What Personal Information Does Line Collect and How Does It Use It?
Line collects, uses, and discloses various types of Personal Information differently. Line may have collected at least some information described in each category of Personal Information outlined below in the last twelve (12) months. For each category of information collected, we detail the categories of sources from which we get the information, our business purposes for collecting it, and the categories of third parties with whom we share that Personal Information.
A. Identifiers:
1. Traditional identifiers.
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At Enrollment. Line collects the following identifiers from you before you can use the Services: your primary bank account details, name, social security number, date of birth, home address, email address, and phone number from you during the enrollment process for a Line ID that grants access for free to the high-trust Line Financial Network. If any traditional identifier you provide at enrollment is mistaken or otherwise unverifiable, Line may collect your correct Personal Information from an identity service and ask you to verify it.
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In General. In the course of your use of the Services, you may correct or update your information collected at enrollment. In certain circumstances, Line may require that you provide, in addition to the information above, the following identifying information: government-issued photo ID, such as a driver’s license or passport; photographs of you; and proof of address documentation, such as a utility bill. Additionally, if you contact Line via a social media platform, Line may collect your social media handle from the social network or from a social media analytics tool.
Line collects your traditional identifiers in order to provide the Services and send you related communications; analyze individual and aggregated behavior to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including anti-money laundering (“AML”) and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; process and deliver promotion (including contests and sweepstakes) entries and rewards; collect fees and other amounts owed in connection with the Services; comply with obligations to tax authorities; diagnose and debug our technical systems; and log and store this information.
2. Digital identifiers
As soon as you visit Line’s website or use the Line app, Line automatically collects certain digital identifiers, including device identifiers, internet protocol (“IP”) addresses, web beacons, and other session-tracking information as applicable, as follows:
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Device Identifiers. Line automatically collects information regarding the computer, mobile device, technology or other device (collectively “Device”) you use to access the Services, including your device’s manufacturer, model number, and mobile phone plan carrier. Line collects this information through your use of Line’s website and mobile app, your mobile phone plan carrier, and its risk investigation and mitigation vendors. Line may also assign a unique ID number to your Device.
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IP Addresses. Line automatically collects information regarding your IP address(es). Line collects your IP address from your internet service provider (“ISP”), who assigns it. Your IP address is subject to change, so Line may maintain a record of many ISPs associated with you or your devices over time. IP addresses are typically associated with a particular geographic area and can thus be used to estimate your location. Line therefore collects IP address information both for the purposes associated with digital identifiers generally and for the purposes for which it collects geolocation data (described below).
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Web Beacons & Customized Links. When you use the Line website, Line collects web beacons and customized link information (also known as “clear GIFs” or “pixel tags”). Web beacons are transparent graphic images placed on a web page or in an email to identify you. They can indicate that you have viewed a page or email; tell your browser to get content from another server; and measure traffic to or from, or use of, our online forms, tools or content items and related browsing behavior. Similarly, customized links and related technologies track hyperlinks that you click and associate that information with you in order to provide you with more focused communication.
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Cookies & Other Session Trackers. Line may also collect cookies, local shared objects and similar session-tracking technologies (“Session Trackers”) to identify you over the course of many sessions. Session Trackers help provide additional functionality to the Services, customize users’ experiences with the Services and help us analyze Services usage more accurately for research and product development purposes. Line (and third parties that we work with) may place session trackers on your Device for security purposes, to facilitate navigation of the Services, and to personalize your experience while using our Services. If you would prefer not to accept Session Trackers when using the Site, follow the instructions provided by your website or mobile browser (usually located within the “Help”, “Tools” or “Edit” facility) to modify your Session Tracker settings. Please note that if you disable Session Trackers, you may not be able to access certain parts of our Site and other parts of our Services may not work properly. As a result, we recommend that you leave Session Trackers turned on when accessing the Services because they allow you to take advantage of all of the Service’s features.
Line collects your digital identifiers in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; diagnose and debug our technical systems; and log and store this information.
In order to accomplish the business purposes described above, Line may disclose your traditional and digital identifiers to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.
B. Financial Information:
Financial information includes your Line and other bank account numbers, debit card and credit card numbers, and transaction history. To the extent Line collects this information, it does so on behalf of BBVA Open Platform, Dwolla and future partners (collectively, Line’s bank partners), pursuant to the Privacy Notice you received from the partner at the time of enrollment. You may review the Privacy Notice(s) applicable to your account(s) at any time at https://www.useine.com/policies/.
1. Line partner bank account numbers.
Line collects your account number from the bank partner who issued your Spending Account. If you enroll in a Line savings account, Line will also collect your Savings Account number from the issuing bank partner.
