Date Updated: January 12, 2024
At First Dollar, Inc. (“First Dollar”, “we”, or “us”), we take our responsibility to safeguard your personal information extremely seriously. This Privacy Policy explains how we acquire, use, and transmit your Personal Information (as defined below). We deliver our product through our website located at FirstDollar.com, our mobile application (“Application”), and our widgets (collectively, the “Site”) and online services, including the establishment of a savings account to hold funds, the option to receive a debit card to spend funds on qualified expenses, and the ability to establish an investment account (all of the foregoing collectively the (“Services”). We may update this Privacy Policy from time to time. We will notify you by posting a notification on the Site and through the Services and/or by sending you an email about the update(s). You can always find the most recent version here at FirstDollar.com/legal. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.
I. Personal Information That We Collect
First Dollar collects information about you as a user to provide you with the Services. In general, we receive and collect all information you provide via the Services, including through the Site input fields (including advertisements), phone, email (including email campaigns), web chat, or in other such ways. We collect information about you in a range of forms, including Personal Information. “Personal Information” means data that allows someone to identify or relates to you, including, for example, your name, telephone number, and Internet Protocol (“IP”) (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), mailing and email addresses, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. For purposes of this Privacy Policy, Personal Information also includes Non-Public Information, as that term is defined in the Gramm-Leach-Bliley Act of 1999 (“NPI”) and Protected Health Information, as that term is defined in the Health Insurance Portability and Accountability Act of 1996 (“PHI”). “Anonymous Data” means Personal Information that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated from the aggregate data and identified as originating from you. We collect Personal Information and Anonymous Data, as described below.
You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned above or for tracking your preferences, subscribing to a newsletter, or initiating other such actions.
A. Information from the User
When you create an account to log in to our network (“Account”), you may be prompted to provide some or all of the following information in connection with our provision of the Services:
Name
Physical Address
Mailing Address
Social Security Number
Employer Identification Number (EIN)
Date of Birth
Email Address
Phone Number
Gender
Health plan information
Beneficiary Information
Dependent information
Receipts for medical expenses, which may contain PHI
Existing Health Savings Account information (for rollover purposes)
HSA-related investment account information
Personal bank account information
If you use our Services on your mobile device, including through our Application, we may collect your phone number and the unique device ID number.
If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can deactivate GPS on your mobile device.
Our Site may let you store preferences including how your content is displayed, your location, safe search settings, and favorite widgets. We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.
When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
We retain information on your behalf, such as files and messages that you store using your Account.
If you provide us with feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
If you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
If you participate in one of our surveys, we may collect additional profile information.
We may also collect Personal Information at other points on our Site where it states that Personal Information is being collected.
B. Information Collected Automatically
Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, IP address, domain name, and/or a date/time stamp for your visit.
Log Files. As is typical of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Information.
We sometimes use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services.
Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of website users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in website pages. Pixel Tags also allow us to send email messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Information.
Collection of Data by Advertisers. We may also use third parties to serve ads on the Site. Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, and the browser you use to visit our Site (but not your name, physical address, email address or telephone number). They do this by using Cookies, Pixel Tags, or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Site and the other websites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: aboutads.info/choices or www.networkadvertising.org.
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our Site.
Mobile Services. We may also collect non-Personal Information from your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, and how you use the Site and Services. We may also collect information about the type of device you use. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
Browsing-Session Tracking. We may track your browsing activities on our Site and Application in other ways, including by recording, the actions you take, the time you spend, and the features that you utilize. This information may be used to create Anonymous Data to help us better understand customer preferences and needs. Except to the extent we utilize third party services to assist in the collection of this data, we do not share this information with any other party.
Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Site or use our Services. This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Site and Services, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at legal@firstdollar.com. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com. If you don’t want to take advantage of these services, you may be able to opt out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/.
C. Information Collected from Third Party Companies
We may receive Personal Information and/or Anonymous Data about you from companies that help us verify your identity, comply with legal obligations, and/or provide our Services. We may also receive Personal Information and/or Anonymous Data about you from co-branded or private-labeled websites or companies that offer their products and/or services on our Site or through our Services. Additionally, we may receive certain publicly available information about you from companies we partner with to provide us market research. These third party companies may supply us with Personal Information. We may add this information to the information we have already collected from you via our Site or Services in order to improve or Site and/or the Services we provide.
