EVOLVE BANK & TRUST PRIVACY POLICY

Sharing & Disclosure · Company practice

Company may disclose user information to third parties, including the listed recipient categories

The disclosure section states that Evolve may disclose a user's information with third parties, including the recipient categories listed below. Read with the policy's scope definition, 'your information' means information about users of the Services.

Supporting quotations

HOW THE COMPANY DISCLOSES YOUR INFORMATION We may disclose your information with third parties, including with:

describes how we collect, use and disclose information about users of our website

Qualifications & exceptions

• The list is introduced by 'including with' and is not exhaustive.
• The policy does not state that every recipient receives every category of information.

Not stated here

• The policy does not give a complete named recipient list.

Sharing & Disclosure · Company practice

Vendors and service providers receive information for operational services

Evolve may disclose information to vendors or other service providers that help provide the Services, including for cloud storage, security, customer relationship management, fraud detection and prevention, marketing communications, web analytics, payment networks and payment processors.

Supporting quotations

Vendors or other service providers who help us provide the Services, including for cloud storage, security, customer relationship management, fraud detection and prevention, marketing communications, web analytics, payment networks and payment processors.

Qualifications & exceptions

• The list of functions is introduced by 'including' and is not exhaustive.
• Payment networks and payment processors are named among the service-provider functions.

Not stated here

• No vendor names or contractual limits are stated in this item.

Sharing & Disclosure · Company practice

Partners and other third parties may receive information for products and marketing, including joint marketing

Evolve may disclose information to partners with whom the user may interact directly and for whom Evolve may provide products or services, and to other third parties for marketing purposes, including joint marketing with other financial companies.

Supporting quotations

Partners, with whom you may interact directly and for whom Company may provide products or services.

Other third parties, for marketing purposes, including joint marketing with other financial companies.

Qualifications & exceptions

• The partner category is tied to partners with whom the user may interact directly and for whom Evolve may provide products or services.
• The marketing category expressly includes joint marketing with other financial companies.

Not stated here

• The policy does not name the partners or financial companies.

Cross-references

• contrast (model-proposed): Policy says it does not 'sell' or 'share' personal information as defined by the CCPA — The general disclosure section permits disclosures to other third parties for marketing, including joint marketing with other financial companies, while the later section says Evolve does not 'sell' or 'share' personal information as those terms are defined under the CCPA. The statements use different defined terms; the policy does not reconcile them, and this relation records the contrast without deciding how the definitions apply.

Sharing & Disclosure · Company practice

Credit reporting agencies receive account information as permitted by law

Evolve may disclose information to credit reporting agencies to report account information as permitted by law.

Supporting quotations

Credit reporting agencies, to report account information as permitted by law.

Qualifications & exceptions

• The stated limit is 'as permitted by law'.

Not stated here

• Which account information is reported is not specified here.

Sharing & Disclosure · Company practice

Information may be shared for legal compliance, terms enforcement, safety, corporate-group and advisor purposes

Evolve may also share information to comply with applicable law or obligations, to comply with applicable terms of service, to ensure the safety of the Company or its users, within its corporate group, with professional advisors such as auditors, law firms and accounting firms, or when the user consents, requests or directs the sharing.

Supporting quotations

We may also share your information to comply with applicable law or any obligations thereunder

to comply with applicable terms of service, to ensure the safety of the Company and/or its users, within our corporate group, with professional advisors such as auditors, law firms, and accounting firms, or when you consent, request or direct us to share information.

Qualifications & exceptions

• The purposes are alternatives in one list; the policy does not state that all apply at once.
• Sharing when the user consents, requests or directs is included in the same list.

Not stated here

• The policy does not describe the corporate group's entities here.

Sharing & Disclosure · Company practice

Information may be shared in an asset sale, merger, bankruptcy or other business transaction

The policy lists sharing in connection with an asset sale, merger, bankruptcy or other business transaction among the circumstances in which Evolve may share information.

Supporting quotations

in connection with an asset sale, merger, bankruptcy, or other business transaction

Qualifications & exceptions

• 'Other business transaction' is not defined in the policy.
• The policy does not state what happens to information after such a transaction.

Not stated here

• Whether a successor would be bound by this policy is not stated.

