CABICASH SOLUTIONS, LL.C. (DBA UALETT)
Privacy Policy
Last updated: January 12 2019
This Cabicash Solutions, LL.C. (“UALETT”) Online Privacy Policy describes our
practices in connection with information that we collect through UALETT or any our
Third party Software Providers, including DWOLLA, any other websites
www.ualett.com that may be operated by us from which you are accessing this
Privacy Policy (the “Websites”), through the software applications made available by
us for use on or through computers and mobile devices (the “App”), through our
social media pages and apps used by us collectively, (our “Social Media Pages”) as
well as through text messages, and HTML-formatted email messages that we send
to you that link to this Privacy Policy (collectively, including the Websites, the Apps
and our Social Media Pages, the “Services”). As used in this Privacy Policy, The
Trademarks UALETT, UALETT App, or Cabicash Solutions, LL.C/ LLC., the licensor”
or “we” or “us” or “our” refers to the Cabicash Solutions, LL.C. (Doing Business As/
DBA UALETT).
This Online Privacy Policy supplements other applicable policies, practices and
privacy notices that may relate to specific business relationships you have with
Cabicash Solutions, LLC. (DBA UALETT) and our trusted partners or to certain
products or services, as described in the particular privacy notice. We will use and
share any information that we collect from or about our U.S. account holders and
visitors to the Services in accordance with our Terms of Service and Conditions.
With your consent, we may share your personal data with business partners that
request it in order to provide you with a better experience when using our Services or
the services of the business partner (including their independent marketing purposes
subject to their privacy policies). Those trusted business partners and Third Party
providers includes, but not limited to: Dwolla, Plaid, inter alia.
By providing Personal Information to us through the Services, you agree to the terms
and conditions (ToS) of this Online Privacy Policy.
Personal Information
Personal Information We May Collect Online
Personal Information” is information that identifies you as an individual or relates
to an identifiable person, such as information you provide via forms, downloads,
surveys, applications or other online fields, including:
Full Name (as in government issued ID)
Driver’s License information
Mailing address
Email address
Telephone number
Banking Account number
Routing number
Date of birth
Username and password
Profile picture (optional)
Business profile or company you are affiliated (Lyft, Uber, Via, Juno, Curb, inter
alia)
IP address
Current billing address
Mobile/cellular phone Number
If you share with us any Personal Information relating to other people to us or to our
service providers in connection with the Services, you represent that you have the
authority to do so and to permit us to use the information in accordance with this
Online Privacy Policy.
How We May Collect Your Personal Data
We and our Third Party Software Providers, may collect Personal Information in a
variety of ways, including:
Through the Services: We may collect Personal Information through the
Services, for example, when you sign up for one of our Cash Advance products,
newsletter or request information about one of service and products, such as
Cash Advance or any other receivable you may apply for.
From Other Sources: We may receive your Personal Information from other
sources, such as financial institutions, public available information, public
databases; joint marketing partners; social media platforms; from people with
whom you are friends or otherwise connected on social media platforms, as well
as from other third parties such as banks and other financial institutions.
We Use Personal Information as following:
We may use Personal Information or data:
To respond to your inquiries and process your requests, and provide you with the
best customer service.
To send administrative information to you, such as, information regarding the
Services and changes to our terms, conditions, payment reminder or requests,
and policies.
To allow you to apply for products and services, evaluate your eligibility for such
products and services, communicate with you regarding your application and
provide you with related customer service, whether it has been successful or not.
To send you targeted marketing communications that we believe may be of
interest to you.
To personalize your experience on the Services by presenting products and
offers tailored to you.
To send you emails through Third Parties Providers for payment in or if you fall in
arrears or are unable to make the relevant repayment for your Cash Advance.
For our business purposes, such as data analysis, audits, risk control, fraud
detection, monitoring and prevention, developing new products, enhancing,
improving or modifying our products and services, identifying usage trends,
determining the effectiveness of our promotional campaigns and operating and
expanding our business activities.
As we deem to be necessary or appropriate: (i) under applicable law; (ii) to
comply with laws and regulations and to comply with legal process and law
enforcement requirements; (iii) to respond to requests from public and
government authorities, including public and government authorities outside your
state of residence; (d) to enforce our terms and conditions; (e) to protect our
operations or those of any of our affiliates, including but not limited to DWOLLA;
(f) to protect our rights, privacy, security, safety or property, and/or that of our
affiliates, Third Party Software Provider, Dwolla, you or others; and (g) to allow us
to pursue available remedies or limit the damages that we may sustain.