We may offer features and/or functionality that require you to enter other Personal Information. In these cases, we will use the information, including sharing the information with third parties as may be necessary, to provide the features and/or functionality described.
D. Information Collected from Employers, Payroll Companies, or Health Plans
If your Account was established by your employer or your health plan, they may have requested that we set up a communication channel whereby you can log into First Dollar’s portal (known as single sign on) or access your Account information through their site without entering your user name and password again. Your employer or health plan may have also contracted with another vendor that provides additional services, such as personal health care costs management or online benefits enrollment, that allows you to log into First Dollar’s portal or access your Account through that vendor’s website, also without entering your First Dollar username and password. When you use those websites to sign into First Dollar’s portal or access your Account, you are authorizing First Dollar’s system to pass on certain information, such as your account balances, to those systems.
E. Information Collected from Banks and Financial Institutions
We collect information from banks and/or financial institutions in several different cases.
If you had previously established an account through another provider with a bank or financial institution, we may receive information pertaining to your account, deposit and withdrawal history, and financial transactions.
In the establishment and ongoing maintenance of your Account with First Dollar, we will receive information from our banking and financial institution partners related to your Account in order to provide the Services.
You may receive separate terms and conditions from our partner financial institutions, which will also describe their processing of your personal information connected with the use of your Account.
If you establish an investment account through the Services, we will transmit and receive information between First Dollar and the investment institution to provide you with the Service.
You may elect to receive and use a debit card to facilitate qualified purchases from your Account. In this case, information will be shared between the financial institution, the card issuer, the payment processor, and First Dollar to facilitate the provision of the Service. The terms and privacy policy from the financial institution will provide more information on this arrangement.
F. Location Information
When you use our Site, the Application, and Services, we may collect and process location information. If you do not want this information collected by us, you can disable location services on your phone.
II. Processing of Personal Information
We need certain Personal Information in order to provide you with access to the Site and/or the Services. We will process your Personal Information in accordance with applicable data protection and privacy laws. If you registered with us, you will have been asked to check a tick box indicating your agreement to provide this data in order to access our Services and view our content. This consent provides us with the legal basis we require under applicable law to process your Personal Information. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your Personal Information in line with this policy, please do not use our Site or Services.
A. Use of Your Personal Information
We use and retain your Personal Information in order to provide products and the Service and may, from time to time, provide such information to nonaffiliated third party service providers to perform services for or functions on behalf of us, to effect, administer, or enforce transactions authorized by you, including:
To detect, analyze, and prevent security incidents.
To audit our Site’s performance.
To identify, debug, and repair any errors that impair existing intended functionality.
In order to deliver the Services to you, we will also use your information:
To verify your identity, open and administer your Accounts, and provide other financial services under the USA PATRIOT Act;
To link accounts you provide us to facilitate the movement of funds for savings, investment accounts, and payments, as directed by you;
To communicate with you about your Account(s) and the Services;
To make payments to medical service providers;
To provide you with any health insurance information, if applicable;
To help us protect you and us from financial loss;
To prepare account statements; and
To prepare annual tax reporting information, if applicable.
In addition, we will collect and store the following:
Names and other identifying information of the dependents that are covered by your Account;
Names and other identifying information of people authorized by you to use your Account;
Names and other identifying information of people authorized by you to access your Account; and
Transactions with us such as your Account balance, fees, payments, withdrawals, deposits/contributions, and the identity of persons to whom you make payments, including health care providers.
B. User Testimonials and Feedback
We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. If we publish this content, we may identify our users by their first and last initial and may also indicate their home city with the user’s consent. We may share your feedback with your first name and last initial only. If you make any comments on a blog or forum associated with our Site, you should be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to submit in these blogs and forums.
C. Anonymous Data
We may create Anonymous Data records from Personal Information that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated from the aggregate data and identified as originating from you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties, including partners, sponsors and advertisers, in our sole discretion. We may also use such Anonymous Data for research purposes
D. Financial Institution Data
If you enable certain features, First Dollar uses Plaid Technologies, Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant First Dollar and Plaid the right, power, and authority to act on your behalf to access and transmit your Personal Information and financial information from the relevant financial institution. You agree to your Personal Information and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy: https://plaid.com/legal
III. How We Share Your Personal Information
We disclose your Personal Information as described below and as described elsewhere in this Privacy Policy.
