EarnIn has a privacy program that focuses on
respect, fairness, and transparency in the collection, use, disclosure, and retention of Personal Information (as defined below). This Privacy Policy will help You understand EarnIn’s data protection practices and Your rights with respect to Your Personal Information. We will from time to time update this Privacy Policy as We adopt new privacy practices in response to updates in the law, to align with changing industry best-practices, and to reflect Our Services enhancements. If You have any questions, please
contact Us.
Helpful Definitions
The following definitions will help You understand the terms of this Privacy Policy. Capitalized terms not defined below have the meaning assigned to them in Our
Terms of Service.“Agent” means an individual who acts on behalf of an unaffiliated third party (including Service Providers and Bank Partners), such as staff members, officers, and beneficial owners (as applicable).
“Community Member '' means an individual who uses or has used EarnIn’s Services.
“EarnIn” or “We” or “Us” or “Our” means Activehours, Inc., and the following affiliates: Activehours-Courage LLC, Earnin Activehours 1 LLC, EarnIn US1 LLC, EarnIn International Holdings LLC, Earnin Canada Inc., EarnIn (Thailand) Limited, EarnIn Mexico, S. de R.L. de C.V., Taslar, Inc., and Activehours-River LLC.
“Bank Partners” means Evolve Bank & Trust and Lead Bank.
“Bank Products” means products issued by our Bank Partners such as the Deposit Account, Secured Account, and the EarnIn Card.
“Service Providers”” means a trusted third-party company that helps us operate Our business and provide services to You. They may assist with things like connecting Your bank account to the Site, identity verification, payment processing, payroll processing, customer support, credit reporting agencies, data security, and analytics. These providers are only allowed to use Your information to perform the services we’ve hired them for and are not permitted to sell or use your data for any other purpose.
“Opt-In” means You expressly and unequivocally chose to give consent.
“ EarnIn Payroll” means the payroll platform] powered by EarnIn and accessible in our Site..
“EarnIn Payroll End User” means the employees who access their payroll through EarnIn Payroll.
“EarnIn Payroll Licensees” means the service bureaus that contract with EarnIn to sublicense EarnIn Payroll to EarnIn Payroll Users.
“EarnIn Payroll User” means the employers who make payroll information accessible to their employees via EarnIn Payroll.
“Opt-Out” means You expressly refuse to give consent, or You withdraw Your consent (as applicable).
“Personal Information” means any information that identifies You or can identify You. Some examples are: full name, address, phone number, government ID, Social Security Number (“SSN”), IP address, Your picture, biometrics, employment history, education history, Your bank account information, bank transactions data, Services transactions data, geolocation, consumer behavior.
“Sensitive Personal Information” the following Personal Information is considered Sensitive Personal Information: financial account number, SSN, account log-in credentials, debit or credit card number in combination with any required security or access code, password allowing access to an account, geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, the contents of a consumer’s mail, email, or text messages (unless the business is the intended recipient of the communication), genetic data, health data, consumer’s behavior, sexual orientation and sex life.
“Services” means EarnIn’s products, services (including third-party services), and features, available to individuals through our Site.
“Site” means Our websites and Our mobile application.
“You” or “Your” means Community Members, Agents, employment applicants, or Site visitors (as applicable).
About this Privacy Policy
This Privacy Policy applies to EarnIn and Our subsidiaries, divisions, affiliates, and operations that link to or otherwise provide notice of this Privacy Policy. Additional privacy disclosures or policies may apply in connection with Your use of a specific Service or relationship You may have with one of Our lines of business. Please read this Privacy Policy and any additional privacy disclosures or policies to understand Our practices and Your rights. Unless We advise you otherwise, this Privacy Policy does not apply to third-party websites accessible through Our websites.
Who is EarnIn?
EarnIn is a U.S. financial technology company, not a bank. However, EarnIn provides access to some Bank Products in partnership with our Bank Partners. When You sign up for a Bank Product, EarnIn collects and uses Your information on behalf of Our Bank Partners to provide You with the Bank Services. Your information, where applicable, is shared with the Bank Partner and is subject to Our Bank Partner's privacy notice that governs that financial product or service and is available via the link(s) below, except where You may have directly received a more recent policy for such product or service via mail or email. While EarnIn is not responsible for Our Bank Partners’ privacy practices, We may publish their notices and process data requests as their service provider. We encourage You to review their privacy notice before signing up for a Bank Product.
Does EarnIn Comply with Strict Privacy Regulations (Like Banks Do)?
