Website Privacy Statement

Last updated March 1, 2023

Welcome to Sila! Thank you for visiting us at silamoney.com (the “Website”, as defined in the Website Visitor Agreement to which you agreed). Sila Inc. (also known as Sila Money Inc., together with its subsidiaries and affiliates, “Sila”) maintains this Website Privacy Statement (this “Statement”) to demonstrate its organizational commitment to privacy and security. The Website Visitor Agreement is available at silamoney.com/legal/website-visitor-agreement.

Sila gathers certain types of information from Website users and believes it is important that you fully understand what information Sila gathers and how it obtains, uses, shares, and manages that information, so please read this Statement carefully. Accordingly, Sila is providing this Statement to you to disclose what information Sila gathers as part of the Website and how that information is obtained, used, shared, and managed. This Statement is only applicable to information gathered by Sila by means of the Website. This Statement is not applicable to information that Sila may obtain through any of its other business activities or from other sources.

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

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

Attention California Residents: See Sila’s California Consumer Privacy Act (“CCPA”) Rights Disclosures incorporated as part of this Statement at silamoney.com/legal/ccpa-rights-disclosure for additional disclosures about your rights and Sila’s collection and use of your personal information under the CCPA, and for information on submitting CCPA requests.

Attention European Economic Area Residents: See Sila’s General Data Protection Regulation (“GDPR”) Rights Disclosures incorporated as part of this Statement at silamoney.com/legal/gdpr-rights-disclosure for additional disclosures about your rights and Sila’s collection and use of your personal information under the GDPR, and for information on filing GDPR complaints.

1. Your Personally Identifiable Information

1. Personal Information Collected. Sila collects information that you voluntarily provide via the Website using one or more devices to receive products, services, or related information that you may request from Sila or its partners or suppliers. The information you submit may include your name, company information, street address, email address, phone number, and, in some cases, social security number or other tax ID number. Sila considers this information to be your personally identifiable information (your “PII”). Unless Sila has your complete street address, Sila does not consider your city, state, ZIP code, or general geographic location to be your PII. Sila also collects information about the devices you use to access the Website. Sila does not consider this information to be your PII, but certain device information of California residents may be considered "Personal Information" under the California Consumer Privacy Act (“CCPA”). If you are a California resident, please review Sila’s CCPA Rights Disclosures, available at silamoney.com/legal/ccpa-rights-disclosure.
2. ‍Use of Your Personal Information. Your PII may be shared between Sila and its partners or suppliers and may also be disclosed to other entities based on any separate requests you may make for Sila to provide other products and services to you. When you provide PII like your phone number or email address, such as when submitting a “Contact Us” form or registering for Sila’s customer console at console.silamoney.com (the “Console”), Sila may use it to reach you to fulfill your request, answer your questions, and obtain or associate additional information about you and your company. Sila may use whatever information it may have or know about you, including your PII, to customize or enhance your experience on the Website (including the potential display of advertisements or marketing material), provide you with information on or access to Sila’s or its partners and suppliers’ products or services, or to communicate with you about those products or services. Sila may use this information to optimize the manner in which these products or services are operated and managed. Sila may also aggregate and use this information for purposes of producing reports and analytics, both internally and when demonstrating the effectiveness of Sila’s products and services to its investors, partners, or suppliers. Sila does not sell your PII to third parties, and Sila does not otherwise make commercial use out of your PII other than for business purposes directly related to supporting the provision of products or services to you or as otherwise specified above.
