Privacy Policy

Effective Date: June 26, 2023

This website is owned and operated by MoVi Partners, Inc. ("MoVi"). We respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, including content on our websites and related services (collectively, "Services").

Your use of MoVi websites and services is subject to this Privacy Policy and the Terms of Use. If you disagree with these terms, please discontinue use of our website and services.

These websites are general audience sites and we do not knowingly collect information from children under 18. If you are under 18, please do not use our site.

For questions about this policy, contact us at tessa@movipartners.com.

Acceptance of this Privacy Policy
Information and Data
How We Collect Your Information
How We Use Your Information
Disclosure of Your Information to Third Parties
Information Obtained from Third Parties
Third Party Sites and Services
Updating, Accessing, and Storing Your Information
Privacy Rights
California Specific Privacy Rights
Security
Choice/Opt-Out
Special Notice to California Residents
Special Notice to Vermont Residents
Changes to this Privacy Policy
Notification of Privacy Policy Changes
Contact Information

1. Acceptance of this Privacy Policy

By accessing and using our Services, you signify acceptance of this Privacy Policy. Where we require your consent to process your personal information, we will ask for it as described below. We may provide additional "just-in-time" disclosures about data processing practices for specific Services.

If you do not agree with this Privacy Policy, you should immediately discontinue use of our Services.

2. Information and Data

Personal information is data that identifies, relates to, describes, or could reasonably be linked with a particular consumer or household.

A. Information You Provide to Us

To establish an account and access our Services, we'll ask you to provide information about yourself. This information is either required by law, necessary to provide services, or relevant for specific purposes described below. You may not be able to access certain Services if you choose not to share certain information. Any information you provide that is not required is voluntary.

B. Information We Collect

Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, IP address, social security number, email

Formal Identification Information: Government-issued identity documents such as passport, driver's license, national identity card, state ID card, tax ID number, visa information

Institutional Information: Employer Identification number, proof of legal formation, personal identification information for material beneficial owners

Financial Information: Bank account information, tax return information, federal and state tax ID, profit and loss statements, average monthly sales revenue, income statements, credit score, business invoices, wire instructions

Transaction Information: Information about transactions you make on our Services, including recipient name, your name, amount, timestamp

Employment Information: Office location, job title, role description

Correspondence: Survey responses, information provided to support or research teams

Business Information: Business legal entity, NAICS code, business description, officers/members/managers, articles of incorporation, certificates of good standing, ownership structure, number of employees, date of incorporation, business address, state of incorporation, legal business name, business website

Funding Information: Requested funding amount, purpose of funding, funder name, balance of outstanding working capital loans

Documents and information collected are securely stored and safeguarded. At your request and with your permission, these documents may be shared with certain lenders. We will not disclose, transmit, or share these documents without your permission.

C. Information We Collect Automatically

We receive and store certain information automatically when you interact with our Sites or Services. This information helps us address customer support issues, improve performance, provide personalized experience, and protect your account from fraud.

Online Identifiers: Geolocation/tracking details, browser fingerprint, operating system, browser name and version, IP addresses

Usage Data: Authentication data, security questions, click-stream data, public social networking posts, data collected via cookies and similar technologies

We may automatically receive and record information including:

How you came to and use the Services
Device type and unique device identification numbers
Device event information (crashes, system activity, hardware settings, browser type and language, date/time of requests, referral URL)
How your device interacts with our Sites and Services (pages accessed, links clicked)
Broad geographic location
Technical data collected through cookies, pixel tags, and similar technologies

D. Information Collected from Third Parties

We may obtain information about you from third-party sources as required or permitted by law, including:

Public Databases & ID Verification Partners: For verifying your identity in accordance with applicable law

Credit Bureaus: With your consent, we obtain credit reports. We will not disclose your credit report without explicit permission.

Financial Institutions: With your consent, we obtain information directly from your financial institution, including account statements. We utilize Finicity (privacy policy: https://www.finicity.com/privacy/) and Ocrolus (privacy policy: https://www.ocrolus.com/privacy-policy/).

