DIRECT, Inc. Privacy Policy

Direct, Inc. Privacy Policy Effective as of December 31, 2021.

Direct, Inc. (“Direct”, “DIRECT”, “we”, “us”, and “our”) is dedicated to protecting your Personal Information and informing you about how we use it. This Privacy Policy (the “Privacy Policy”, or the “Policy”) is intended to provide information to individuals who visit, signup, access or use the Direct website and/or Direct mobile app (“you”, “your”, “user”) about the Personal Information we collect, and how we source, use, disclose, and protect your information when you access or use (1) our websites located at https://www.directb.net/, and all of our other websites to which this Privacy Policy is posted (collectively, the “Website”); (2) our mobile application(s) to which this Privacy Policy is linked or posted (collectively, the “Application”); (3) our rewards program(s); and (4) any services, content, communications, and product features relating to the Website and Application (together with the Website and the Application, the “Services”).

This Privacy Policy covers the privacy practices of Direct with regard to the Services only. It does not cover privacy practices of Direct affiliates or business partners, including but not limited to, Optimize Financial Technology, Inc. (“Optimize”), Engage Financial Technology, Inc. (“Engage”), CBW Bank (Member FDIC) (“CBW”), or MasterCard.

By using or accessing the Services, Website and/or Application, you are consenting to the terms of this Privacy Policy.

1. SECURITY AND PRIVACY OF YOUR PERSONAL INFORMATION

In the course of providing you with the Services, Direct collects certain Personal Information and we are committed to the security and privacy of your Personal Information.

Personal Information is data which, alone or in combination with other information, can be used to identify an individual. This information includes, but is not limited to name, birthdate, social security number, driver’s license number, address, email address, card number, account number, account usage data, commercial information, IP address and device ID. Personal Information does not include information available from public government records, de-identified consumer information, or aggregate consumer information.

We use reasonable and appropriate physical, technological, organizational and administrative measures to handle your information securely, and protect your Personal Information from unauthorized access, disclosure, misuse, loss, and destruction. Measures we have in place include, but are not limited to, encryption of data, role-based systems access, physical access limitations, and regular review of our data policies and procedures.

It is important for you to safeguard your Personal Information including, but not limited to, your Direct Card number, Direct Card expiration date, username and password. Unfortunately, no security method or system can be 100% guaranteed and digital transmission of information via the internet is not completely secure. We encourage you to monitor your Direct Card and Account and if you believe your Card and/or Account has been compromised, please immediately notify us of the problem at 1-833-263-2826.

2. DIRECT DOES NOT SELL YOUR PERSONAL INFORMATION

Direct does not sell Personal Information provided by you or acquired by Direct to third parties.

3. INFORMATION WE COLLECT, PURPOSE, AND SHARING

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.

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 Direct, Inc. chooses to share; and whether you can limit this sharing.

I. Types of Information Collected

The types of Personal Information Direct may collect and share, depends on the product or service you have with us, including the extent to which you may use the Site, enroll and/or use the Services. Specifically, below are the types of information Direct collects.

a. Information You Provide

Examples of information we collect include information you provide to us directly, including but not limited to your name, Social Security Number (SSN), date of birth, email address, phone number, physical home address, owned property address(es), internet protocol (IP) address, device ID, driver’s license number, social media handle, and other similar identifiers.

b. Information about Your Use of the Services

Examples of information we collect include your account number, Card number, pseudonymized validated external routing and account number, mortgage servicer, mortgage loan number, and other pseudonymized financial information. We also collect transaction history using Direct Card and/or Direct Account, including but not limited to, purchases, cash-back transactions, ATM usage, returns, electronic funds transfers (ACH), and direct deposits.

c. Commercial Information

In some cases, we may also collect the address associated with the rewards property you select, your mortgage servicer, mortgage loan amount, mortgage loan rate, mortgage loan term, and Directors Mortgage loan unique identifier. We may obtain this information from third parties including but not limited to Directors Mortgage.

d. Data Collected Automatically through the Services

When you use the Services, certain information is automatically collected and provided to us. This may include your IP address, browser and device type, session IDs, crash reporting data, location data, and number of email addresses per device.

We use “cookies” on the Website. A cookie is a piece of data stored on a user’s hard drive to help us improve your access to the Website and identify repeat visitors the Website. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on the Website. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. The Website may also collect information about your geographic location.