Line collects this information in order to deliver promotion (including referral, contests and sweepstakes) entries and rewards, and collect fees and other amounts owed in connection with the Services. Additionally, Line collects this information for the purposes applicable to financial information generally (see below).
2. External bank account information.
Your use of certain features of the Services requires Line to collect account numbers, balances, and other information about your bank accounts unrelated to your relationship with Line. Line may collect this information through a payment processor that facilitates a transfer to a Line partner bank account or through a third-party secure access tool such as Plaid.
Line collects this information in order to provide certain features of the Services, including surfacing your external bank account balance and facilitating transfers between your external and Line partner bank accounts. Additionally, Line collects this information for the purposes applicable to financial information generally (see below).
3. Debit and credit card numbers.
Line collects the first six and the last four digits of your debit and credit card numbers from its processor and/or the issuing bank for the Services in which you enroll.
It uses this information to help you activate your card by verifying your physical address. Additionally, Line collects this information for the purposes applicable to financial information generally (see below).
Line does not routinely collect, but may access, your full debit and credit card numbers. We access and use (but do not store) this information only through a payment network or transaction dispute processing service to process and resolve disputes you initiate.
4. History of Line partner bank account transactions.
Line collects your Line account transaction history from its processor and bank partner. It collects this information in order to provide you with the Services, in particular preparing your statement, resolving errors and unauthorized transfers, and verifying your identity in certain circumstances.
Line may use certain transaction information as applicable, most notably whether you electronically deposit a portion of your paycheck above a minimum threshold (“Direct Deposit Status”), to determine your eligibility for certain features or elements of the Services. (See, e.g., Flex Line Terms & Conditions). If you are referred to Line by certain marketing partners, Line may use your Direct Deposit Status to determine whether the partner must be compensated for referring you. If the marketing partner’s offer involves an incentive or bonus from the partner contingent on your Direct Deposit Status, Line will disclose your Direct Deposit Status to the partner so you can receive the incentive. Line will not share this information with a marketing partner unless the information-sharing is required for you to receive an incentive according to the offer terms you accept. Additionally, Line collects this information for the purposes applicable to financial information generally (see below).
5. Credit reporting and scoring information
If you enroll in certain features of the Services, Line does not collect credit score and other credit history data from a credit bureau unless you enroll into Line Network’s credit reporting service and grant us access to the same. Line collects this information in order to provide you with the Services, in particular to surface your credit score in the app.
In addition to the purposes for which Line collects each subcategory of financial information described above, Line collects your financial information generally for the following purposes, as applicable: to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; to comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; diagnose and debug our technical systems; and log and store this information.
In order to accomplish the business purposes described above, Line may disclose your financial information to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.
C. Employment Information:
Employment Information includes information about your occupation, salary, and job title that you may have provided at enrollment. It also includes information you may provide to Line in the course of setting up direct deposit or receiving your paycheck via direct deposit into your Line account or if you enroll into Line Network’s Tax related services offered in conjunction with Line partners.
1. Occupation information
If you choose to fill in the optional “occupation,” “source of income,” “approximate annual income,” and “how often do you get paid” fields at enrollment, Line will collect from you information regarding your occupation. Line collects this information for the purposes applicable to employment information generally (see below).
2. Direct deposit information
If you enroll in Line direct deposit, Line will collect identifying information about your employer from you or a third-party service provider, including your employer’s name and address. Line may use this information to analyze trends in its user base. Line will not share information about your employer unless it is de-identified and aggregated. Additionally, Line collects this information for the purposes applicable to employment information generally (see below).
Line collects your employment information, as applicable in order to: analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; and log and store this information.
In order to accomplish the business purposes described above, Line may disclose your financial information to the following categories of third-party service providers: our bank partners, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.
D. Protected Class Information:
Line does not generally collect information relating to your status as a member of a protected class under federal or California law. However, Line does collect and disclose your date of birth for the purposes applicable to traditional identifiers, described above. Your date of birth necessarily indicates whether you are a member of the protected class of persons age 40 or older, but Line does not use or share the fact that you belong to this group for any purpose.
E. Commercial Information:
Commercial information consists of information about your interest in a particular product or service, your purchasing or consuming tendencies, and/or receipts or records for products or services.
Line collects this information from you whenever:
- You begin the enrollment flow or click on an email ad for a new Line product;
- You click on a partner’s offer tile on your /home line associated with Line extensions or click on an email for a third-party partner’s offer;
- You make a purchase with your Line debit or credit card; or
- You produce a receipt in response to a fraud prevention, anti-money laundering, or security inquiry from Line.