Sharing & Disclosure · Company practice

California table: identifiers disclosed to vendors, marketing third parties, credit agencies and partners

The California data table lists 'Identifiers such as name, e-mail address, IP address' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers, third parties for marketing purposes, credit reporting agencies, and partners for whom Company may provide products or services. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Identifiers such as name, e-mail address, IP address

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Third parties for marketing purposes

Credit reporting agencies

Partners for whom Company may provide products or services

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: Customer Records categories disclosed to vendors, marketers, credit agencies and partners

The California data table lists 'Personal information categories listed in the California Customer Records statute such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers, third parties for marketing purposes, credit reporting agencies, and partners for whom Company may provide products or services. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Personal information categories listed in the California Customer Records statute such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Third Parties for marketing purposes

Credit reporting agencies

Partners for whom Company may provide products or services

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: protected classifications disclosed to vendors or other service providers

The California data table lists 'Characteristics of protected classifications under California or federal law such as race, color, national origin or ancestry, sex, age, physical or mental disability, veteran status and citizenship' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Characteristics of protected classifications under California or federal law such as race, color, national origin or ancestry, sex, age, physical or mental disability, veteran status and citizenship

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: commercial information disclosed to vendors, marketers and partners

The California data table lists 'Commercial information such as records of products or services purchased' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers, third parties for marketing purposes, and partners for whom Company may provide products or services. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Commercial information such as records of products or services purchased

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Third Parties for marketing purposes

Partners for whom Company may provide products or services

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: internet or network activity disclosed to vendors or other service providers

The California data table lists 'Internet or other similar network activity such as information regarding your interaction with the website' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Internet or other similar network activity such as information regarding your interaction with the website

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: geolocation data disclosed to vendors or other service providers

The California data table lists 'Geolocation data such as IP address' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Geolocation data such as IP address

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: audio, visual and similar information disclosed to vendors or other service providers

The California data table lists 'Audio, electronic, visual, thermal, olfactory, or similar information such as photographs, video recordings and voice recordings' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Audio, electronic, visual, thermal, olfactory, or similar information such as photographs, video recordings and voice recordings

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: professional or employment information disclosed to vendors, marketers and partners

The California data table lists 'Professional or employment-related information such as title of profession, employer, professional background' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers, third parties for marketing purposes, and partners for whom Company may provide products or services. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Professional or employment-related information such as title of profession, employer, professional background

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Third Parties for marketing purposes

Partners for whom Company may provide products or services

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: inferences disclosed to vendors and third parties for marketing

The California data table lists 'Inferences drawn from other personal information such as profile reflecting your preferences' as a category collected in the preceding 12 months. For that row, the 'Categories of Recipients' column lists vendors or other service providers and third parties for marketing purposes. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Inferences drawn from other personal information such as profile reflecting your preferences

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Third parties for marketing purposes

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: government identifiers disclosed to credit agencies, vendors and partners

The California data table lists 'Government Identifiers* such as Social Security, driver’s license, state identification card, or passport number' as a category collected in the preceding 12 months and marks it with an asterisk as sensitive personal information. For that row, the 'Categories of Recipients' column lists credit reporting agencies, vendors or other service providers, and partners for whom Company may provide products or services. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Government Identifiers* such as Social Security, driver’s license, state identification card, or passport number

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Credit reporting agencies

Vendors or other service providers

Partners for whom Company may provide products or services

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: account access credentials disclosed to vendors or other service providers

The California data table lists 'Account access credentials* such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account' as a category collected in the preceding 12 months and marks it with an asterisk as sensitive personal information. For that row, the 'Categories of Recipients' column lists vendors or other service providers. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Account access credentials* such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company practice

California table: precise geolocation disclosed to vendors or other service providers

The California data table lists 'Precise geolocation data*' as a category collected in the preceding 12 months and marks it with an asterisk as sensitive personal information. For that row, the 'Categories of Recipients' column lists vendors or other service providers. The introduction states that disclosure for a business purpose is indicated in the table; the table does not give a separate purpose for each recipient.

Supporting quotations

Precise geolocation data*

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Vendors or other service providers

Qualifications & exceptions

• The row associates the category and recipient categories by table position; the policy does not state a separate purpose for each recipient.
• The table reports the preceding 12 months.

Not stated here

• The table does not name specific recipients within each category.

Sharing & Disclosure · Company commitment

Policy says it does not 'sell' or 'share' personal information as defined by the CCPA

Under the heading 'Selling and/or Sharing of Personal Information,' Evolve states that it does not 'sell' or 'share' personal information as those terms are defined under the CCPA, and has not done so in the preceding 12 months. It also says it does not have actual knowledge that it sells or shares personal information of residents under 16.

Supporting quotations

Selling and/or Sharing of Personal Information

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months.

we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

Qualifications & exceptions

• The statement uses the CCPA definitions of 'sell' and 'share'.
• The under-16 statement is limited to actual knowledge.
• The statement covers the preceding 12 months as well as current practice.

Not stated here

• The policy does not explain how the CCPA definitions apply to the marketing disclosures described in the general sharing section.

Cross-references

• contrast (model-proposed): Partners and other third parties may receive information for products and marketing, including joint marketing — The general disclosure section permits disclosures to other third parties for marketing, including joint marketing with other financial companies, while the later section says Evolve does not 'sell' or 'share' personal information as those terms are defined under the CCPA. The statements use different defined terms; the policy does not reconcile them, and this relation records the contrast without deciding how the definitions apply.