This policy was last updated June 27, 2019
If you have questions about deleting or correcting your personal data please contact our support team at firstname.lastname@example.org.
Third Party Service Provider Terms
By using the Platform you are engaging in transfers between your external bank account (the “User Bank Account”) and the “Level Account.” The Level Account consists of funds held by Evolve for your benefit in an FDIC-Insured “FBO” account held at Evolve Bank & Trust, Member FDIC, a subsidiary of Evolve Bancorp, Inc. (the “Bank”). Further, the Platform uses Synapse Financial Technologies, Inc. (“Synapse”), a third-party banking software provider, to carry out all financial transactions between your User Bank Account and the Level Account.
It is essential for you to read and understand the Provider Terms, and by using the Platform you represent that you have read, understood, and agree to the Provider Terms, which may change at any time, here is a non-exhaustive list of terms you agree to when using the Platform:
Collection and Use of Information
Your use of the Platform may result in certain PII collected or used by Level or the Providers.
We may use the information collected for several purposes, including but not limited to:
Process applications and transactions;
Communicate with you;
Ensure legal and contractual compliance;
Protect against fraud;
Respond to customer service requests;
Perform analytics concerning your use of the Platform;
Improve the Platform; and
Carry out any other lawful purpose as may be disclosed to you at any time.
We may share the information collected with:
Non-financial service providers, such as identity verification and fraud prevention service providers;
Financial service providers, including the Providers;
Non-affiliated companies for Level’s everyday business purposes; and
Others in the form of aggregated and de-identified data, which cannot reasonably be used to identify you.
By using the Platform you consent to Level’s collection and use of information as specified below:
a) Registration Information.
In order to utilize some of the Platform you will need to set up an “Account” with us, we require certain identifying information that will be linked to your account, including your:
Mobile Number, and
We encourage you to exercise caution before voluntarily disclosing other types of PII about yourself, and prohibit you from disclosing any PII about another person, whether another account holder or not.
b) Verification and Compliance.
While users generally have the right to limit most information collected and shared via the use of the Platform, federal law requires the collection and verification of certain information as it relates to financial institutions. Specifically, in order to use the Platform, the Providers must verify certain information in order to carry out financial transactions. This information may include:
Date of Birth, or
Social Security Number.
Additional documentary evidence, such as photo identification, might also be collected and shared for legal compliance and identity verification purposes. Level or the Providers may also collect public or non-public information about you in order to verify your identity, to prevent fraud, or otherwise provide the Platform to you.
c) Linking User Bank Account.
In order to link your User Bank Account to the Platform, the Providers might use and verify certain information in order to carry out financial transactions. This information may include:
Account and Routing Details,
User Bank Account Username and Password, and
User Bank Account Security Questions and Answers.
Additional documentary evidence might also be collected and shared for legal compliance and identity verification purposes.
d) Transaction Information.
By using the Platform, Level or the Providers may collect your Transaction Information. “Transaction Information,” includes but is not limited to User Bank Account and/or Level Account:
Transaction Dates and/or Times, and
Other details relating to the transaction.
Level or the Providers may use Transaction Information, in an anonymized or aggregated format stripped of personally identifiable information, to operate, provide, develop, and improve the Platform.
e) Use Analytics
The Platform automatically collects certain types of technical information, such as:
Browser or Device Type,
Page Views, and
Date and Time of Visit.
We use this information to better understand how our visitors use the Platform, and to maintain and improve Platform.
We use Google Analytics to help us understand how our Users use the site. For more information about your PII and Google, please visit
f) Location Information & IP Addresses
Internet Protocol (“IP”) addresses indicate the location of your computer or mobile device on a network connected to the Internet. Using the Platform may result in the logging of IP addresses for systems administration, troubleshooting purposes, and to prevent prohibited account sharing. While this may be used to infer an approximation of your location when using certain features of the Platform, we do not log IP addresses to track your location. If you are an account holder, we may link IP addresses to PII in order to monitor account sharing and prevent prohibited activity.
g) Data Aggregation
In addition to the other uses described in this Policy, you agree that we may extract and use information from the information you disclose for the purposes of aggregating data in a non-identifiable method. This aggregated data may be used to improve Platform or without limitation, to develop, analyze, combine, or publish the aggregated data for commercial purposes.
