Settle Privacy Notice
Effective Date: October 1, 2024
This Privacy Notice applies to the use of and interaction with Settle Inc., Settle Funding, LLC, and their affiliates (collectively “Settle”), and for all Settle websites, applications, promotions, products and services (collectively, the “Service”), including all those that link to this Privacy Notice, and describes how Settle collects, uses, shares, transfers, stores, retains, or otherwise processes your personal information. This Privacy Notice also applies to any surveys, rewards, promotions, sweepstakes, contests, referrals, or other marketing activities conducted by Settle or in connection with the Service (collectively “Settle Marketing”). Settle will share your information only as described in this Privacy Notice, or as permitted by law. Capitalized terms not defined in this Privacy Notice have the meanings given to them in Settle's Terms of Service. Please review this Privacy Notice carefully.
This Privacy Notice does not apply to, and we are not responsible for, any third-party services, websites, or applications that are not owned or controlled by Settle, including those that link to the Service. To understand how third parties process and protect your information, we recommend that you review their privacy policies, terms of use, and websites.
This Privacy Notice may be updated periodically and will be posted on the Settle Website (the “Website”), indicating when it was last updated. If there are material changes to our Privacy Notice, we will post a notice on our website and/or provide other notice as required by law. If you object to any changes to this Privacy Notice, you can cancel your account at any time in accordance with our Terms of Service.
Information that We Collect from You
Contact Information. We may collect your contact and professional information, including name, email address, telephone number, job title, as well as company name and size.
Account Information. When you sign up for a Settle account or register as a Settle user, we collect contact and identifying information about you, including but not limited to your contact information and organization information, including company name and address, formation documents, business license, tax documents, phone number and business email address. We may also collect sensitive personal information to establish your business account.
Sensitive Personal Information. As part of your account and financial information or identity verification, we may collect sensitive information, such as your gender, ethnicity, date of birth (natural persons), Tax Identification Number or Social Security Number (collectively, “TIN”), and your government-issued identification.
Device Information. We may require you to provide device information to receive multi-factor authentication.
Financial Information. When you use the Service to make or receive payments, we collect certain financial information from you, such as bank routing and account information, including bank statements and verification of bank account ownership, and/or a credit or debit card to bill service fees. We may also collect information to verify financial condition and creditworthiness, such as monthly revenue.
Business and Customer Contacts. We may collect information from you about your business customers and vendors, including but not limited to name, address, email address, phone number, TIN, and financial information, based on your use of the Service and payment instructions. If you choose to import contacts from your email account, including to invite those contacts to use the Service, we will collect the username and password for the linked email account, as well as the contact information for your contacts.
Payment Transaction Information. When you request, make, receive, record, or otherwise process a payment through the Service, we collect information about the payment transaction and the transacting parties, such as the date, time and location(s) of the transaction, identifying information of the sender and recipient, the payment or transfer amount(s), bank account information for the sender and/or recipient, a description of the transaction, and any service fees Settle may charge.
Other Transactional Information. We collect information that you choose to provide in connection with your use of Settle’s Services.
Customer Support and Feedback. We collect information that you choose to provide to us in connection with your contacting Customer Support, or when you provide feedback about Settle or the Service, including through your use of the Service or your participation in Settle marketing. Settle may, without further notice or warning and in its sole discretion, where permitted by law, monitor or record telephone conversations between Settle or its agents and you or anyone acting on your behalf, for quality control and training purposes, or for Settle's protection.
Referrals. You may provide the Contact Information of businesses that may be interested in our Service. We will use this information to send an email invitation to use Settle to the business you are referring. Settle may retain the referral information, but solely for the purpose of tracking the success of our referral program.
Online Forms. We collect the information that you provide to us through online forms, including but not limited to forms on our Website or social media forms, such as Settle webinar sign-up forms or LinkedIn forms.
Settle Marketing Participant Information. We collect the information that you provide voluntarily in connection with your participation in Settle marketing, including but not limited to engagement at event booths, surveys, and referrals.
Other. We may also collect information from you when you visit our Website. As we introduce new products, services, or features, we may collect new and different types of information from you when you use the Service or contact Settle in connection with your account. If there are material changes to our Privacy Notice, we will post a notice on our website and/or provide other notice as required by law. If you object to any changes to this Privacy Notice, you can cancel your account at any time.