Line may also collect information from a Line offer partner indicating whether you purchased or enrolled in the partner’s product or service. The partner will share this information with Line so that Line can compensate the partner for referring you
Line collects your commercial information in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; process and deliver promotion (including referrals, contests, and sweepstakes) entries and rewards; collect fees and other amounts owed in connection with the Services; comply with obligations to tax authorities; diagnose and debug our technical systems; and log and store this information.
In order to accomplish the business purposes described above, Line may disclose your commercial information to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.
F. Biometric Information:
Except as described below, Line does not collect your physiological, biological, or behavioral characteristics that could be used to identify you (“Biometrics”).
1. Voice Recordings
If you call Line’s member services over the phone, Line will collect from its customer service and communications platform vendors a record of the call, including your voice recording. Line collects this recording for customer service training and quality assurance, but Line may also use your voice recordings to verify your identity and prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services.
2. Facial Recognition Technology
If you sign up for Line or use certain features available in-app, you may be asked to provide an image of yourself to verify your identity. Line and any service providers will collect an image of your face and any other body parts in the frame in order to verify your identity and provide services, to comply and support our bank partners’ compliance with applicable law, and to prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services.
In order to accomplish the business purposes described above, Line may disclose your biometric information to third party service providers such as identity verification services, data processors, modeling and analytics tools, and network infrastructure and data storage services for the limited purposes described with respect to each subcategory of biometric information described above.
G. App and Website Usage Information:
Line collects information about your interactions with the Line app and website through the digital identifiers described above. When you perform an interaction such as visiting a particular webpage or app screen, Line uses third party usage trackers, such as Mixpanel, Segment and Google Analytics, to collect the particular digital identifiers associated with that interaction or series of interactions. If you choose to share your location with Line, we may also collect Geolocation Data associated with certain interactions (see Section H, below).
Additionally, Line collects the following information regarding your use of the app and website:
1.Referral information
At enrollment, Line collects information about how you came to Line. First Line automatically collects this information provided by marketers (e.g. Facebook and Google) and publishers and other websites on which Line advertises, including the Apple App and Google Play stores. Line may also collect information about how you were referred to Line based on the landing page you enrolled on, or from the link you followed to the Apple App or Google Play store. Last, Line may collect information from you directly during enrollment, if you answer the optional question regarding how you came to Line.
2. Information you offer through contacts integration
If you decide to grant Line access to your contacts, Line can access your contacts through your mobile phone's operating system. However, Line assures that this data will be utilized solely to simplify the sharing of your Line referral codes, prevent any fraudulent activities, and adhere to the regulations mandated by our banking partners, particularly those involving Anti-Money Laundering (AML) and sanction screening policies. Additionally, Line utilizes your contact access as part of the Everdraft qualification process, enabling us to offer a personalized Everdraft proposal. While providing contact access is not mandatory, sharing this information may enhance your likelihood of qualifying for Everdraft.
3. Information you offer through Music & Photos.
If you decide to grant Line access to your Music and Photos, Line can access your music & photos through your mobile phone’s operating system. Line assures that this data will be utilized solely as a component of Everdraft qualification process. Although sharing the information is not mandatory, doing so may increase your likelihood of qualifying for Everdraft.
4. Information you offer through Calendar
If you choose to authorise Line to access your calendar and calendar reminders, Line can access them through your mobile phone’s operating system. Line assures that this information will be used solely as a part of Everdraft qualification process. Although, sharing the information is not mandatory but doing so may increase your likelihood of qualifying for Everdraft.
5. Information you offer through customer service interactions
Whenever you interact with Line via the in-app chat, email, phone, or website, Line collects your communications. Line collects this information for customer service training and quality assurance, but may also use the information to investigate fraud or unusual activity relating to your account.
6. Information you provide about your experience with Line
If you give Line any information about your use of the Services; participate in user research by responding to a questionnaire, survey; or offer other feedback, including opinions about Line, Line may collect that information.
Line collects your app and website usage information in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; diagnose and debug our technical systems; and log and store this information.
In order to accomplish the business purposes described above, Line may disclose your app and website usage information to the following categories of third-party service providers: our bank partners, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.
H. Geolocation data:
Line may collect information from your mobile Device about your location while you are accessing or using the Application and while you are not accessing or using the Application. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.
Line collects your geolocation data in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; diagnose and debug our technical systems; and log and store this information.
In order to accomplish the business purposes described above, Line may disclose your geolocation data to the following categories of third-party service providers: our bank partners, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.