A. Third Parties Designated by You
When you use the Services, the Personal Information you provide will be shared with third parties that you or your employer designate to receive such information. Depending on the type of access you or your employer grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by contacting us at support@firstdollar.com calling us at (844) 204-4244. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.
B. Employers
We will share your Personal Information with your employer solely for the purpose of providing the Services.
C. Third Party Service Providers
We may share your Personal Information with third party service providers, including reputable reference sources or reporting agencies, to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; for risk management and to maximize the accuracy of your information; and/or to provide other services to First Dollar. These third party service providers are required not to use your Personal Information other than to provide the services requested by First Dollar.
D. Affiliates
We may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
E. Corporate Restructuring
We may share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
F. Disclosure to Third Party Companies
We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Information that we collect from its customers. As a result, we may disclose your Personal Information to a Third Party Company partner involved in the provision of our Services; however, we will not disclose your Personal Information to any unaffiliated Third Party Company for the unaffiliated Third Party Company’s own direct marketing purposes. The privacy policies of these Third Party Companies may apply to the use and disclosure of your Personal Information that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of Third Party Companies, you should read and understand their privacy policies.
G. Other Disclosures
Regardless of any choices you make regarding your Personal Information (as described below), First Dollar may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation or obligation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on First Dollar; (c) to protect or defend the rights or property of First Dollar or users of the Site or Services; (d) to operate our business and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
H. Third Party Websites
Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Information or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, services, or websites.
I. No Sales
First Dollar does not engage in the sale of Personal Information. We have not engaged in the sale of personal information in the past 12 months and do not anticipate doing so moving forward.
IV. Exercising Your Rights
To exercise any of rights set forth below, you may contact First Dollar through any of the following means:
Email: legal@firstdollar.com
Telephone: 1-844-204-4244
Postal: Trustee Operations, 25 Air Park Drive, Suite 100 London, KY 40744
A. Right of Access and Updating Your Information
You can access your account through the Site and view and update your personal information. Users may make changes to their Personal Information through their Accounts. To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and request details about how we process it, (ii) request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, (iii) request that we update or correct inaccuracies in that information, (iv) object to our use of your personal information, (v) ask us to block or delete your personal information from our database, and (vi) request to download the information you have shared on the Services. For Personal Information that cannot be changed via your Account, or if you have questions about what Personal Information First Dollar holds about you, you can contact us at support@firstdollar.com or through any of the other methods described above. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
B. Right to Deletion
You may request deletion of your personal information. We may retain an archived copy of your records as required by law, to continue to provide you with the Services, or for other legitimate business purposes. If you completely delete all of your Personal Information, then your Account may become deactivated.
C. Right to Non-Discrimination
First Dollar will never discriminate against you for exercising any of the above-described rights.
D. Other Choices Regarding Information
In addition to the above rights, you have the following choices regarding the use of information on our Service:
Email Communications. We will periodically send you free newsletters and emails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us, and you will have the opportunity to “opt out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information above). Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
V. About the Services
A. No Users Under Age 13
The Services are not intended for children. We do not intentionally gather Personal Information from visitors who are under the age of 13. If a child under 13 submits Personal Information to First Dollar and we learn that the Personal Information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at support@firstdollar.com or through any of the other methods described above.
B. Users Outside the United States
The Site and Services allow you to manage accounts established under and governed by U.S. tax law. First Dollar makes no claim that the Site and Services are appropriate or lawful for use or access outside the United States. If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Site and Services. In addition, your Personal Information may be stored or processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.
C. Security of Personal Information and Bank Information
We have developed policies and procedures to keep your Personal Information confidential and secure. We restrict access to those employees and other persons who must use that information to provide services on our behalf. We maintain physical, electronic, and procedural safeguards, in compliance with applicable laws, regulations, and industry standards, to protect the confidentiality of the Personal Information we obtain. We require our service providers to maintain the same level of confidentiality and security that we do. We continually update and improve our security standards and procedures to help protect against anyone gaining unauthorized access to your Personal Information and to prevent fraud.
D. Your California Privacy Rights
California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at support@firstdollar.com or through any of the other methods described above.
E. Changes to This Privacy Policy
This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Information, we will notify you by prominently posting notice of the changes on our Site and in some cases by sending you an email to the last email address you provided to us. These changes will be effective immediately for new users of our Service, and details about when the changes take effect for existing users will be included in the communication about the changes. Continued use of our Site or Service following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.