3. ‍Disclosure of Your Personal Information. Sila may disclose whatever information it may have or know about you, including your PII, without first providing you with additional notice or obtaining your consent, to (i) third-party service providers that provide advice, products, or services to Sila, or that help Sila improve its products, services, or information or understanding their value to Website users or Sila’s partners or suppliers; (ii) a potential acquirer in connection with any merger, acquisition, or sale of at least substantially all Sila’s business assets; (iii) third parties to whom disclosure of your information is deemed to be required by law, regulation, or legal process, or that is or may be reasonably necessary to enforce or take appropriate action under the Website Visitor Agreement, available at silamoney.com/legal/website-visitor-agreement; or (iv) other third parties when reasonably necessary to protect the rights, property, or safety of Sila, its partners and suppliers, the Website, or other Website visitors. Sila may also disclose your PII to social media companies in an encoded (or “hashed”) format that can only be recognized if you have an account on those companies’ platforms. Sila only discloses your PII to those of its partners, suppliers, or other service providers with appropriate controls for handling and protecting your PII. Sila also imposes contractual obligations on service providers to ensure they only use your PII in accordance with applicable law as necessary to provide services to Sila or you.
4. ‍Your Geolocation Information. When you access the Website, Sila may use cookies to discern your general geolocation information from the IP address associated with your computer or mobile device. Sila uses this information to support general analytics and marketing functions, and to help discern your location within or connection to any jurisdiction that is the subject of applicable sanctions or with which Sila is prohibited from doing business. For more information about prohibited jurisdictions and other restrictions to use of Sila’s products or services, please visit Sila’s Acceptable Use Policy, available at silamoney.com/legal/acceptable-use-policy. You may stop Sila’s collection of your geolocation information by rejecting analytics cookies using the Cookie Consent Manager, provided this action may be disruptive to Website functionality and performance. As described above, unless Sila has your complete street address, Sila does not consider your city, state, ZIP code, or general geographic location to be your PII.
5. ‍Your Responses to Surveys and Marketing Emails. Sila may from time to time administer or work with a third party to administer surveys to its customers and Website users to help Sila better target its ideal online audience and improve Sila’s products or services, as well as the products or services of its partners and suppliers. Additionally, if you are receiving marketing emails from the Website or other communications from Sila requesting information from you in connection with your Website use, then you may opt out of receiving these kinds of communications by selecting “unsubscribe” at the footer of the emails or requesting to opt out in writing by delivering an email to Sila at privacy@silamoney.com.
6. ‍Your Use of Community Services. The Website may provide you with a variety of means for communicating with Sila, its partners or suppliers, and other Website users, such as when using Sila’s community forum at community.silamoney.com (the  “Community”) or adding or submitting information or other content through the Website or interacting with content submitted by other Website users. For more information on the Community and other Website services, including warnings and recommendations regarding PII disclosure and communications practices, please visit the Website Visitor Agreement, available at silamoney.com/website-visitor-agreement, which supplements this Statement.
7. ‍Where is Your Information Held? The information handled by Sila, including your PII, is encrypted in transit and in storage. This information may be held at Sila’s offices and the offices of Sila’s partners or suppliers, or in Sila’s encrypted cloud-based database hosted by Amazon Web Services. Sila and some of the above third parties are based outside the European Economic Area. If you are a resident of the European Economic Area, please see Sila’s General Data Protection Regulation (“GDPR”) Rights Disclosures at silamoney.com/legal/gdpr-rights-disclosure.
8. ‍How Long is Your Information Kept? If you register an account on the Console, the Community, or other Website service, then Sila will retain your PII for at least as long as you have the account. If you or your company separately sign up for any of Sila’s services, then Sila will retain your PII for at least as long as Sila is providing services to you or your company. If you close all your accounts or lose access to Sila’s services, then Sila will continue to hold records of your PII only for as long as necessary to comply with applicable laws or regulations governing records retention. Sila may additionally hold your PII as necessary to adequately respond to any questions, complaints, or claims made by you, by your company, or on your behalf, and to show that Sila treated you fairly. Sila will not keep your PII for longer than necessary for the purposes set forth in this Statement and, at the end of the applicable retention period, will delete or anonymize your information. If you voluntarily publish or submit any of your PII or other information on any public space on the Website, such as Community, then you do so at your own risk, and your information may persist online indefinitely if you do not remove that information or specifically ask Sila, in writing, to remove it. If Sila is separately providing services to you or your company, then your information is additionally subject to Sila’s Privacy Policy, available at silamoney.com/legal/sila-privacy-policy, and different records retention periods will apply to various types of PII and other information, as described in more detail by the Privacy Policy.