Information We Collect from Your Use of the Settle Service
The following categories of data that are automatically collected when you interact with our Service:
Device Information. We collect information about your device when you install, access, or use the Service on that device. The device information that we collect may include IP address, hardware model, operating system information, Settle app version, browser information, and mobile network. Your device may also allow us to collect and use information received through device-based settings, such as access to your contacts, based on your settings.
Analytics Information. When you interact with our Service we collect information about how you access and use the Service, including but not limited to your geolocation information, the domain name of the Internet Service Provider you use, the date(s) and time(s) you access the Service, the pages you access and view, any term(s) you search, and the individual address of the device that you use to interact with the Service.
Application Integration. We may also collect information about you from third-party services that are supported by, or sync or integrate with the Service, including but not limited to third-party data entry services or accounting software providers.
Business Record Information. This includes records of your purchases of products or Service.
Marketing information. We use special advertising and other unique identifiers, such as cookies, that enable us, or third parties working on our behalf, to gather information about your activities in order to provide you with targeted advertising based on your online activity and interests. For more information, please see the section, “Cookies and Third-Party Technologies” below.
Information We Collect about You from Third Parties
Contact Information. We may collect demographic information, and information about your interests and purchases from consumer data providers.
Vendor or Business Customer Information. We collect information from third parties you choose to interact with through Settle. We collect information about you from third parties with whom you interact through the Service, including but not limited to your vendors or business customers.
Financial Information. We may obtain information about your credit history from credit reporting agencies. We may also collect your banking information and business records when you create an account.
Address and Organization Information. We collect information about you or your organization from commercially available sources to ensure the accuracy of your account information (e.g., that your address is accurate and up-to-date).
Marketing. We collect information about current and prospective users of the Service from third-party services, including but not limited to lead generation services and providers of customer and lead data, as well as enriched data about visitors to our Website.
Device Information. We use third-party service providers to collect device information for risk management and fraud detection and prevention.
How we use the information we collect
We use the information that we collect for purposes of:
Registering Your Account. When you create a Settle account or enroll as a Settle account user, we use the information that we collect about you, including any identifying information or financial information, for purposes related to the review, establishment, provision, administration, maintenance and monitoring of your Settle account or your use of the Service.
Identify Verification. We collect information about you from third parties, as required and permitted by law, including but not limited to for purposes of verifying your identity and/or complying with anti-money laundering and anti-terrorism financing laws, “know your customer” regulations, and Federal sanctions requirements.
Providing our Service to You. We use the information that we collect about you, together with information that you provide about your business customers and vendors and the content that you upload to the Service, to provide the Service to you in accordance with your instructions and Settle account settings and elections. We also use your information to process payments requested by you and to provide you with transaction history and account information and to conduct general business operations, such as accounting, recordkeeping, and audits. We will only use this information for the purposes for which it is shared by you.
Communicating With You. We will use your information to contact you about the Service or your Settle account, and to provide you with security, technical support, customer support, and administrative messages, including for purposes of multi-factor authentication.
Providing customer service and technical support. We use your information to process and respond to your requests or inquiries, and to provide you with customer service, technical support, or software updates.
Improving and Developing the Service. We aggregate your information, including your payment transaction information and your feedback to Settle, with information from other Settle users and use that data to improve the Service, to develop new Settle products or features, and to enhance the quality of the Service. We use this information to provide you with a better experience, to administer the Service, to improve the quality and value of the Service, and to gather broad demographic information about how the Service is used. If you link to a third-party service, website, or application through the Service, we may track whether the link has been followed to improve the quality of the Service and Settle's partnership activities.
Marketing and Advertising. We use the information that we collect about you to market the Service to you, and to communicate with you about Settle products or features, or Settle marketing, that may be of interest to you. We may also use information about you for our marketing purposes, including to identify other similar prospective business customers who may be interested in the Service.
Referrals. We will use this information to send an email invitation to use Settle to the person you are referring. Settle may retain the referral information, but solely for the purpose of tracking the success of our referral program.
Security. We use the information we collect from you to prevent, detect, investigate, and report fraud or security incidents related to your use of the Service or your Settle account. We use your information to investigate any error, unauthorized transaction, or other fraud or security incident that we discover or that you report to us.