This is How Cabicash Solutions, LL.C., May lawfully disclose your Personal
Data
Your Personal Information will be shared consistent with the U.S. Consumer
Financial Information Rule. For example, Personal Information may be shared: (i)
under applicable law; (ii) to comply with legal process; (iii) to respond to requests
from public and government authorities; (iv) to enforce our terms and conditions;
(v) to protect our operations or those of any of our affiliates; (vi) to protect our rights,
privacy, safety or property, and/or that of our affiliates, you or others; (vii) to allow us
to pursue available remedies or limit the damages that we may sustain; and (viii) in
the event of any reorganization, merger, sale, joint venture, assignment, transfer or
other disposition of all or any portion of our business, assets or stock (including in
connection with any bankruptcy or similar proceedings).
Other users of the Services and the general public
Please be reminded that any information you post or disclose on or through our,
profile pages and blogs and other services to which you are able to post information
and materials (including our Social Media Pages) will become public information, and
may be available to users of the Services and to the general public. We urge you to
use discretion when deciding to disclose your Personal Information, or any other
information, on the Services.
Other Information
Other or Additional Personal Data We May Collect
Other Information or Additional” is any information that does not reveal your
specific identity or does not directly relate to an individual, such as:
Browser and device information
App usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you
Aggregated information
How We May Collect Other Information
We and one of our Third Party Software Provider, Dwolla may lawfully collect Other
Information in a variety of ways, including:
Through your browser or device: Certain identifying information is collected by
most browsers or automatically through your device. We use this information to
ensure that the Services function properly.
Through your use of the UALETT App: When you download and use the
UALETT App, we and our Third Party Software Provider, Dwolla, may track and
collect UALETT App usage data.
Please be aware you will need to agree to additional terms and conditions when
downloading the UALETT App. Especially those from Third Party Software
Provider, Dwolla in order to successfully complete your request or any other
operation through our platform.
Please note that in most instances, a download of the UALETT application
alone will NOT be enough to determine your eligibility to accessing our
services. We urge you to carefully review our ToS and this Privacy Policy,
below, for a complete list of all the information and documentation you are
required to submit online.
Using cookies: We may use cookies and similar technology on our
Application and in our emails. Cookies are very small text files that may be
stored on your computer or handheld device when you visit a website or view
images or click on a link in an email. This technology works in different things,
such as letting you navigate between web pages efficiently and remembering
your preferences. In emails they help us to understand whether you have
opened the email and how you have interacted with it.
Our platform give you more information on this technology, how and where we
use the technology and how you can control it or opt out. UALETT, as a
mobile application functions with cookies. Cookies help us give you a better
service e.g. showing relevant tailored adverts to you across all UALETT
services and platforms. By using UALETT mobile application or closing this
message you agree to our use of cookies.
Using pixel tags and other similar technologies: Pixel tags (also known as
web beacons and clear GIFs) may be used in connection with some Services to,
among inter alia, track the actions of users of the Services (including email
recipients), measure and compile statistics about usage of the Services and
response rates.
IP Address: Your “IP Address” is a number that is automatically assigned to the
computer that you are using by your Internet Service Provider (ISP). An IP
Address may be identified and logged automatically in our server log files
whenever a user accesses the Services, along with the time of the visit and the
page(s) that were visited. We use IP Addresses for purposes such as calculating
usage levels of the Services, helping diagnose server problems, and
administering the Services.
Physical Location & Time Zone (s): We may collect the physical location of
your device to provide you with personalized location-based services and
content.
From you: Other personal data or information, such as your location or your
preferred means of communication, is collected when you voluntarily provide this
information. You can request us to remove any or all the information you have
provided us with.
Universally Unique Identifier of your handheld (UUID)
Application Version Installed
Mobile Phone Model (IOS, Android, etc.
By aggregating information: Aggregated Personal Information does not
personally identify you or any other user of the Services, (for example, we may
aggregate Personal Information to calculate the percentage of our users who
have a particular telephone area code).