Absolutely! Even though EarnIn is not a bank, for certain of its financial products EarnIn is subject to the same federal, state, and foreign privacy laws (as applicable) that banks located in the United States comply with. For instance, EarnIn complies with a federal privacy law called the Gramm-Leach-Bliley Act (“GLBA”). The GLBA protects the Personal Information that financial institutions collect about their customers for the purpose of providing financial services (for personal or household use). For more information about Our privacy practices for Our financial services, please see Our
Short Privacy Notice. EarnIn also complies with state privacy laws that apply to its products and services and, where applicable. Your rights are listed at the end of this Privacy Policy.
What Personal Information Does EarnIn Collect About You and How is it Collected?
Context | Categories of Personal Information Collected |
When You register for an account on Our Site, use Our Services and/or communicate with Us for purposes of obtaining Our Services, You may be asked to provide: | Identifiers, such as Your full name, alias, cell phone number, email, home address, proof of domicile, work address, date of birth, employer’s name, SSN or Individual Taxpayer Identification Number (“TIN”), government identification number, Driver’s License number or other state identification, andIP address. You may also choose to provide access to Your contacts’ information as well. Employment information, such as Your employer’s name and address, Your salary, and time and attendance. Sensitive personal information, such as SSN, Your account log-in, bank account information in combination with any required security or access code, password, or credentials * allowing access to the account, and device signals (GPS, Motion, Pedometer, Bluetooth, Wi-Fi)*. |
If You use or visit Our Site, We automatically collect information about Your activity on the Site using tracking technologies. For more information see Our Cookie Notice. | Internet or other electronic network activity information, such as browsing history, information on Your interaction with Our Site, device identifiers, time zone setting. Sensitive Personal Information, such as device precise geolocation data. Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes. |
If You choose to receive marketing communications from EarnIn via SMS, You will be asked to provide: | Identifiers, such as Your cell phone number. |
If You choose to participate in promotions, contests or giveaways made available by EarnIn through social media platforms and/or other alternate means, You will be asked to provide/share: | Identifiers, such as Your full name, social media profile, email, phone number, and/or Your mailing address.
Sensitive Personal Information, such as SSN (for tax reporting purposes, if applicable). |
If You choose to participate in an EarnIn survey, You may be asked to provide: | Identifiers, such as Your full name, phone number, email address and physical address. Other personal information, such as financial habits, financial preferences, interests. |
If You apply for a job posting directly on Our Site or indirectly through one of Our recruiting partners, You may be asked to provide: | Identifiers, such as Your full name, cell phone number, email, and address. Employment Information, such as Your resume, employment history, education history, and references. Sensitive personal information, such as Your ethnicity, race, and pronoun. Protected classification characteristics under California or federal law, such as race, citizenship, physical or mental disability, gender identity, and veteran or military status. |
If You choose to participate in Our advocacy and engagement efforts, You may be asked to provide the following Personal Information to help Us determine Your local, state and federal representatives; to contact You; and to direct Your emails and/or calls to the appropriate representative or third party: | Identifiers, such as Your full name, cell phone number, email, and address. |
If You are a non-affiliated third party (including Service Providers and Bank Partners), You may be asked to provide the following information for due diligence purposes, or for other reasons associated with the performance of the contract: | Commercial information, such as corporate bank account information, corporate tax ID, incorporation documents identifying beneficial owners and officers of the company. Identifiers of Your agents and/or beneficial owners, such as full name, work address, telephone number, email address, date of birth, and government Identification number. |
I If you use EarnIn Payroll, You may be asked to provide the following information for Us to make EarnIn Payroll available to You, to manage Your user account, allow You to log in and access Our Services, to deliver the requested Services to You (including personalized interactions), to offer services to You, and to protect the security of Our Services by investigating suspicious activity and enforcing our terms and policies. | Identifiers such as name and email, date of birth, and your employer name, as well as IP address, operating system type and version, whether service tasks and notifications complete, date and time stamps, and details about which of our Services You are using. Authentication information, such as mobile number, email address, or other unique verification identifiers. System-generated information. Sensitive personal information, such asSSN, Your financial account log-in*, bank account information (routing number, account number, and debit card number). |
* Please note in some instances, such as when you connect Your bank account to the Site, You will be asked to provide to Our Service Provider, certain login access credentials (e.g., username and password) or other account or financial information. This information is provided directly by You to Our Service Provider under the Service Provider's privacy policy. You may only provide account credentials to access a valid account that You hold in Your own name. The account login credentials of Your bank account are not stored at or accessible to anyone at EarnIn. Please also note that if you connect Your bank account via our Service Provider, We may collect your bank transaction history.
