Last Updated December 15, 2020
By using our Services, you are consenting to our processing of your Personal Information and data as set forth in this Policy now and as amended. As used herein, “processing” means using or accessing information in any way, including but not limited to collecting, storing, deleting, combining, and disclosing information. Our servers are located in the United States. Accordingly, if you reside outside the U.S., by using the Services, you acknowledge and agree that your Personal Information will be transferred to the United States and processed and stored in the United States. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
1.1. Information You Give Hatch.
If you open an account or use the Service, we may collect the following types of information: Information we use to verify your identity and manage risk: - your name, social security number, address, phone, email, photo IDs, credit history, transaction history and other similar information. Business information – name, address, phone, email, beneficial owners, employees, EIN, credit history, transaction history and other similar information. Financial information - bank account information, transaction history and/or numbers and other similar information. Before permitting you to use the Services, we may require you to provide additional information in order for us to manage risk, make decisions about your eligibility for our products, or manage risk by verifying your identity or other information that you provide.
1.2. Information Hatch Learns From Your Use.
In addition to the information that you provide to us, we collect certain information automatically through your use of our website or interaction with our advertisements at other websites. For example, we may collect data regarding your use of the website directly or through our service providers using cookies, web beacons, page tags, pixels or similar tools that are set when you visit the website or when you view an advertisement that we have placed on another site (“Clickstream Data”). Clickstream Data may include computer and connection information such as statistics on your page views, pathways to and from the website, referral URL, ad data, IP address (which can be used to derive the location of your device), device identifiers, the type of operating system and browser you use, and other device settings. Clickstream Data also may include your browsing history, transaction history, your web log information and other information that may be aggregated and/or de-identified. Clickstream Data helps us suggest product or service offerings that may be of interest to you. This information may be used by us (or third parties on our behalf) for business purposes as permitted by law.
When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account. We may also collect information about you from any contact you have with any of our Services or employees, such as, with our customer support team, in surveys, or through interactions with our affiliates.
1.3. Location Data
Hatch may receive varying degrees of location information from Social Media stored by third parties such as social media websites and services or banking websites. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. that you enable within our Service and also (with your permission) from your computing devices (“Location Data”). For example, we may collect and use location data (e.g. GPS or IP-based geography detection) to screen for fraudulent activity or to verify self- reported information (for example, to verify you reside in a certain city or near a university in which you are enrolled) and to customize the Service to make it more relevant to you (for example, to send newsletter information that may be of interest to you).
1.4. Server Log Data
1.5. Cookies and Anonymous Identifiers
1.6. Information Obtained From Third Parties.
1.7. Bank Access/Login Credentials
Prior to establishing a Hatch line of credit or business bank account (jointly and individually, a “Hatch Account”) or after a Hatch Account is established, or both, we invite Hatch Account holders to enter certain login credentials (such as a username and password) for certain online account types (for example, debit cards, or traditional bank accounts) in order to verify identity. These credentials provide Hatch with consistent and reliable access to each financial account. Hatch uses such access to among other things, counter fraud.
2.1. Safety Policies
Hatch stores and processes your information maintaining physical, electronic and procedural safeguards. We maintain physical and electronic security measures to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our offices, and we authorize access to personal information only for those employees or agents who require it to fulfill the responsibilities of their jobs.
3.1. To Improve Our Service.
Hatch uses the Personal Information you provide in a manner that is consistent with this Policy. We may use your information, including nonpublic personal information as follows:
To provide, maintain, and improve our Services; To provide inputs to our credit underwriting system and to assess creditworthiness of credit card applicants; To provide and deliver the products and services you request, process transactions and send you related information, including confirmations; To verify your identity and prevent fraud or unauthorized access; Send you technical notices, updates, security alerts and support and administrative messages; To respond to your comments, questions, and requests, and provide customer service; To communicate with you about products, services, offers, promotions, incentives, and events offered by Hatch and others, and provide news and information we think will be of interest to you; To monitor and analyze trends, usage, and activities in connection with our Services; To comply with legal obligations; To personalize and improve the Services and provide advertisements, content, or features that match user profiles or interests; To process and deliver contest or promotion entries and incentives; To link or combine it with the information we receive from others to help understand your needs and provide you with better service; and to carry out any other purpose for which the information was collected.
If you contact us by email we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you and provide you with information about our products and services and the products and services of our partners that we believe may be of interest to you. If you decide at any time that you no longer wish to receive such marketing information or communications from us, please follow the unsubscribe instructions provided in any of our communications.
In an ongoing effort to better understand and serve the users of our Services, Hatch occasionally conducts separate research efforts on its customer demographics, interests, and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed in the aggregate and Hatch may share this aggregated data with its affiliates, agents and business partners. This aggregated information does not identify you personally. Hatch may also disclose aggregate user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
3.2. To Serve Relevant Marketing to You.
We may use information to deliver targeted marketing, service update notices, and promotional offers based on your communication preferences. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.
4.1. For Our Everyday Business Purposes.
We share your personal information with employees, affiliates, vendors, partners, merchant partners, marketing providers, and third parties as required to offer the Services. This includes, but is not limited to, processing transactions, maintaining your account, responding to legal and regulatory matters, litigation purposes, complying with audits or other investigations, and reporting to credit bureaus. We may share your information with our partners for marketing purposes, and as otherwise permitted by law.
4.2. When Required By Law.
We will share your information with any party when required by law, regulation or by a government request to do so or to combat fraud or other criminal activity. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
4.3. With Our Partners to Provide Personalized Offers.
We may share your information with our partners for marketing purposes, if you consent or as permitted by law. You’re able to revoke your consent at any time by following the steps below. If you choose to do so, we will stop sharing your information with partners from that point onward, except as necessary to complete transactions you initiate. To revoke your consent to information sharing with merchants for marketing, you can send us the request to email@example.com or at 1-888-516-2369.
4.4. To Enable Our Service Providers.
Hatch shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Hatch operates.
We don't sell or rent your personal information to third parties without your permission.
6.1. Your Right to Opt-Out.
If you no longer wish to receive notifications (such as SMS or email messages) about our Services, you may change your notification preferences by sending us an email to firstname.lastname@example.org or at 1-888-516-2369. Alternatively, you may be able to indicate your preference by logging into your account and adjusting your preferences or by following the directions provided with the communication. Hatch reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Services. You are still responsible for any amounts due to Hatch even if we close or limit access to your account.
6.2. Your Right To Access Your Information.
6.3. Learn about State Laws.
6.4. European Union General Data Protection Regulation (EU GDPR).
The aim of the GDPR is to protect the “personal data” of EU citizens – including how their personal data is collected, stored, processed and destroyed. The meaning of “personal data” under the GDPR currently exceeds how similar terms are defined in the U.S. Hatch, Inc. accepts and reviews all applicants for credit, however, the Company only offers lines of credit and/or banking services to residents of the continental US.
6.5. Contact Hatch.
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the U.S. Online Privacy Notice of Hatch and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device
(“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
US Postal Mail to:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must:\
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to Our U.S. Online Privacy Notice and this State-Specific Notice
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at: