobile apps
We may also collect or use third parties to collect additional information about you including:
- Background information about you
- Details of any transactions you conduct using our service
We may collect or receive information about you from your card issuer or card program manager, such as identification information or information about your card account.
How we use the information we collect
- In general, we use the information that you provide for the purposes described when we collect it, to identify you, and to process transactions or provide other services to you.
- We also use the information you provide and information that we collect to improve our services, website and mobile apps, to manage risk associated with transactions, to assist you with customer service inquiries, and to detect and deter fraud.
- Our website, mobile apps and services may interact with or link to third party sites, mobile apps and services. We cannot control how these third parties use any information that you choose to share with them. Please check the privacy notices and terms of service established by these sites, mobile apps and services.
Your privacy rights
What information we collect
We collect four main types of information when you visit this site or use the Ingo mobile apps: login information, usage data, invite requests, and customer and transaction information. In the normal course of browsing the site and using the Ingo mobile apps, we may also collect usage information such as your IP address, browser type, phone type, and device identifier, your physical location, language settings, and the URLs of any referring or exit pages. We can also keep track of how much time you spend on the site or on different screens of our mobile apps and any links you visit from the site or within the mobile apps.
When you request an invite, you have to provide us with your name and email address. When you sign up to use Ingo, we will ask you for your name, address, phone number, email address, date of birth, social security number, and other information. You will also be asked to choose a Username and Password.
In order to deliver funds, customers have to provide us with the card or account number of an eligible prepaid or debit card, or other eligible account. We may also request your online log in credentials to provide you with access within the Ingo mobile apps or website to your balance, transaction history and other information. We may receive information about you or your card account from your card issuer or card program manager.
We collect information on each transaction you perform using Ingo. Transaction information includes time, dollar amount, check details, and funds destination (e.g., your prepaid card, debit card, or other eligible account). We may also collect background and other information about you from reporting services, credit agencies, and social networks. By using our services, you agree to our collecting this third-party information.
When you use our mobile apps, we collect the information that you enter into the app and information already stored on your device that you permit the app to access. For example, you may give the app permission to access contacts stored on your device and the app may send that information to us. We may also automatically collect information about your location and certain technical information about your mobile device including its make and model, operating system version, and device identifier. Our mobile apps also contain analytics features that track how you use the applications. These features periodically send information to us or our trusted analytics provider about the features and screens you access in the apps and we use this information to improve the apps.
Email, mailing lists, and other services
We use your email address to send you notices, provide information in connection with our services, and to respond to your inquiries. You may request that we stop sending you information by email by following the instructions in emails that we send to you. Some of our services require that we have your email address and use it to send notifications to you and may become unavailable if you choose to no longer receive this information from us. We will not use your email address to send you any unsolicited message or information, nor will we share it with, or sell it to, anyone else for such use, other than as specified in this policy. We will not use your email address or other information to provide you with any unsolicited message or information (unless the message or information is part of the service you are requesting) without your prior consent.
Modifying your information
If you have provided us with information and would like to make changes to it or how we contact you, please get in touch with us by calling us at (229) 276-3990 or emailing us at firstname.lastname@example.org. If you cancel your Ingo Money customer account, we will note your account as “closed” in our database, but we will retain personal information from your account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce our User Agreement, or as otherwise required or permitted by law or this policy.
What we do with the information we collect
- We use invite request information to track how many people are interested in our services.
- If you complete the sign up process, we store your information in our secure servers and use the information to confirm your identity, process and review checks for approval that you submit to us, collect any checks that you present to us that are rejected or returned for insufficient funds or other reasons, identify potential fraud, report suspicious and other activity to applicable agencies, and provide access to our services.
- We use anonymous web usage information to analyze how people use our site and to help direct improvements for our site. We aggregate this information in a way that does not identify you personally. We may share this aggregate data with our affiliates, agents, and other third parties.
- We store and use your financial transaction information so that you can access it from our various services, websites, and mobile apps, to allow us to improve our services and provide services to you, to enhance security and identify suspicious activity and transactions, and to assist you with customer service inquires.
- If we or any of our affiliated companies or lines of business are acquired, we may transfer all of your information to the buyer along with other business assets. If any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered one of our assets and may be sold or transferred to third parties.
With whom we share information
We may share your personal information with unaffiliated third parties as permitted by law, or if we believe such action is necessary in order to:
- conform to the requirements of the law, regulations, and the requirements of government and regulatory agencies,
- comply with any court order, regulatory directive, or other legal process;
- protect or defend our legal rights or property, our website, or our users;
- investigate, reduce, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the terms and conditions for using our websites and services, or
- enhance our risk management or ability to process transactions or provide services to you or our clients.
We may share information with the issuer, program manager, or distributor of any card or account that you ask us to fund for risk management, fraud prevention, or other business purposes such as enhancing their ability to provide services to you in relation to your account. We may also share information with a service provider that performs marketing services on our behalf, or with a financial institution with whom we may conduct joint marketing.