* With Your express consent, We collect optional device signals such as GPS, motion activity, step count, Bluetooth, and Wi-Fi to help verify when you enter or exit your approved work location. These signals are used only to improve the accuracy of earnings tracking and can be managed or disabled in your device settings.
Third Party | Categories of Personal Information Received |
Service Providers or EarnIn Payroll Users.
| Identifiers, such as Your full name, phone number, mailing address, and date of birth. Sensitive Personal Information, such as SSN, bank account number, bank account balances and transactions, consumer behavior (e.g., credit reports). Employment Information, such as the name and address of Your employer, compensation information, employment ID. |
Social media platforms, marketing agencies
| Identifiers, such as account ID, account name, unique user identifier, device identifier, IP address, user agent, and advertising identifiers. They also include contact information like email address and phone number, as well as online activity data such as browsing history, search history, pixels, and technical diagnostic data. Additional elements encompass preferences and account details, including language preferences, social media accounts, and user consent data, and photographs. Sensitive r Personal Information, consumer behavioral patterns and location data |
We use third party information to supplement the information We collect about You through the Services, to verify Your identity, to provide You with the Services, to enhance Our ability to serve You, and/or to offer You opportunities to use new Services or features that We believe may be of interest to You, and to find new talent to join Us. Please note, when You provide Your phone number to Us, You authorize Your wireless carrier to use or disclose information about the status of Your account and Your wireless device, if available, to EarnIn for the duration of the business relationship, to help identify You or Your wireless device, to prevent fraud, and for other reasons outlined in this Privacy Policy.
By Using Our Services, You grant EarnIn and each of the Service Providers listed below the right, power and authority to act on Your behalf to access and transmit Your Personal Information from the relevant financial institution. You agree to Your Personal Information being transferred, stored and processed by these Service Providers in accordance with the Service Provider’s terms of service and privacy policy (the links are provided below).
How Does EarnIn Use Your Personal Information?
To verify Your identity, determine Your eligibility to use the Services, and communicate with You
To provide You with the Services and for Our everyday business purposes
To detect, monitor and prevent fraud and unauthorized transactions
To improve Our Services and to notify You about changes to the EarnIn Site and Services
To enforce our Terms of Service, and any other agreements between You and EarnIn
To send You marketing materials (provided You have consented as required by law), and to offer You tailored content by giving You more relevant search results and ads
To inform You about Our advocacy program(s) and to give You the opportunity to voice Your opinion with Your local, state, and federal representatives
To conduct and report on certain analytics, benchmarking, and performance tracking through the use of anonymous, aggregated information comprised of the categories above
To conduct due diligence on Service Providers To process Your application for employment
To comply with any court order, law, or legal process, including retaining Personal Information or responding to any government or regulatory request.
For other reasons with your consent.
Does EarnIn Sell Your Personal Information?
No. EarnIn does not sell your Personal Information.
Who Does EarnIn Share Your Personal Information with and for What Purpose?
EarnIn shares your Personal Information with the following third parties,
subject to contract terms that limit their use and disclosure of Personal Information only to the purpose established in the contract between EarnIn and the third party and/or subject to compliance with legal requirements. Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes. To learn about the short code format see our
General Terms of Service.
With law enforcement and administrative authorities, when so required to comply with applicable law; to comply with rules imposed by payment networks in connection with the use of that payment method (e.g., NACHA rules); to enforce EarnIn’s contractual rights; to protect the Services against malicious or fraudulent activity and security incidents; and to respond to subpoenas from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your jurisdiction.
With an acquiring business. If EarnIn is involved in a merger, acquisition, or sale of all or a portion of its assets, or in the event of a bankruptcy or dissolution of Our business, subject to restrictions under applicable laws. You will be notified by email and/or by a prominent notice on Our Site of any change in ownership or uses of Your Personal Information, as well as any choices You may have regarding your Personal Information.
With third-party ad networks and third-party ad companies. Some of your Personal Information (device identifier, email and/or cellphone number) may be shared with companies like LiveRamp, Facebook, Google, TikTok, Apple Search Ads, or Reddit to manage Our advertising on their sites. For more information see Our
Cookie Notice.
EarnIn may aggregate and modify Personal Information in a manner that does not personally identify You or any other individual and therefore is no longer considered Personal Information. Such aggregated and anonymized data may be shared by EarnIn with third parties without restrictions. For example, EarnIn may use aggregated and anonymized data to prepare statistics, infographics and other data graphs, to train artificial intelligence models, for demographic information, for marketing and/or for research purposes.
