Lili Online Privacy Policy

Last updated: April 1, 2024

Protecting the privacy of your Nonpublic Personal Information (“NPI”) is important to Lili

App Inc. and our employees (collectively, “Lili”, “we”, “us” and “our” as appropriate). This Privacy Policy (“Policy”) explains how we may collect, use and disclose information we obtain through the Lili website or the Lili App (collectively, “Lili Service”).The words “you” and “your” mean each individual who accesses the Lili Service.

NPI is any “personally identifiable financial information” that a financial institution collects about an individual in connection with providing a financial product or service, unless that information is otherwise “publicly available.”

1. How We Collect Your Information

We collect information, including NPI when you:

Apply for a Lili business deposit account (“Lili Account”);
- Register to use the Lili Service;
- Process transactions through your Lili Account;
- Use one or all of Lili’s Services;
- Interact with us by sharing information on a blog or a social media platform that we manage;
- Request Lili Account access for others; and ● Communicate with us.

We may also collect NPI from the following sources:

Information we receive about your transactions from our service providers;
- Information we receive about your transactions with nonaffiliated third parties;
- Information we receive from any devices that interface with us;
- Information you give us access to, such as other financial services accounts; and
- Information we receive about you from vendors, third party service providers, or consumer reporting agencies, such as credit bureaus.

Our Security Procedures

We take all necessary steps to safeguard NPI. We restrict access to NPI and account information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard NPI.

1.1. Creating a Lili Account.

You must register to use the Lili Service. When you choose to create a Lili Account, we are required to collect information including your name, address, date of birth, and social security number if you are a sole proprietor, or the same information for ultimate beneficial owners of legal entities. To further verify identity and prevent fraud, we collect additional information about you, such as biometric information, device information, IP address, email address and phone number, as well as information about your business. You may decline to provide this information, however, doing so may prevent you from engaging with and using the Lili Service.

1.2. Using the Lili Service.

We collect information from you as you use the Lili Service; when you initiate a transaction, when you send payments or otherwise engage with or use the Lili Service. Lili may offer additional financial and non-financial products and services via the Lili Service which are governed by this Privacy Policy.

1.3. Customer Support.

We may collect information, including NPI from you through your communications with our customer support or other team members.

1.4. Mobile Device Information.

We collect information about the computer, tablet, or mobile device you use to access the Lili Service which may include the hardware model, operating system and version, unique device identifiers and mobile network information. We may also collect other device identification information for the purposes of detecting and preventing fraud.

1.5. Location Data.

If you have ‘background location’ turned on, the Lili App will, from time to time, tell us about your mobile device’s location even if you are not directly interacting with the application.

When we have location information, we use it to tailor the Lili Service for you and others, like helping reduce debit card fraud by matching your card activity with your location.

When you visit the Lili website, we and third parties that provide certain functionality on the Lili Service may engage, receive and record information from your use of the Lili Service and server logs from your browser, including your IP address, cookies, and similar technology. This information is used for security purposes to authenticate your identity and improve the quality of our services, such as storing your account preferences.

Cookies are commonly used on websites and do not harm your system. By configuring your preferences or options in your browser, you determine if and how a cookie will be accepted. Most browsers allow you to block and delete cookies however by blocking cookies on our site it may impact the services we can provide you.

2. How We Use Your Information

We use the information we collect, including NPI to:

Facilitate and improve the Lili Service;
- Communicate with you;
- Provide and deliver the products and services you request, process transactions and send you related information, including confirmations;
- Verify your identity and prevent money laundering, fraud, and other wrongful conduct;
- For Lili and our bank partners to offer other products and services available on the Lili App that you may qualify for or might be interested in; and
- Monitor and analyze trends, usage, and activities in connection with the Lili Service

We use information, including NPI, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Lili Service. We may use and retain any data we collect to provide and improve our services.

2.2. Communications.

We may send emails or text messages to the email address and phone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance. We may store your email address and phone number, your message and our response for quality assurance. We may also do this to meet legal and regulatory requirements.

2.3. Marketing.

We do not rent, sell, or share NPI about you with other individuals or non-affiliated companies for their direct marketing purposes, unless we have your permission. We also do not provide any NPI to any third-party advertising networks. We may use your NPI and other information to communicate with you by email to provide you with information and services we think may be of interest to you.

2.4. Aggregate Data.

We may cleanse and aggregate data collected through the Lili Service and use it for any purpose. We do not consider information that has been cleansed to be NPI.

We may share your information, including cleansed NPI, with our third-party service providers, vendors and other partners:

To comply with legal obligations;
To protect and defend our rights and property; and
With your permission.

3. How We May Disclose Your Information.

We are permitted under law to disclose NPI about you to other third parties in certain circumstances. For example, we may disclose NPI about you to third parties, such as service providers and vendors, to assist us in servicing your account with us and to prevent wrongful conduct. We do not disclose any NPI about you to anyone, except as permitted by law.