Affiliated businesses and links to other sites
We employ other companies and individuals to perform services on our behalf, such as (1) administering technical services, (2) sending emails, (3) providing marketing assistance, and (4) analyzing data. Some of these companies and individuals will have access to the personal information necessary to perform their services but will not be permitted to use it for any other purpose.
How we protect your information
We take commercially reasonable steps to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We encrypt personal information using appropriate encryption technologies. We consider security at all layers of our business and services, using technologies and physical and procedural safeguards designed to help ensure the security of the information that we collect. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to and from us over the internet. In particular, email may not be secure, and you should therefore take special care in deciding what information you send to us via email.
This is an American web site
This website is operated from within the United States and our mobile apps send information to computer servers in the United States. If you are located outside of the United States, please be aware that any information you provide to us or enter into our mobile apps will be transferred to the United States. By using the website or mobile apps or providing us with any information, you consent to this transfer.
We are not responsible for external web sites
Under the California Consumer Privacy Act (“CCPA”), you have the right to request disclosure of the information we collect, use, disclose and sell about you, free of charge no more than twice per 12-month period. To request this information, you may send your request to ConsumerPrivacy@ingomoney.com. Please be sure to send your request from the email address associated with your Ingo Money profile using “Consumer Privacy” in the subject line of your email. Please also include your full name, address and the nature of your request in the email. You may be required to provide additional identifying information, including “selfie” and copy of current, unexpired picture identification for verification purposes. You may also contact us at 1-877-206-5884. To learn more about your rights under “CCPA” please refer to the California Resident Rights Under the California Consumer Privacy Act section below.
How to contact us
If we need to contact you concerning the information that you provided we may do so by telephone, email, or mail.
© 2020 First Century Bank, N.A.
© 2020 Ingo Money, Inc.
California Resident Rights Under the California Consumer Privacy Act (“CCPA”)
CCPA provides California residents the following rights:
Right to know about personal information we collect
- Identifiers: including real name; email address; username; password; physical address; unique profile identifier; device IP address; device identifier; Social Security Number; Date of Birth; and in some cases, a Driver’s License or Passport number.
- Personal information: including telephone number; credit card number including account status; debit card number, including account status; signature and physical characteristics, if Driver’s License or Passport image are collected; device type; device identification number; mobile service provider for device used to access the service; and details of any transactions you conduct using our service.
- Electronic activity information: including, but not limited to information regarding interaction with the mobile application.
- Geolocation data: your physical location at the time of connecting to the mobile application.
Right to know the categories of sources from which we collect personal information.
- We collect information from you, the consumer, as provided during the enrollment process and each subsequent login in or transaction.
- We collect information from third party service providers in the normal course of business for things such as identity verification, fraud mitigation, credit card and debit card verification.
Right to know the business purpose for collection or selling of personal information.
- We use the information that you provide for the purposes described when we collect it, to confirm your identity, and to process transactions or provide other services to you at your request.
- We use the information we collect to manage risk associated with transactions, to assist you with customer service inquiries, and to detect and deter fraud.
- We may collect and use your transaction information to enhance security and identify suspicious activity and transactions and so that you can access it from mobile apps.
- We may collect information in order to comply with legal, regulatory and contractual obligations.
Right to know about personal information we share.
- We may share your personal information with unaffiliated third-party service providers.
- Card or program issuer of the card account you provided for funds loading.
- Government or regulatory agencies as legally required in response to subpoenas, court orders and other verified legal requests.
Right to know the categories of personal information we have sold in the past 12 months.
We do not sell any information we collect about consumers.
Right to request deletion of personal information.
You have the right to request that we delete personal information we have collected about you.
Right to opt out of the selling of personal information.
We do not sell any information we collect about consumers.
Right to know about personal information we have collected in the past 12 months
You have the right to know the specific pieces of information we have collected about you in the past 12 months.
We will not discriminate by diminishing the goods or level of service provided you; increasing fees associate with your use of the service; or denying you access to the service as result of exercising your rights under CCPA.
Requests by Authorized Agents
You have the right to allow an authorized agent to make a request on your behalf, by way of written authorization from you. Such authorization must include either a limited or full power of attorney or other proof of your written permission authorizing your agent to act on your behalf in making a request under CCPA.
You may submit your requests as noted above to ConsumerPrivacy@ingomoney.com. Please be sure to send your request from the email address associated with your Ingo Money profile using “Consumer Privacy” in the subject line of your email. Please also include your full name, address and the nature of your request in the email. You may be required to provide additional identifying information, including a “selfie” and copy of current, unexpired picture identification for verification purposes.
All requests will be acknowledged within 10 days from receipt. Response to requests will be provided within 45 days of request and identification verification. If more time is needed to fulfill the request, you will be notified within the stated 45 days and it may take up to 90 days to complete the request.