Does EarnIn Transfer Your Personal Information Outside the United States?
The Services are controlled and operated by EarnIn from the United States and are not intended to subject Us to the laws or jurisdiction of any country or territory other than the United States. However, We may store and process Your Personal Information in any country where We have facilities or in which We engage Service Providers. By using the Services, You consent to the transfer of Your Personal information to countries outside of Your jurisdiction, which may have different data protection rules than those of Your country. We will make efforts to ensure that Your Personal Information receives an adequate level of protection in the jurisdictions in which We process it, including through appropriate written data processing terms and/or data transfer agreements.
Does EarnIn Follow Do Not Track (“DNT”) Signals?
EarnIn does not respond to DNT Signals. For more information, please see our
Cookie Notice.
Does EarnIn Recognize Global Privacy Control (GPC) Signals? We recognize and honor GPC signals as a valid request to opt out of the sale or sharing of Personal Information. While we do not sell YourPersonal Information, We provide this notice to confirm that Your GPC preferences will be respected automatically.
How Does EarnIn Protect Your Personal Information?
Your Personal Information is protected by physical, electronic, and procedural safeguards in compliance with applicable US federal and state laws and regulations. We also use computer safeguards such as firewalls and data encryption and We enforce physical access controls to Our offices and files. Please be aware We cannot guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by breach of our technical safeguards. Therefore, We urge You to take adequate precautions to protect Your Personal Information as well, including never sharing Your EarnIn and/or financial account credentials with anyone.
How Long Does EarnIn Keep Your Personal Information For?
We will keep Your Personal Information for as long as Your EarnIn account is active or as needed to provide You with Our Services, and for as long as We may be required to comply with Our legal obligations, resolve disputes, maintain appropriate business records, and enforce Our agreement(s) with You or other third parties who have contracted Us to Provide You with Our Services. Even if You request for Your information to be deleted (as applicable), laws and regulations may require Us to retain a copy of Your Personal Information in our files for a longer period. When it is no longer necessary for Us to hold Your Personal Information, We will securely destroy it in accordance with Our internal policies and applicable laws and regulations.
Does EarnIn Collect Personal Information of Children?
No. Our Services are not intended to be used by or directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 years of age. If we become aware that a child under the age of 13 has provided personal information to Us through the Services, we will endeavor to collect or verify guardian consent to process the minor child’s data or will endeavor to delete that information from our database in accordance with applicable law. Please
Contact Us if You believe We have mistakenly collected information from a child under the age of 13.
How Can You Contact EarnIn?
How Will EarnIn Keep You Informed of Any Changes to this Privacy Policy?
We may make changes to this Privacy Policy at any time. If We make changes, the updated Privacy Policy will be posted on the Site. If We make any changes to the ways in which We process Your Personal Information that could be reasonably considered material or substantial, We will make additional efforts to notify You of those changes, either by email or via a prominent notice on the Site prior to the change becoming effective. Where required by law, We will obtain Your consent or give You the opportunity to Opt-Out of such changes. Any changes will become effective on the Last Updated date specified in the Privacy Policy. This Privacy Policy does not apply to third party products or services and/or companies EarnIn does not own or control.
What Are Your Rights with Respect to Your Personal Information?
Subject to applicable law, you may make the following requests:
Right to Know. You may have the right to request that We disclose the categories and specific pieces of Personal Information We have collected about You. You also have the right to know the categories of sources from which Your Personal Information is collected, the purpose for collecting Your Personal Information, and the categories of third parties with whom We share your Personal Information. This information is already provided in this Privacy Policy.
Right to Correct Your Personal Information. If Our Site does not permit You to update or correct certain information, You can
contact Us. Note that We may keep historical information in Our backup files as permitted by law.
Right to Opt-Out of Sharing of Personal Information for Targeted Advertising Purposes. To opt out please visit our
Privacy Page and click on the blue link titled ""Do Not Share My Personal Information.” For more information see Our
Cookie Notice.
Submitting Requests
We will require you to prove your identity when making most types of requests. We may verify your identity by phone or email. Depending on your request, we will ask for information such as your name, phone number and email address registered with us, or the date of your last transaction with us. In some circumstances, you may designate an authorized agent to exercise rights on your behalf. If you are an authorized agent, you must attach a copy of a complete notarized permission stating that the agent has authorization to act on your behalf.
If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”
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