GDPR Rights Disclosure

Last updated November 23, 2022

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Sila Inc. (also referred to as Sila Money Inc., together with its subsidiaries and affiliates, “Sila”) maintains these GDPR Rights Disclosures (these “Disclosures”) to supplement the terms of the Website Privacy Statement at silamoney.com/legal/website-privacy-statement and the Sila Privacy Policy at silamoney.com/legal/sila-privacy-policy. These Disclosures apply to you only if you are an individual resident of the European Economic Area.

These Disclosures provide you with additional information about how Sila collects, uses, discloses, and otherwise processes your personal information (or “Personal Data,” as defined below) as a European Economic Area resident within the scope of the General Data Protection Regulation (“GDPR”) in relation to your use of the Website (as defined by Website Visitor Agreement at silamoney.com/legal/website-visitor-agreement) or the Services (as defined by the Sila Terms of Service at silamoney.com/legal/terms-of-service).

If you have any questions about these Disclosures, you may contact Sila at privacy@silamoney.com.

Sila reserves the right to change the provisions of this GDPR Rights Disclosure at any time and without providing notice to you. The date of the most recent version of these Disclosures will appear at the top of this page. Accordingly, you should visit this Disclosures page periodically to review its provisions and note any changes that may affect you.

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1. What is Personal Data?

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Under the GDPR and as used in these Disclosures, “Personal Data” means information related to an identified or identifiable natural person who is identified or identifiable, directly or indirectly by means of reference to any particular identifier like name, identification number, location data, a web-based identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. Personal Information does not include any of the following: (i) a company registration number or generic company email address; (ii) aggregated or anonymized data that is not capable of being associated with you; and (iii) certain information that Sila, as a “service provider,” may process solely on behalf of its business customers. Sila may be responsible under the GDPR as the “controller” of your Personal Data.

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2. What Personal Data is Collected?

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Sila may collect from you or otherwise gather certain Personal Data about you in connection with your or your company’s use of the Website or the Services. Please review the Website Privacy Statement and Sila Privacy Policy, as applicable, to learn more about the information Sila collects, including your Personal Data. To learn how to restrict the information Sila collects from your use of the Website, please refer to the Website Privacy Statement at silamoney.com/legal/website-privacy-statement. In the last 12 months, Sila has collected the following categories of Personal Data:

1. Individual Identifiers. Names, street addresses, email addresses, and other similar information that Sila may directly collect from you or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
2. ‍Employment Application or Recruitment Records. Only to the limited extent you have submitted an employment application to Sila or participated in Sila’s recruitment process, special categories of information under the GDPR, such as your race and ethnic origin, sexual orientation, or biometric data, which is used by Sila only with your express consent and only to assist Sila with monitoring its commitments to diversity, equity, and inclusion.
3. ‍Professional Records. Business and employment records or other professional information, such as your current occupation, job title, employer, and industry, which Sila may directly collect from you or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
4. ‍Other Personal Data. Your Personal Data that may be identified as part of service requests to Sila or social media content and other public communications, which Sila may gather from public sources, directly collect from you, or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
5. ‍Cookies and Other Network Information. Information generated from your use of the Website (pursuant to your authorized preferences) on browser and internet use, such as analytics data on your Website activity, which Sila may collect from your browser or device through use of cookies.
6. ‍Geolocation Data. Your general geographic location based on log data, which Sila may collect from your browser or device.
7. ‍Sensory Information. Notes, recordings (to which you have consented), or other data from phone calls, remote conferences, or virtual meetings, or any audio files, images, or video footage you choose to provide, any of which Sila may directly collect from you.

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3. How is Personal Data Used?

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Under the GDPR, Sila may only use your Personal Data if it has a proper reason for using your Personal Data. Sila may use the Personal Information identified above as necessary in pursuit of the following business purposes: (i) providing or managing your access to the Services and any Website services, if and as applicable; (ii) auditing the transactions performed using the Services and managing Sila’s relationship with your or your company’s clients or platform users; (iii) communicating with you, such as by email, phone, push notifications, social media, or the Website; (iv) operating, evaluating, securing, enhancing, and improving Sila’s business, the Services, any Website services, and any other related products, services, or features; (v) recognizing you and remembering your information when you return to the Website or when you access or use the Services; (vi) curating and managing marketing campaigns and related business activities; (vii) debugging intended functionality of the Website or the Services; (viii) informing tests, training, research, analysis, and product development that supports the Website or the Services; (ix) preventing, detecting, and responding to system breaches or other security events; (x) defending, protecting, or enforcing Sila’s rights under any applicable agreements, terms, or conditions to which you or your company may have agreed; (xi) complying with legal process and any applicable legal or regulatory requirements; and (xii) fulfilling rights, enforcing obligations, and performing permitted activities within the scope of any applicable agreements, terms, or conditions Sila may have with you or your company.