If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

3.1. Vendors and Service Providers.

We may share any information we receive with vendors and service providers retained in connection with the provision of the Lili Service. Our vendors and service providers may compare your identifiers (such as email address, IP address, and phone number) and NPI with consortia information to assist us in preventing fraud, money laundering and other wrongful conduct. Conversely, this information may be used by the consortia to prevent fraud, money laundering and other wrongful conduct at other financial institutions.

3.2. As Required By Law and Similar Disclosures.

We may disclose your NPI, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order, levy, garnishment, or subpoena; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.

3.3. Merger, Sale, or Other Asset Transfers.

If we are involved in a merger, acquisition, reorganization, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

4. Security of Your Information.

We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Lili Service or providing NPI to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Lili Service. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on the Lili Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at [email protected] .

5. Links to Third Party Services.

The Lili Service may allow you to access third party services to provide information about you, including NPI, to the Lili Service. This Policy applies only to the information collected by the Lili Service. When logging into a third party service or following a link to third party websites from the Lili Service, please be aware that the privacy practices of those services may differ. We encourage you to carefully read the privacy policy for each website you visit. We are not responsible for the privacy policies or practices of linked third party sites or services.

6. International Users.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

7. Update Your Information or Pose a Question.

If you have any questions or concerns about this Policy or the use of your information, or to modify or update any information we have received, please contact us at [email protected].

7.1. Modifying Your Information.

If you are a registered user of the Lili Service, you may modify your account settings and information through the Settings portal within the Lili Service.

7.2. Terminating Your Lili Account.

If you wish to terminate your account, we will be sad to see you go, but you can contact customer support at the email address below to do so. When you terminate your Lili Account, or if we terminate it, you will no longer be able to view your Lili Account or profile information, but we may continue to have access to your information for a period of time in order to comply with applicable legal or service obligations. We suggest that you download all your monthly statements before contacting customer support to close your Lili Account.

7.3. Data Retention.

We will retain your Lili Account and associated information for as long as your account is active or as needed to provide you the Lili Service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Changes to Our Policy and Practices

8.1. Posting of Revised Policy.

We may update this Policy to reflect changes to our information practices. If we make any change in how we use NPI, we will notify you by means of a notice on the Lili Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

8.2. New Uses of NPI.

From time to time, we may desire to use NPI for uses not previously disclosed in our Policy. If our practices change regarding previously collected NPI in a way that would be materially less restrictive than stated in the version of this Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

9. Biometric Information

Through our vendor or directly, we collect certain biometric data from individuals for the purpose of verifying their identity. We recognize the sensitivity of Biometric Data (defined below) and take seriously our obligation to maintain the confidentiality and protect security of such data. To promote these efforts, we have adopted the following biometric information privacy policy.

9.1. Definitions

“Biometric Data” means any biological characteristics of a person, or information based upon such a characteristic, including characteristics such as those defined as “Biometric Identifiers” and “Biometric Information” under laws regulating the processing of biometric identifiers or information.

“Biometric Identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, or any additional characteristics defined as such under laws regulating the processing of biometric identifiers or information.

“Biometric Information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual, or any additional characteristic or measurement defined as such under laws regulating the processing of biometric identifiers or information.

9.2. Purpose for Collection of Biometric Data

We (or our service provider) use facial recognition software to compare an individual’s driver’s license photograph against that individual’s self-taken picture to verify the identity of the individual.

9.3. Disclosure and Authorization

We will not disclose or disseminate any Biometric Data to anyone other than our service providers (who would be acting on our behalf and subject to contractual obligations) without/unless:

First obtaining your written consent to such disclosure or dissemination;
The disclosed Biometric Data completes a financial transaction requested or authorized by you;
Disclosure is required by state or federal law or municipal ordinance;
or Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction

9.4. Security of Biometric Data

We will use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic Biometric Data collected.

9.5. Retention Schedule

We will retain Biometric Data only until, and shall request that any service providers that may have access to the Biometric Data destroy such data when, the first of the following occurs:

The initial purpose for collecting or obtaining such Biometric Data has been satisfied, such as the identity of the individual has been verified; or
Within 3 years of your last interaction with us.

If legal obligations require us to retain Biometric Data for longer than the above, we will destroy such data not later than the first anniversary of the date the data is no longer required to be maintained by law.

10. Children’s Privacy

The Lili Service is not intended for businesses only. It is not intended for individuals (except sole proprietorships). In connection with verifying the identity of businesses, we do collect information on the sole proprietor or on the control person and other ultimate beneficial owners of legal entity customers. The Lili Service is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. In the event that we learn that we have collected personal information from a child under age 18 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 18, please contact us at the email address provided below.

11. Contact Information

If you have any questions about this Privacy Policy, please contact us at [email protected].

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