Joint Marketing Partners & Resellers: May share information about you so we can better understand which Services may interest you

Advertising Networks & Analytics Providers: Provide de-identified information about how you found our Sites and how you interact with them

E. Data Anonymization and Aggregation

Anonymization is a data processing technique that removes or modifies personal information so it cannot be associated with a specific individual. We may use anonymized or aggregate customer data for any business purpose, including understanding customer needs, improving products and services, conducting business intelligence and marketing, and detecting security threats.

Types of data we may anonymize include transaction data, click-stream data, performance metrics, and fraud indicators. When you request deletion of your information, it will be anonymized or aggregated in compliance with applicable law.

3. How We Collect Your Information

Log Files: Our servers automatically gather information from your browser (IP addresses, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks) to analyze trends, administer the site, prevent fraud, and track visitor movement. We do not share log files externally.

Cookies: We use cookies to track information while you visit our website or use our services. Cookies allow us to count visitors, distinguish repeat visitors from new ones, and save user preferences. If your browser rejects all cookies, the website will not function properly.

Web Beacons: Small transparent graphic images used in conjunction with cookies to personalize our website and collect limited information about visitors. We may also use web beacons in email communications to understand customer behavior. We do not link web beacons to personally identifiable information.

Sign-Up Information: We require your name, address, phone number, email address, and other personal information to process sign-ups.

Application: To access our services, we require personal information including your name, address, phone number, email, business name, business address, federal and state tax ID, business type, location, average monthly sales, state of incorporation, landlord name (if applicable), credit card transactions per month, loan purpose, and current outstanding loans.

Emails and Telephone Calls: We require an email address when you register. We use your email for transactional (order confirmation, refund processing) and promotional (newsletters, new offerings, special discounts, events) purposes. You may opt out of promotional emails (see "Choice/Opt-Out" section). We reserve the right to send service announcements and administrative messages without opt-out options. We may contact you by telephone or text message in connection with MoVi's services. We fully comply with the U.S. CAN-SPAM Act.

Other Sources: We may obtain information about you from third parties such as credit reports, with your permission.

4. How We Use Your Information

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We use personal information to create, develop, operate, deliver, and improve our Services, content, and advertising; and for loss prevention and anti-fraud purposes.

We may use your information for the following purposes:

1. To Maintain Legal and Regulatory Compliance

Most core Services are subject to laws requiring us to collect, use, and store your personal information in certain ways. MoVi must identify and verify customers to comply with commercial lending laws. We use third parties to verify your identity by comparing information you provide against third-party databases and public records. If you don't provide legally required information, we may close your account.

2. To Enforce Our Terms

We actively monitor, investigate, prevent, and mitigate potentially prohibited or illegal activities, enforce agreements with third parties, and prevent violations of our user agreement.

3. To Detect and Prevent Fraud

We handle sensitive information, making it critical to actively monitor, investigate, prevent, and mitigate potentially prohibited or illegal activities.

4. To Provide MoVi's Services

We process your personal information to provide Services to you. For example, when seeking a loan from lending partners, we require identification, contact information, and income information. We cannot provide Services without such information.

5. To Provide Service Communications

We send administrative or account-related information to keep you updated about Services, inform you of relevant security issues or updates, and provide transaction-related information. You may not opt out of critical service communications sent for legal or security purposes.

6. To Provide Customer Service

We process personal information when you contact us to resolve questions, disputes, collect fees, or troubleshoot problems. Without processing personal information, we cannot respond to requests and ensure uninterrupted use of Services.

7. To Ensure Quality Control

We process personal information for quality control and staff training to ensure we continue providing accurate information.

8. To Ensure Network and Information Security

We process personal information to enhance security, monitor and verify identity or service access, combat spam or malware, and comply with applicable security laws. Without processing personal information, we may not be able to ensure Services security.