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4. When is Personal Data Disclosed?

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In the last 12 months, Sila has not sold any Personal Data about you but may have disclosed Personal Data of any of the above categories to Sila’s partners or suppliers for a business purpose. While Sila never “sells” your Personal Data, Sila may occasionally disclose your Personal Data to certain of its partners or suppliers for business purposes as necessary to (i) assess and improve the Website or the Services, (ii) improving and measuring the success of advertising or marketing campaigns; (iii) detect, stop, and report fraudulent activities; or (iv) promote the products or services of Sila’s partners or suppliers and their associates in accordance with the U.S. Gramm-Leach-Bliley Act. For more information on Sila’s disclosure practices as applied to information Sila obtains in connect with your use of the Website, please refer to the Website Privacy Statement, available at silamoney.com/legal/website-privacy-statement. For more information on Sila’s disclosure practices as applied to information Sila obtains in connection with your use of the Services, please refer to the Sila Privacy Policy at silamoney.com/legal/sila-privacy-policy.

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5. What Are Your Rights?

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As a resident of the European Economic Area (which, as of the revision date of this Policy includes Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain or Sweden), you may be eligible to exercise any of the following rights in relation to the Personal Data that Sila collects, subject to certain limitations under applicable law. Please direct all requests to exercise rights under these Disclosures to Sila in writing by emailing privacy@silamoney.com with the subject “EEA/GDPR Rights Request,” and identify your country of domicile. In each instance, Sila may need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in Sila’s systems (which may necessitate requesting additional Personal Information from you). Sila may in certain circumstances deny your request, particularly if Sila is unable to verify your identity.

1. The Right to Access. You have the right to request from Sila copies of any and all of your Personal Data that Sila has in its position, including the specific information or data points Sila has collected from or about you and the business or commercial purposes for which Sila collected and used your Personal Data or, if applicable, sold your Personal Data. To exercise your right to access, please identify in your request to Sila any specific categories of information you want to know about.
2. ‍The Right to Rectification. You have the right to require Sila to correct any mistakes or discrepancies in your Personal Data held by Sila. To exercise your right to rectification, when possible, please update your Personal Data at the source of that information, such as through the Website or applicable customer platform application. To exercise your right to rectification, please identify in your request to Sila the specific pieces of Personal Data you wish to correct and their corresponding corrections.
3. ‍The Right to be Forgotten. In some circumstances, you may have the right to request deletion or restrict processing of Personal Data that we have collected from you, such as if certain information is inaccurate or incomplete or is otherwise not used in accordance with or as permitted under applicable law or regulation. The right to be forgotten is not available when Sila is providing or has provided Services to you or your company and Sila is required by law or internal policy to retain your Personal Information. To exercise your right to be forgotten, please identify in your request to Sila what Personal Data you would like Sila to delete or restrict processing and why the GDPR affords you the right in relation to the identified Personal Data for Sila’s particular use.
4. ‍The Right to Data Portability. You have the right to request that Sila provide you with your Personal Data in a reasonably establishable format that allows you to more easily reuse your information in another context, and to transmit this data to another data controller of your choice. To exercise your right to be forgotten, please identify in your request to Sila what Personal Data and in what format you would like Sila to export and to whom, whether you or another data controller, you would like it to be exported.
5. ‍The Right to Object. You have the right to object to Sila processing your Personal Data for direct marketing purposes, including profiling. In certain other, limited circumstances, you have the right to object to Sila’s continued processing of your Personal Data as part of process carried out pursuant to Sila’s other legitimate business purposes or commercial interests. To exercise your right to object, please identify in your request to Sila what processing of Personal Data you would like Sila to discontinue and why the GDPR affords you the right in relation to the identified Personal Data for Sila’s particular use.
6. ‍The Right to Opt Out of Automated Decision Making. You have the right to not be subject to a decision based solely on automated individual processing, including profiling, if it produces legal effects concerning you or significantly and directly affecting you. Sila does not, however, base any kind of determinations in relation to persons in the European Economic Area solely on automated decision-making processes with any legal effect.

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6. How to File a GDPR Complaint?

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While Sila hopes to resolve any questions, concerns, or requests to exercise rights concerning Sila’s collection and use of your Personal Data (please email privacy@silamoney.com), the GDPR affords you the right to file a complaint with a supervisory authority of competent jurisdiction in the particular European Economic Area state where you work or reside, or where any alleged infringement of your rights under the GDPR occurred.