Last Updated June 10 2015
Our Commitment to Privacy
Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.
The Information We Collect
When you visit the website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use our Service. If you open an account, we collect the following information from you, including but not limited to:
- Identification Information - your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
- Device Information - We also may obtain information about you: (a) from your mobile device such as your device type, machine or mobile device identification number, geo-location, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
- Social Web Information - including but not limited to your email account information and other social web data (including Facebook). If you authorize Facebook, the plug in allows us access to your friends' contact information. We may also allow you to import data from other social web services, including but not limited to Twitter, FourSquare, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve our services and fight fraud). Additionally, another Frank user may mention you in a group note. Financial Information - bank account and routing numbers and credit cards linked to your Frank account. Frank does not share financial information with third party services.
We are committed to providing a safe, secure and all around great service. Therefore, before permitting you to use our service, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.
When you are using our Service, we collect information about your account transactions and trust relationships and we may collect information about your computer or other access device for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.
When you access our website, we, or companies we hire to track how our website is used, may place small data files called "cookies" on your computer.
For example, we send a "session cookie" to your computer any time you log in to your Frank account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don't need to ask you for your password on each page.
Users are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website.
How We Protect & Store Personal Information
We store and process your personal information using third party servers located in secure data centers in the United States, This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Frank password with anyone.
If Frank learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Frank service, you agree that Frank may communicate with you electronically. Frank may post a notice on the Website if a security breach occurs. Frank may also send you an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us.
How We Use The Personal Information We Collect
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:
- provide the services and customer support you request;
- process transactions and send notices about your transactions or your network activity;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
- customize, personalize, measure, and improve our services and the content and layout of our website;
- send you updates about new products and services that we are offering to customers
- compare information for accuracy and verify it with third parties;
- perform other duties as required by law.
How We Share Personal Information With Other Frank Users
To process help your Frank group function effectively, we may need to share some of your personal information with the people that you are connected to. Your name, date of sign-up, photo and your nominees will regularly be provided to other members of groups that you have joined. Information on payment schedules, amount of money taken from a group pot, amount of money put into a group pot, the number of interaction between you and a particular group, voluntary tip rates and additional information MAY be provided to members of a particular group if certain actions are met (including but not limited to a user electing to make the information public and a user not executing on a proposed transfer schedule). Information on voting for other potential members will not be shared with other members of a group
Regardless, we will not disclose your credit card number or bank account number to anyone, except authorized third parties or with your express permission or if we are required to do so to comply with a subpoena or other legal process.
How We Share Personal Information With Other Parties
Frank does not share your email address or phone number with third parties for promotional or marketing purposes
We may share your personal information with:
- Law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order or similar legal procedure, when we need to do so to comply with law we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement, or as otherwise required by law.
- Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our [or any vendor's] behalf.
- Your social web, should you designate your specific Frank account transactions as "public" or “private” payments such that other Frank users in your group can view your payments or when you otherwise request Frank payments be posted to your Frank groups.
How You Can Access Or Change Your Personal Information
You can review and update your personal information at any time by logging in to your account and clicking the Settings tab.
Links To Other Sites
The Website may contain links to other sites. Frank does not control the information collection of sites that can be reached through links from the website. We encourage our users to be aware when they are leaving our site and to read the privacy statements of each website that collects personally identifiable information.
How To Contact Us
If you have questions or concerns regarding this policy, or any feedback that you would like us to consider, please email us at firstname.lastname@example.org. You may also write to us at Frank, Inc Attn: Privacy Department, 115 W 18th St. NY, NY, 10014.