9. For Research and Development

We process personal information to better understand how you use and interact with MoVi's Services. We use such information to customize, measure, and improve Services and website/application content and layout, and to develop new services.

10. To Enhance Your Experience

We process personal information to provide personalized experiences and implement preferences you request. For example, you may provide us access to certain personal information stored by third parties.

11. To Facilitate Corporate Transactions

We may process information regarding your account and use of Services as necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You can close your account if you don't wish personal information processed for such purposes.

12. To Engage in Marketing Activities

Based on your communication preferences, we may send marketing communications (emails or mobile notifications) to inform you about events, deliver targeted marketing, and provide promotional offers. Marketing will be conducted in accordance with your preferences and as permitted by law.

13. For Any Purpose You Consent To

We may disclose personal information for any purpose you consent to.

We will not use personal information for purposes other than those disclosed without your permission. You may opt out of having personal information shared with third parties or used for purposes incompatible with those for which we originally collected it. If you limit use of personal information, certain features or Services may not be available.

5. Disclosure of Your Information to Third Parties

i. Disclosure By Law

You acknowledge and agree that we may disclose information if required by law, at the request of a third party, or if we believe disclosure is reasonable to: (1) comply with law, law enforcement requests, or legal process; and (2) protect or defend MoVi's, or a third party's, rights or property.

ii. Lenders and/or Brokers

By signing up for our services or submitting a loan request, you consent to disclosure of your information with lenders and/or brokers within our network. We will not perform credit checks without authorization. Lenders, brokers, and service providers you're matched with may retain your information even if you don't enter into agreements with them. Contact each party directly regarding their privacy policies. If you enter into an agreement with a lender/broker and update your information with us, we may share updated information with them.

iii. Disclosure to Trusted Third Parties

Upon completing a profile and application, we will share your information with third-party service providers you're matched with. By accepting Terms of Use, you agree to receive marketing materials from trusted third parties, including potential lenders and service providers. We are not responsible for third-party materials or actions. Your information may be shared with third-party contractors providing services to MoVi who are bound by this privacy policy. From time to time, we may share personal information about our user base with carefully selected third parties so they can offer goods and services that may interest users. You can opt out as outlined in "Choice/Opt-Out."

iv. Service Providers

We share information with service providers under contract who help with business operations. Contracts require these providers to only use information for services they perform for us and prohibit them from selling your information. Service provider types include:

Network infrastructure
Cloud storage
Payment processing
Transaction monitoring
Security
Document repository services
Customer support
Internet service providers
Data analytics
Information technology
Marketing

v. Other Companies

We may share information with companies or entities we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.

vi. Professionals

We may share information with professional advisors providing banking, legal, compliance, insurance, accounting, or consulting services to complete audits or comply with legal obligations.

By disclosing your information through signing up and agreeing to Terms, you expressly consent to any transfer of information as described in this Privacy Policy.

6. Information Obtained from Third Parties

We purchase marketing data about customers from third parties and combine it with information we already have to create more tailored advertising and products. If you provide information about others, or if others give us your information, we only use it for the specific reason it was provided.

The Websites contain links to third-party websites. These third parties are solely responsible for their own websites. We don't control and are not responsible for third-party privacy and security practices.

7. Third Party Sites and Services

If you authorize third-party applications to access your MoVi Services, information you provided to MoVi may be shared with those third parties. Unless you provide further authorization, these third parties may not use information for purposes other than facilitating transactions using MoVi Services. Third parties have their own privacy policies, and MoVi is not responsible for their operations.

Examples of account connections include:

Lenders: If you conduct a transaction with a third-party merchant, the merchant may provide data about you and your transaction to us.

Your Financial Services Providers: If you send funds from your bank account, your bank will provide identifying information and account information to complete the transaction.

Information shared with third parties based on account connections will be used according to the third party's privacy practices. Review privacy notices of any third party that will gain access to your personal information.

8. Updating, Accessing, and Storing Your Information

You may update or access profile information anytime by logging into your account and making changes. Changes update immediately. You can deactivate or delete your account to stop using it.

