Pinwheel Terms & Policies

Contents

Website Privacy PolicyEnd User Privacy PolicyTerms of ServiceResponsible Disclosure PolicyDeveloper PolicyWhistleblower Policy

End User Privacy Policy

Last Updated: April 14, 2020.

Underdog Technologies, Inc., d/b/a Pinwheel (“Pinwheel,” “we,” “us,” or “our”) allows individuals (“End Users”) to connect payroll accounts to our third-party customers (“Customers”) such as financial institutions and control where your direct deposits are sent (the “Service”). Pinwheel has prepared this Privacy Policy to explain what Personal Data (defined below) we collect from End Users in connection with providing the Service, how we use and share that data, and your choices concerning our data practices.

Before using the Service or submitting any Personal Data to Pinwheel, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

Please note that this Privacy Policy does not describe how the Customers whom you grant access to your payroll accounts use your and share your Personal Data. Please review the privacy policies made available by such Customers to learn more about their practices.

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:

Identification Data

We collect your name, email address, mailing address, log on credentials, and social security number.

Financial Data

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.

Employment Data

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:

Cookies

We use cookies to operate and administer the Service, gather Internet Activity Data on the Service, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

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:

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.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at  http://www.networkadvertising.org and follow the opt-out instructions there. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

How We Use Personal Data

We may use Personal Data for the following purposes:

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

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:

With your consent we will also disclose your Personal Data to our Customers.

Update your Information

Please contact us if you need to change or correct your Personal Data.

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.

Privacy Rights

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”):

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.

Please contact us if you have questions about your rights or our disclosures under the CCPA, or to request access to an alternative format of this Privacy Policy.

Children

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.

Links to Other Websites

The Service may contain links to other websites not operated or controlled by Pinwheel, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

Security

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.

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.

Changes to the Privacy Policy

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

Privacy Notice

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@getpinwheel.com.

Facts
What does Underdog Technologies, inc. d/b/a Pinwheel ("Pinwheel") do with your personal information?
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 bank account routing and account numbers.
  • Salary and/or hourly wage rate.
  • Paystub and Form W-2, W-4, and 1099 information.
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 Pinwheel chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
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.
No
For our marketing purposes to offer our products and services to you.
No
For joint marketing with other financial companies.
No
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
Questions?
Who we are
Who is providing this notice?
This notice is being provided on behalf of Underdog Technologies, Inc. d/b/a Pinwheel.
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.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Pinwheel has no affiliates.
Nonaffiliates
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.
Joint Marketing
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.