We tell you How We May Use and Disclose Other Information collected or
provided by you
Please note that we may use and disclose Other Information for any purpose we and
our Trusted Business Partners, except where we are required to do otherwise under
applicable law. If we are required to treat Other Information as Personal Information
under applicable law, then we may use and protect it for all the purposes for which
we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information
(such as combining your name with your geographical location, your name and
company you are affiliated with, telephone number and or e-mail address). If we
combine any Other Information with Personal Information, we will treat the combined
information as Personal Information.
Our Third Party Software Provider (s)
In order to guarantee a satisfactory experience, Cabicash Solutions, LL.C., interacts
with several Third Party Providers that are listed in this Online Privacy Policy.
This Online Privacy Policy does not address, and we are not responsible for, the
privacy, information or other practices of any Third Parties, including any third party
operating any site or service. For instance, Dwolla and Plaid.
Please note that we are not responsible for the collection, usage and disclosure
policies and practices (including the data security practices) of other organizations,
such as Instagram, Facebook, Apple, Google, Microsoft, or any other app developer,
app provider, social media platform provider, operating system provider, wireless
service provider or device manufacturer, including any Personal Information you
disclose to other organizations through or in connection with the Apps or our Social
Media Pages.
Tailored Advertising
Online Behavioral Advertising (OBA) helps us serve you marketing messages that
are relevant to you, based on your behavior on the web and the usage of UALETT. If
you don’t want to receive targeted advertising, you can opt out of OBA. This would
remove your information from collection across UALETT, our affiliates, Third Party
Software Providers.
If you choose to opt out of advertisements or sharing any personal data with us, you
will still see ads, but they will probably be less relevant to you.
Your Security comes First
We seek to use reasonable organizational, technical and administrative measures
designed to protect Personal Data within our platform. Unfortunately, no data
transmission or storage system can be guaranteed to be 100% secure. If you have
reason to believe that your interaction with us is no longer secure (for example, if you
feel that the security of your account or someone’s you have referred to use our
services, you might have with us has been compromised), please immediately notify
us of the problem by contacting us in accordance with the “Contacting Us” section
below.
If you reasonably believe that the information you have shared with us is at risk, you
are entitled to:
To request access to, or erasure of, the personal data we hold about you.
To request us to restrict the processing of the personal data we collect and hold
about you.
To object to us processing any personal data relating to you.
You have the right to obtain certain personal data from us in a format that can be
transferred electronically to a third party.
Your Choice Based on our Advertising Strategies
If you no longer want to receive marketing-related texts or emails from us on a going-
forward basis, you may opt out by following the instructions contained in such email.
We also tell how to stop receiving these emails or texts.
We will try to comply with your request(s) as soon as reasonably practicable. Please
also note that if you do opt-out of receiving marketing-related emails from us, we
may still send you important administrative messages, and you cannot opt-out from
receiving administrative messages. Especially those in connection with your account
with us.
We attempt to assure your information is accurate
Keeping your account information up-to-date is very important. If you believe your
account information is incomplete or not current, please contact us by email contact@ualett.com or calling the following number (646) 513-4224.
Use of our Services by MINORS
The Services are not directed to individuals under the age of twenty-one (21), and
we request that these individuals do not provide Personal Data through the UALETT
App.
Governing Law
The Services are controlled and operated by Cabicash Solutions, LL.C. (DBA
UALETT), and Third Party Software Providers and other trusted business partners,
in the United States, and are not subject to the laws or jurisdiction of any state,
country or territory other than that of the United States. Your Personal Information
may be stored and processed in any country where we have facilities or in which we
engage service providers, and by using the Services you consent to the transfer of
information to countries outside of your state or country of residence.
Online Updates of Our Privacy Policy and APP Version
We may change this Online Privacy Policy. Please take a look at the “Last Updated
legend at the top of this page to see when this Online Privacy Policy was last revised
and updated. Any changes to this Privacy Policy will become effective when we post
the revised Online Privacy Policy on the Services.
Notice that UALETT may change or cancel the availability of any services at any
time with or without previous notice. You are not entitled to use the App or any other
services provided by Cabicash, LL.C., in any way that could harm them or impair
anyone else’s use of them. You may not use the platform to try to gain unauthorized
access to any service, data, account or network by any mean. Your use of the
Services following these changes means that you accept the revised Online Privacy
Policy.
Getting in Touch with Us
If you have any questions about this Online Privacy Policy, please contact us by
email contact@ualett.com or dialing the following numbers: (646) 513-4224.