When you deactivate an account, information will not be sent to further lenders, brokers, or third parties, but won't be deleted. Deactivating allows you to restore the account in its entirety.

Deleting your account permanently removes it from MoVi. Only delete your account if you're certain you never want to reactivate it.

Upon deletion, data you provided will be retained by MoVi in a commercially reasonable manner to comply with lending laws. Once deleted, MoVi will not share your information and will only use data for internal research and marketing. Retained data will be kept for a commercially reasonable period as determined by MoVi in conformance with applicable law.

We store personal information securely throughout your MoVi Account life. We only retain personal information as long as necessary to fulfill collection purposes, including satisfying legal, accounting, or reporting obligations or resolving disputes. Typical retention periods include:

Personal information collected to comply with legal obligations under financial, consumer protection, and commercial credit laws may be retained after account closure as long as required by law.
Contact information for marketing purposes is retained until you unsubscribe, then added to our suppression list.
Content you post may be kept after account closure for audit and crime prevention purposes.
Telephone call recordings may be kept for up to six years.
Information collected via technical means (cookies, analytics tools) is kept for up to one year from cookie expiry.

9. Privacy Rights

Depending on applicable law, you may be able to assert certain rights related to your personal information. If any rights listed are not provided under law for your jurisdiction, MoVi has absolute discretion in providing those rights.

Your rights to personal information are not absolute. Access may be denied: (a) when required or authorized by law; (b) when granting access would negatively impact another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious.

i. Access and Portability

You may request a copy of your personal information held by us. This will be provided without undue delay subject to a potential fee (as permitted by law), unless provision adversely affects others' rights and freedoms. In certain circumstances, you may request to receive personal information in a structured, commonly used, machine-readable format, and have us transfer information directly to another data controller.

ii. Rectification

You may request us to rectify or update inaccurate personal information. You may do this anytime by logging in and clicking the Profile or My Account tab.

iii. Erasure

You may request to erase personal information, subject to applicable law. If you close your MoVi Account, we'll mark it as "Closed" but keep certain account information in our database for a period described above. This is necessary to deter fraud and comply with legal obligations. However, if you close your account, personal information won't be used for further purposes or shared with third parties, except as necessary to prevent fraud, assist law enforcement, as required by law, or according to this Privacy Policy.

iv. Withdraw Consent

If processing personal information is based on your consent, you may withdraw consent anytime. Withdrawal won't affect lawfulness of processing based on consent before withdrawal.

v. Restriction of Processing

In some jurisdictions, applicable law may give you the right to restrict or object to us processing personal information under certain circumstances. We may continue processing personal information if necessary for defense of legal claims or for other exceptions permitted by law.

vi. Automated Decision-Making, Including Profiling

MoVi relies on automated tools to help determine whether transactions or customer accounts present fraud or legal risk. In some jurisdictions, you have the right not to be subject to decisions based solely on automated processing of personal information, including profiling, which produces legal or similarly significant effects, except as permitted under data protection laws.

vii. How to Make a Privacy Request

You can make privacy rights requests by contacting us at tessa@movipartners.com. When we receive requests via other methods, we may verify your identity before complying to protect your privacy and security.

viii. How to Lodge a Complaint

If you believe we've infringed your rights, contact us at tessa@movipartners.com.

10. California Specific Privacy Rights

If you are a California resident, you have the right to request information from us regarding whether we share certain categories of personal information with third parties for their direct marketing purposes. To the extent we share personal information this way, you may receive:

(a) categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; and

(b) names and addresses of third parties that received such information, or examples of products or services marketed if the nature of their business cannot be determined from the name.

Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), California residents have certain rights in relation to personal information, subject to limited exceptions.

For personal information collected during the preceding 12 months not otherwise subject to an exception, California residents have the right to access and delete personal information. MoVi will not discriminate against those who exercise rights. If you exercise rights, we won't deny services, charge different prices, or provide different service levels or quality.