The Website also employs Google Analytics, which uses cookies to collect certain information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Website. On subsequent visits to the Website, frequently used information may be automatically displayed for you. We may be able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Website is transmitted to a Google server, which may be located within or outside of, the United States, and stored there. You can visit Google’s Privacy Policy at https://policies.google.com/privacy to learn more about Google Analytics’ use of cookies.

We integrate the Services with certain third party services that may be able to access data concerning your use of the Services, including but not limited to Google, Facebook, Instagram, and Squarespace. We also use third-party re-marketing tools, including the Google Adwords tracking cookie and Facebook pixel, to serve ads about our services and events online. These ads appear on Facebook, Google products, and other websites across the Internet. The third-party vendors use cookies, web beacons, and similar technologies to tailor the ads based on your past visits to the Site and elsewhere online and to measure ad conversion. You may be able to opt out of a third party’s use of cookies or ad targeting by visiting Google’s Ad Settings page, the Digital Advertising Alliance Consumer Choice Tool at https://optout.aboutads.info/ or the Network Advertising Initiative opt-out page at https://optout.networkadvertising.org/.

II. When We Collect Your Information

We collect your Personal Information, for example, when you:

• Enroll in a Direct, Inc. product, such as a prepaid debit card.

• Open an Account or deposit money.

• Submit an inquiry, feedback or other information to Direct, Inc. via any method including, but not limited to, email, phone, fax, postal mail, social media and in-person.

• Use your Direct Account or Direct App.

• Use your Direct Card.

• Use the Direct Site.

• Enter a contest or sweepstakes.

• Qualify for DIRECT Home Rewards.

  As described above, Direct also collects your Personal Information from others, such as affiliates, non-affiliates, or other companies, and collects some information automatically when you use the Services.

III. Information Collection Purposes

Our purposes for collecting Personal Information include the following:

• Carrying out transactions and facilitating your use of the Services;

• Responding to inquiries from users or the public;

• Managing and providing technical support relating to your use of the Services;

• Communicating with you about your use of the Services or about promotions, offers, or other products or services that may be of interest to you;

• Verifying your identity to comply with applicable laws;

• Meeting our own contractual and legal obligations.

IV. Information Disclosure

Direct discloses your Personal Information to third party service providers to facilitate our provision of the Services to you. Direct requires our Third-Party Service Providers to protect your confidentiality and have reasonable and appropriate safeguards in place to protect information contained in their systems from unauthorized access, disclosure, misuse, loss and destruction. Direct will, as needed, disclose information required by Third-Party Service Providers for your authorized access and use of Services and transactions.

Direct may also share your Personal Information with affiliated companies and partners of ours, as described below, for marketing and promotional purposes. If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. You may opt out of our sharing your Personal Information for this purpose by contacting us via the following means:

• Call 1-833-263-2826, or

• Email clientservice@directb.net, or

• Mail to P.O. Box 2364, Lake Oswego, OR 97034.

When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

In some instances, Direct may also disclose your Personal Information in order to meet our own legal and contractual obligations.

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 non-affiliates to market to you

  State laws and individual companies may give you additional rights to limit sharing.

4. AFFILIATES, NON-AFFILIATES, AND JOINT MARKETING

Affiliates are companies related by common ownership or control. They can be financial and nonfinancial companies. Direct, Inc. affiliates include financial companies, such as Directors Mortgage (NMLS-3240).

Non-affiliates are companies not related by common ownership or control. They can be financial and nonfinancial companies. Direct, Inc. non-affiliates include, but are not limited to, financial companies, such as CBW Bank (Member FDIC), Mastercard, and NYCE.

Joint Marketing is a formal agreement between non-affiliated financial companies that together market financial products or services to you. Direct, Inc. markets with non-affiliated financial companies, such as CBW Bank (Member FDIC).

5. PROCESSING LOCATION AND INFORMATION RETENTION

Any Personal Information Direct acquires will be processed in the United States and may in some instances be stored or processed in other locations. Please note that the laws concerning the processing of Personal Information in these jurisdictions may differ from the laws of the jurisdiction where you are located.