The Providers may also place a cookie or similar file on your computer: (i) to customize your experience; (ii) to collect technical and navigational information; or (iii) for security purposes.
i) Behavioral Advertising; Marketing
We may use your PII to provide you with targeted advertisements or marketing communications. Our marketing communications contain information about unsubscribing from such communications.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s website at
You can opt out of targeted advertising by visiting:
Google at or
Digital Advertising Alliance’s online portal at www.optout.aboutads.info.
Protection of Certain Personally Identifiable Information
We take all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially PII. We disclose potential PII only on an as needed (or required) basis as follows:
To Our employees that: (a) need to know that information in order to process it on our behalf or to provide the Platform; and (b) that have expressly agreed not to disclose it to others. Note* Some of those employees, and contractors may be located outside of your home country; by using the Platform you consent to the transfer of such information to them.
As required by law such to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process.
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request
To any other third party with your prior consent to do so.
Feedback & Support
If you send us a request (via a support email or one of our feedback channels), we reserve the right to publish it (stripped of all PII) in order to help us clarify or respond to your request or to help us support other users (i.e. create a FAQ database).
We may provide technical support to service your Account with us. In order to do so, we may use certain PII, with your consent, to access your Account for the purpose of troubleshooting, running tests, and/or otherwise providing support. In providing technical support to you, we may potentially see other PII viewable on your Account pages. As with all other information, we will hold any information we encounter in the process of providing support to the highest possible security and protection standards.
Accessing and Updating your Personal Information
To review, access, or update your personal information to review its accuracy, or request deletion please contact us.
We will make commercially reasonable efforts to provide you with reasonable access to any of your personal or other account information held by Level within 45 days of your request. We provide this access so you can review, make corrections, or request deletion of your information. If we cannot honor your request within the 45-day period, we will tell you when we will be able to provide access. In the unlikely event that we cannot provide you access to your information, we will explain why we cannot do so.
Please note that any changes you make will be reflected in our active user database within a reasonable time, however we may retain information you submit for backups, archiving, prevention of fraud, to satisfy legal obligations, or otherwise we reasonably believe there is a legitimate reason to do so.
You can opt out of receiving marketing communication we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the emails we send you or by contacting email@example.com
Additional information for International Users
To prevent unauthorized access, safeguard data accuracy, and maintain the appropriate use of information, we have put in place appropriate physical, technical, and administrative procedures to protect the PII you submit. We make every effort to ensure the integrity and security of our network and systems. However, since the Internet is not 100% secure and as new technology evolves and emerges, we cannot guarantee that our security measures will prevent third-party interferences from illegally obtaining or tampering with your personal information.
Online Banking Security: The Bank employs bank grade processes and technologies to protect the privacy and security of your information when you bank online, including firewalls, encryption techniques, and authentication procedures.
We encourage you to help us by also taking precautions to protect your personal data when you use the Platform. Change your Account password often, using a combination of letters, numbers, and characters, and make sure you use a secure connection.
Privacy of Minors
The Bank, Synapse, and Level does not promote or offer the Platform for use by anyone under the age of 13 (“minors”), knowingly solicit or collect PII from minors, and will not knowingly link to any third-party website or platform that solicits or collects PII from minors. If you believe that a minor has disclosed PII to us or that we have linked to such a third-party or user website or platform, please contact us.
If our ownership substantially changes, such that all of its assets were acquired, or merged into another entity, or in the unlikely event that we enter bankruptcy, you understand that any stored personally identifying, and non-personally identifying information and data will likely be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer or our merging entity may continue to use your personal information as set forth in this policy.