To the extent we sell personal information to third parties, you also have the right to request that we disclose: (i) categories of personal information we sold, and (ii) categories of third parties to whom personal information was sold. You have the right to direct us not to sell personal information. Note that personal information is only sold when you decide to apply for and fund business loans through the MoVi marketplace. Otherwise, information is maintained by MoVi but not sold.

Should MoVi engage in activities listed in this section, your ability to exercise these rights will be available in account settings. Contact us at tessa@movipartners.com to make requests.

If you are a California resident, you may designate an authorized agent to make access or deletion requests on your behalf. We'll respond to your authorized agent's request if they submit proof they're registered with the California Secretary of State to act on your behalf, or submit evidence you've provided them with power of attorney pursuant to California Probate Code sections 4000 to 4465. We may deny requests from authorized agents who don't submit proof of authorization or can't verify their identity.

11. Security

We have extensive security measures to protect loss, misuse, and alteration of information in our database. Measures include use of Secure Socket Layer (SSL) technology during credit card transactions and administrative access to site data, as well as other proprietary security measures applied to all repositories and transfers of user information. We exercise reasonable care in providing secure transmission between your computer and our servers, but given that no Internet transmission can be guaranteed 100% secure, we cannot ensure or warrant security of information transmitted to us over the Internet and accept no liability for unintentional disclosure.

In the event of a data breach at MoVi, we will notify you within 45 days. We'll notify you that a breach occurred, what type of information was breached, when the breach occurred, steps you can take to further protect your information, actions we're taking regarding the breach, and steps we're taking to prevent future breaches.

Do not share your account login and/or password with anyone. Sharing account information may lead to additional exposure to your account.

12. Choice/Opt-Out

You may stop receiving newsletters or marketing emails by following unsubscribe instructions in emails or contacting us at tessa@movipartners.com. You can choose not to provide certain information, but this will likely prevent use of certain website features and obtaining services and products you seek. Do not post personal information on public forums. You're solely responsible for posting personal information on public forums.

If you decide you no longer wish to receive services or future contact from lenders, brokers, or third parties to which your information was referred, you may cancel your account. Upon canceling, information will no longer be sent to lenders, brokers, or third parties. This doesn't guarantee these parties will cease contacting you or using your information. Contact all lenders, brokers, and third parties to ensure they cease contact.

Federal and state regulations require us to maintain records of your information for certain periods. Due to these regulations, we may be unable to completely delete information from our database until time requirements expire.

13. Special Notice to California Residents

If you are a California resident, in addition to rights set forth in this Privacy Policy:

We will not share personal information about you with third parties to the extent prohibited by applicable California law or to the extent your prior consent is required by applicable California law.
You have the right to request information regarding how we share certain categories of information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive:
- Categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year
- Names and addresses of third parties that received that information
- If the nature of the third party's business cannot be determined from their name, examples of products or services marketed

We may provide this information in a standardized format not specific to your situation. Send requests to tessa@movipartners.com.

14. Special Notice to Vermont Residents

Vermont law places additional limits on sharing information about Vermont residents. In accordance with Vermont law, we will not share information about Vermont residents to companies outside MoVi except: (1) as permitted by law; (2) to companies that perform marketing or other services on our behalf; (3) name, contact, and transaction/experience information to other financial institutions with which we have joint marketing agreements; or (4) with authorization or consent of the Vermont resident. We also won't share non-transactional information about Vermont residents received from others within the MoVi family of companies except with authorization or consent of the Vermont resident.

15. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time, indicated by changing the date at the top of this page. If we make material changes, we'll notify you by email (sent to the email address in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

16. Notification of Privacy Policy Changes

We may update this privacy policy to reflect changes to our information practices. If we make material changes, we'll notify you by email (sent to the email address in your account) or by means of a notice on this Site. We encourage you to periodically review this page for the latest information. When we make changes, we'll revise the revision date at the top of the Privacy Policy.

17. Contact Information

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