Legal Compliance. We collect information about you to comply with legal processes, such as warrants, subpoenas, court orders, and in connection with certain types of lawful regulatory or law enforcement investigations, or as otherwise permitted to comply with applicable legal requirements.
How we share the information that we collect
We share your information:
With Third Parties That You Authorize. We may share your information with other users on your Settle account. If you are the administrator for a Settle account, we will share your information with your users in accordance with your account settings and preferences. If you are a Settle user, the account administrator can access your information and change certain of your settings, and Settle may send information about your use of the Service to the administrator. If you sign up or authorize your accountant or another third-party service provider to use or access the Service on your behalf, or to use your Settle account, we will share your information with that authorized third party.
With Third Parties You Choose to Interact With Through Settle. We share your information with third parties that you choose to interact with through the Service, including but not limited to your vendors or business customers. We may also share your information with third-party services that are supported by and integrate or sync with the Service, based on your choices and account settings, such third-party data entry services, accounting software providers, or social media sites that link to the Service. We will only use this information for the purposes for which it is shared by you.
With Others on the Settle Network to administer relevant transactions. We may share certain information provided by you with members of the Settle payment network to administer relevant transactions. We will only use this information for the purposes for which it is shared by you.The processing of your information by any other member of the Settle network is governed solely by the privacy policy of the third party.
With our Third-Party Service Providers and Business Partners. We may share your information with our third-party service providers and business partners as needed to provide, maintain, support, secure, and improve the Service. Services provided to Settle by these third-party providers include, but are not limited to, identity verification, payment processing, fraud prevention and detection, database management, data storage, web analytics, and marketing services. Our third-party service providers have access to your information only for the purposes of performing specific tasks on our behalf in compliance with our Terms of Service, and are obligated not to use or disclose your information for any other purpose or in any manner that is inconsistent with this Privacy Notice.
Online Advertising Partners. We may partner with companies that assist us in advertising our Service, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.
Government Entities/Law Enforcement. We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the safety of our employees, our customers, or other individuals.
In Connection with Business Transactions or Corporate Changes. The information that we collect in connection with the Service is a business asset. As a result, we may share or transfer your information in connection with a business transaction or potential business transaction, such as a merger, acquisition, reorganization, financing, asset sale, or bankruptcy.
Identify Verification. We collect information about you from third parties as required and permitted by law, including but not limited to for purposes of verifying your identity and/or complying with anti-money laundering and anti-terrorism financing laws, “know your customer” regulations, and Federal sanctions requirements.
Other Purposes. We share aggregated and anonymized information with third parties for industry and clickstream analysis, demographic profiling, and other purposes. Aggregated and anonymized information shared for these purposes will not contain personal information that can be associated with you.
With Your Consent. We may share your information at your direction or with your consent.
How long we retain information
Settle will retain your information in accordance with our internal records retention and management policies and procedures, including as necessary to provide you with the Service or administer your Settle account, or as long as necessary to comply with our legal obligations, resolve disputes, reserve our legal rights, and enforce our agreements.
How We Protect and Secure Your Information
Settle is committed to protecting the security and privacy of your information. Settle recognizes the importance and confidentiality of your information. We have implemented technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, use, and modification. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
International Transfers
Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, we may transfer such information to the United States or other jurisdictions for processing. Your submission of such information represents your consent to that transfer.
Special Information for Job Applicants
When you apply for a job with us, we may collect information from you, including:
- Information you provide in connection with your application.
- Information that you make available through your social media accounts.
- Information about you that is available publicly.
- Information that you authorize us to collect via third parties, including former employers or references.
In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.
Information for Children Under the Age of 18
Persons under the age of 18 year are not eligible to use, access, or otherwise interact with Settle or the Service. If we become aware that a child under the age of 18 has created an account with us, or is otherwise using the Service, we will take steps to remove access, disable the account, and delete any information related to the child as soon as reasonably possible.
Privacy Disclosures for Specific Jurisdictions: California
The California “Shine the Light” Law. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. Please contact us to obtain this information. We do not share your information with third parties for their direct marketing purposes.
Cookies and Third-Party Technologies
Settle and our third-party service providers set and use cookies and similar technologies to store and manage user preferences, enable content, gather analytic and usage data, and deliver targeted advertising. A cookie is a small text file that is placed on a computer or other device, and is used to identify the device and to collect information.
