LAST UPDATED October 10, 2023
Cybrid, Inc. and its affiliates (“Cybrid”) knows that you care about how your personal information is used and disclosed, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. As a company operating in multiple jurisdictions, we follow the General Data Protection Regulation (GDPR) to protect personal information.
To make this privacy notice easy to find, we make it available from the home page of the Cybrid website at Cybrid.xyz (the "Website"). You may also email us at email@example.com with any privacy-related questions you have.
This privacy notice applies to all information we collect through our Services from current and former Cybrid users, including you. “Services” means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Cybrid, Inc. in connection with a Cybrid account. When you are no longer our customer, we continue to disclose your information as described in this statement.
We share your information with other Cybrid companies (“Affiliates”), as well as trusted third parties and service providers, in order to offer our Services and fulfill legal requirements. Personal information that we process and collect may be transferred between companies, Services, and employees affiliated with us as a normal part of conducting business and offering our Services to you.
Throughout this statement, 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 aggregated and/or anonymized so that it does not identify a specific person.
What Information Do We Collect?
When you visit our website or use one of our Services, 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 Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service.
If you open a Cybrid account, we collect the following information from you:
- Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information;
- Identification Information - your name, street address, email address, date of birth, and Social Security Number ("SSN") (or other governmental issued verification numbers);
- Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, 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.
- Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to disclose your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device;
- Financial Information - bank account online login information, bank account and routing numbers linked to your Cybrid account.
We may also collect the above data from other third parties, including service providers, internet service providers, merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks and financial institutions.
We are committed to providing a safe, secure and all around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information to comply with law 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 the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or your operating systems 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, store results when you respond to a survey, or when you use another Cybrid service.
The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
How Do We Store and Protect Personal Information?
We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state laws and 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 strive 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 information as well, including never sharing your Cybrid password with anyone.
If Cybrid learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that Cybrid may communicate with you electronically. Cybrid may post a notice on the website or mobile application if a security breach occurs. We may also send 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), please email us at firstname.lastname@example.org.
How Long Do We Store Your Personal Information?
We retain your Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law.
The criteria used to determine our retention period is as follows:
Personal Information used for the ongoing relationship between you and Cybrid is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:
- a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under Anti-Money Laundering obligations;
- litigation, investigations, audit, and compliance practices, or to protect against legal claims.
- Customers also have various data retention and deletion rights enshrined by law throughout the world including, but not limited to, GDPR, CCPA, and PIPEDA.
How Do We Use the Personal Information We Collect?
Our primary purpose in collecting personal information is to provide you with a safe, smooth, and efficient experience. We may use your personal information to:
- provide the services and customer support you request;
- process transactions and send notices about your transactions activity;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, and Geolocation Information;
- create an account connection between your Cybrid account and a third-party account or platform;
- 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;
- compare information for accuracy and verify it with third parties; and
- perform other duties as required by law.
If you elect to disclose your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, and offers.
How Do We Disclose Personal Information to Other Parties?
Cybrid does not disclose your personal information with third parties for their promotional or marketing purposes.
Some personal information is public information and may be seen by anyone on the internet, whether or not they have a Cybrid account. Public information may also be seen, accessed, reshared or downloaded through Cybrid's APIs or third-party services that integrate with our products.
We may disclose your personal information with:
- Our affiliates, but only for purposes allowed by this document;
- Companies that Cybrid, Inc. plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If your personal information could be used contrary to this statement, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable;
- Third party firms through which Cybrid offers its services;
- Law enforcement, government officials, or other third parties if PayPal is compelled to do so by a subpoena, court order or similar legal procedure; when it is necessary to do so to comply with law; or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Cybrid 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;
- Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit; and
- Other third-parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
For the purposes of this privacy notice, an "account connection" with such a third party is a connection you authorize or enable between your Cybrid account and a non-Cybrid account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Cybrid and the third-party will exchange your personal information and other information directly. Examples of account connections include, without limitation: connecting your Cybrid account to a third-party data aggregation or financial services company, if you provide such company with your Cybrid account log-in credentials.
If you connect your Cybrid account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy notice.
Information that we disclose with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that Cybrid discloses with a third-party account or platform may in turn be disclosed with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
If you choose to use Siri or iMessage to use the Services, such use is subject to Apple’s terms and conditions for use of iMessage and/or Siri, as applicable, and the terms of the Cybrid User Agreement. By using Siri or iMessage, you authorize us to disclose some of your Cybrid account data (including transaction instructions and transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data disclosed with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to Cybrid on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.
How Can You Access and Change Your Personal Information?
You can review and update your personal information in your account settings at any time by logging in to your account.
Residents of California have certain rights under the California Consumer Privacy Act (CCPA), and Cybrid provides the following disclosures regarding the collection, use, and disclosure of personal information.
Under the CCPA, California residents have the following rights:
- Right to Know: California residents have the right to request information about the categories and specific pieces of personal information collected, the categories of sources from which it was collected, the business purposes for collecting or selling the information, and the categories of third parties with whom it is shared.
- Right to Delete: California residents have the right to request the deletion of their personal information.
- Right to Opt-Out: California residents have the right to opt-out of the sale of their personal information if applicable.
- Right to Non-Discrimination: California residents have the right not to be discriminated against for exercising their privacy rights under the CCPA.
How to Exercise Your Rights:
- California residents can exercise their rights by emailing email@example.com.
If you have any questions or concerns about our CCPA compliance or your privacy rights, please contact us at firstname.lastname@example.org.
Links to Other Services or Sites
The Services may contain links to (or allow you to link to) other third-party services or websites. Cybrid does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy notices of any third-party service or website that collects personally identifiable information.
Data use based on your consent
Cybrid uses certain third party service providers in order to provide the Services to you.
In using the Services, you consent to Cybrid providing any Personal Information as may be required for third parties to provide the Services to you.
You have the right to withdraw your consent at any time on a go-forward basis (which will not affect our prior use of your data, based on your previously given consent). You may change your device-based or in-app settings anytime
How Can You Contact Us?
If you have questions or concerns regarding this privacy notice, or any feedback pertaining to your privacy and the Services that you would like us to consider, please email us at email@example.com.