Direct will retain your information for a minimum of the duration under which it is necessary to provide you the Services, and fulfill our contractual, legal and regulatory obligations. When you are no longer our customer, we may continue to disclose your information as needed to fulfill our contractual, legal and regulatory obligations.

Direct will make reasonable efforts to delete requested information, when appropriate and possible. Deletion requests of certain Personal Information may result in our inability to provide you Services. Not all consumer deletion requests can be accommodated. Direct, at our sole discretion, may retain certain information requested by an individual to be deleted to comply with contractual, legal or regulatory retention requirements.

6. UPDATING YOUR PERSONAL INFORMATION

Your Personal Information used for the Services may be reviewed and updated by logging into your Direct Account or calling us at 1-833-263-2826. Your information may be updated or deleted, when reasonable, in accordance with legal or regulatory retention requirements. Please note that certain sensitive information collected and maintained for the Services may not be updated due to its critical role in confirming user identity upon enrollment.

7. CHILDREN AND MINORS

Direct, and its Site and Services, is not directed to individuals under age 18 (“child”, “children”, “minor”). Direct does not wish to receive minors’ information and does not knowingly solicit, collect, use or disclose their information. If you believe Direct has received or collected information from a child under 13, please contact us at clientservice@directb.net and we will make every reasonable effort to the extent possible to delete their Personal Information from our systems.

8. DO NOT TRACK SIGNALS

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard or legal requirement governing what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.

9. THIRD PARTIES AND LINKS TO EXTERNAL SITES AND SERVICES

Direct may provide links in our Site, Application and Services to third parties. Links to third parties and mentions of third parties in our content do not serve as an endorsement of their privacy policies, sites, services or applications. This Policy does not apply to services, applications, sites and practices of third parties, including those with which we partner. We encourage you to read the privacy policies of each third party’s site, services and application and take steps necessary, to protect your information. Direct is not responsible or liable for the privacy policies and practices of third parties, and Direct is not responsible for the failure of third parties to uphold their privacy obligations.

10. COMMUNICATION PREFERENCES

If you enroll with Direct and sign up for Services, you will receive communications from Direct regarding your Card and Account. You may adjust your communication method preferences of text, email and/or SMS when logged into your Account.

If you sign up for Services with Direct, provide information to us by entering a Direct sweepstakes or contest, or otherwise submit your information to Direct to be communicated with, we may provide you promotional information via email. You may opt-out or adjust your communication preferences using the link at the bottom of promotional emails.

11. UPDATES TO THIS POLICY

Direct reserves the right to update this Policy at our sole discretion any time with or without prior notice to you. Unless otherwise stated, any changes to the Policy will be effective immediately when the revised Policy is posted. The Policy posted and/or linked on our Site(s) and Application(s) is always the most current effective version. Notice of material changes to this Policy will be posted on the Site and/or Application. You should periodically review this Policy to ensure that you are familiar with the most current version of this Policy. The “Effective” date indicates when Policy was last changed.

12. IMPORTANT PRIVACY CHOICES FOR CALIFORNIA CONSUMERS

Direct provides important privacy choices for California Consumers in Appendix A.

——— APPENDIX A ———

Direct, Inc.
Important Privacy Choices for Consumers

You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choices below.

Your Rights

You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.

Your Choices

Restrict Information Sharing With Companies We Own or Control (Affiliates): Unless you say “No,” we may share personal and financial information about you with our affiliated companies.

(_) NO, please do not share personal and financial information with your affiliated companies.

Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you say “No,” we may share personal and financial information about you with outside companies we contract with to provide financial products and services to you.

(_) NO, please do not share personal and financial information with outside companies you contract with to provide financial products and services.

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Time Sensitive Reply

You may make your privacy choice(s) at any time. Your choice(s) marked here will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services.

To exercise your choices, do one of the following:

1. Call DIRECT at 1-833-263-2826.

2. Email this completed and signed form to DIRECT at clientservice@directb.net.

3. Mail this completed and signed form to DIRECT at the address below (you may want to make a copy for your records).

   
   DIRECT, Inc.
   Attn: Privacy
   P.O. Box 2364
   Lake Oswego, OR 97035 

First name:_____________________________________ Last name: ____________________________

DIRECT Card Number: ______________________________________

Street address:_______________________________________

City:___________________State:____________ZIP:_________

Signature:_______________________________Date:_________