Cookies are typically assigned to one of the following categories, depending on their function and intended purpose:
- Essential cookies enable you to navigate our Website and to use the Service. Without these cookies, our Website will not perform as smoothly for you as we would like, and we may not be able to provide certain core functions and features.
- Analytics cookies collect information about the use of our Website and application, and enable us to improve the way our Service works. For example, analytics cookies show us the most frequently visited pages and analyze site traffic. We use them to analyze broad trends and patterns of usage on our Website, rather than to monitor the usage of any particular individual.
- Customer interaction cookies allow us to communicate with you, including for purposes of real-time communication through our chat feature.
- Marketing cookies track browsing habits and are used to deliver targeted (interest-based) advertising.
For information about how you can control the use of cookies, please see “How You Can Manage Your Privacy Choices,” below.
How You Can Manage Your Privacy Choices
Controlling Your Profile Visibility. When you create a Settle account, you will create an account profile. The settings that you choose for your profile will control how your profile information is shared within the Settle payment network or with the public.
Updating Your Account Information. You can access, update, change, or correct your account information at any time by accessing your profile through the Service. You can also change your email preferences through your Settle account profile settings at any time. You understand that if you restrict processing of the information associated with your Settle account, you may lose access to certain features and functionalities of the Service, including but not limited to the ability to request or send payments through the Service.
Cancellation of Your Account. You may cancel your Settle account at any time through the Service. See our Terms of Service for more information on canceling your Settle account. After cancellation of your account, this Privacy Notice will continue to apply to any information collected about you by Settle.
Managing Marketing Communications From Us. We will honor any request from you to opt out of receiving marketing communications, including emails and text messages.
- To opt out of receiving marketing emails from Settle, click the “unsubscribe” link at the bottom of a Settle marketing email.
- For marketing text (SMS) messages, reply “STOP” or follow the instructions in the message.
Please note that, even if you choose not to receive marketing communications from Settle, we can continue to send you informational communications related to your use of the Service or your Settle account.
Device Settings. The device that you use to interact with the Service may have setting options that can be enabled or disabled to allow the Service to access and use certain information on your device. You can adjust your device settings if you do not want Settle or the Service to have access to this information or these features.
You can also adjust your device or browser settings to block or provide notice of cookies on your browser or mobile device. Please note, however, that disabling or limiting certain cookie settings on your device or browser may prevent you from interacting with some or all of the features of the Service, or may require you to do additional authentication.
Opting Out of Targeted Online Ads. We may use cookies to gather information about your activities in order to provide you with targeted advertising based on your online activity and interests.
- Opt-Out Choices. The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.
- Browser Plug-Ins. We use third-party service providers, including Google Analytics, to analyze the use of our Website. You can opt-out of the use of web analysis at any time either by downloading and installing a Browser Plugin offered by Google or by configuring your browser to delete and reject cookies.
- Do Not Track. Most browsers are set up to accept cookies automatically. You can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. Some browsers have “Do Not Track” features that allow you to tell websites not to track you. These features are not all uniform. Settle does not currently respond to “Do Not Track” signals.
If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you. If you delete your cookies, you may also delete your opt-out preferences.
If You Sync or Connect Your Settle Account with Third-Party Services. If you choose to sync or connect your Settle account with third-party services, such as accounting software services or social media sites, we will share your information with the third-party service provider. If you do not want us to share your information with these third parties, you can choose not to sync or connect your Settle account with the third-party service.
Community Forums. Settle may offer blogs and publicly accessible community forums. You should be aware that any information you provide in these forums may be read, collected, and used by others who access them.
Auto-Dialed Calls. When contacting you by phone, we may use, and you consent to receive, as permitted by applicable law, informational autodialed calls and text messages, as described in our Terms of Service. If you wish to opt-out of receiving autodialed calls or text messages from Settle, you can contact Settle.
You understand that if you opt out of receiving informational autodialed calls or text messages, such as for multi-factor authentication, you may lose access to certain features and functionalities of the Service, including but not limited to the ability to request or send payments through the Service.
Contact Us
Please contact us if you have questions or wish to take any action with respect to information to which this privacy policy applies.
Settle
Attn: Operations
29 West 17th Street, 2nd Floor
New York, New York 10011
E-SIGN Disclosure and Consent
Settle’s E-SIGN Disclosure and Consent