2. Information Collected Through Cookies

1. What are Cookies? To ensure optimal performance and support your ability to use the Website and any services accessible through the Website as intended, Sila and its suppliers or other third parties install and use cookies. Cookies are small text files generated when you access the Website and used to collect your internet browsing information. All cookies that Sila uses are safe for your computer and only process the information stored on your browser. These cookies cannot execute code, do not contain malware or viruses, and cannot be used to access content stored on your computer. Sila uses four different types of cookies on the Website: (i) cookies that are strictly necessary for Website use (“essential cookies”); (ii) cookies that remember your settings (“functional cookies”); (iii) cookies that monitor your website use (“analytics cookies”); and (iv) cookies that assist with marketing and business communications (“marketing cookies”), the details of each of which are listed below, from Section 2.(b) through 2(e), respectively.
2. ‍Essential Cookies. Essential cookies are cookies needed to ensure you can access the Website and browse securely. You are unable to opt out of these cookies because Website services require them to function. Essential cookies help protect Sila from fraudulent use of the Website or related services, verify that anyone using your registered account on the Website or any of its components is indeed you, and protect your data from unauthorized access and use. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:
      • Google Analytics by Google Ireland Limited (Ireland), which uses essential cookies to record unique visitor views of the Website’s Visitor Agreement and Privacy Statement consent banner. Learn more about Google’s cookies and privacy policies at policies.google.com/technologies/cookies.
      • Website chat support from Intercom, Inc. (California, U.S.), which uses essential cookies to capture your name, email, company, and IP address as necessary to protect your registered account on the Console from unauthorized access, and to monitor whether you are logged into the Console at any given time. Learn more about Intercom’s cookies and privacy policies at intercom.com/legal/terms-and-policies.
3. ‍Functional Cookies. Functional cookies are cookies that gather data necessary to provide you with an interactive user experience. Functional cookies allow Sila to adapt the Website and Website services to your preferences, such as language and other interactive functionality. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:
      • LeadFeeder by Liidio Oy (Finland), which uses functional cookies to track your behaviors when using the Website, including the Website pages you have viewed, time spent on the Website, and link referral source used to access the Website. Learn more about Liidio Oy’s cookies and privacy policies at leadfeeder.com/privacy/.
      • Website chat support from Intercom, Inc. (California, U.S.), which uses functional cookies to capture the details and contents of your chat history to help facilitate continued user support on the Website and operate Website services. Learn more about Intercom’s cookies and privacy policies at intercom.com/legal/terms-and-policies.
      • Web-based forms from Typeform SL (Spain), which uses functional cookies to retain for subsequent Website visits the contents of your entries to the “Contact Us” sales and support contact form, which may include your name, company, email address, website, phone number, or other personal or business information. Learn more about Typeform’s cookies and privacy policies at admin.typeform.com/to/dwk6gt.
4. ‍Analytics Cookies. Analytics cookies are cookies that when used together track, monitor, and analyze how you browse and interact with the Website and any Website services. Analytics cookies reveal trends in Website usage and allow Sila to customize the Website user experience for you. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:
      • Google Analytics by Google Ireland Limited (Ireland), which uses analytics cookies to create unique visitor IDs to capture the pages on the Website you visit, as well as other websites you visit, as well as the time spent on each page or website. Learn more about Google’s cookies and privacy policies at policies.google.com/technologies/cookies.
      • LeadFeeder by Liidio Oy (Finland), which uses analytics cookies to record your IP address, thereby identifying your geographic location and tracking aggregated data about your company’s Website use. Learn more about Liidio Oy’s cookies and privacy policies at leadfeeder.com/privacy.
5. ‍Marketing Cookies. Marketing cookies are cookies that track, monitor, and analyze how you browse and interact with the Website and any Website services specifically as necessary to help Sila deploy, manage, and improve its advertising and marketing strategies. Analytics cookies allow Sila to better understand Website user behavior, develop its audience, and improve business communications and marketing strategies. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:
      • Email and social marketing services platform from ActiveCampaign, LLC (Illinois, U.S.), which uses marketing cookies to identify whether you were referred to the Website by Sila’s digital newsletters or other marketing or business communications, and then monitors your activity on the Website. Learn more about ActiveCampaign’s cookies and privacy policies at activecampaign.com/legal.
      • Google Search Console by Google Ireland Limited (Ireland), which uses marketing cookies to track data related to your use of Google Search, including any source advertising or marketing campaigns. Learn more about Google’s cookies and privacy policies at policies.google.com/technologies/cookies.
      • “Heatmaps” and user behavior analytics services from Hotjar Ltd. (Malta), which uses marketing cookies to collect data about where you click, move, and scroll on the Website to identify errors and bugs, as well as general trends, helping to improve both Website performance and content. Learn more about Hotjar’s cookies and privacy policies at hotjar.com/legal.
      • Instant video chat widget from ServiceBell Inc. (Delaware, U.S.), which monitors your Website use session activity and captures your geographic location from your IP address to provide you with adequate sales support. Learn more about ServiceBell’s cookies and privacy policies at servicebell.com/privacy.
      • Media Conversion Tracker from Slashdot Media, LLC (California, U.S.), which tracks incoming and outgoing Website traffic for conversions or references from Sila’s profile on Slashbot (slashdot.org/software/p/sila), a technology industry social news website and blog. Learn more about Slashdot Media’s cookies and privacy policies at slashdotmedia.com/privacy-statement.

3. How You Can Control Cookies

1. How Can You Manage Your Consent to Cookies? You have the right to accept or reject cookies when you use the Website. You may exercise your cookie rights by setting your preferences in the Cookie Consent Manager, which can also be found linked on the notification banner on the Website. While you cannot reject essential cookies because they are necessary to provide you with access to the Website, you may select those of the other categories of cookies (i.e., functional cookies, analytics cookies, and marketing cookies) that you wish to accept or reject. You may still use the Website if you choose to reject any or all these categories of cookies, but access to certain Website services or functionality may be restricted.
2. ‍How Can You Block or Delete Cookies? If you would like to reject cookies without adjusting your preferences in the Cookie Consent Manager each time you visit the Website, or if you would like to remove the cookies to which you previously consented, then you can modify your browser settings to block or delete cookies. The means by which you may refuse cookies in your web browser settings may vary depending on the browser you use. Please go to your browser’s help menu for more information.

4. Information Collected Through Other Technologies

1. Web Beacons. From time to time, the Website may use other tracking technologies similar to cookies called “web beacons” (or “tracking pixels” or “clear gifs”) to monitor traffic patterns of Website users from one page to another and deliver or communicate with cookies. Web beacons are small graphics that display a unique identifier that allow Sila to recognize when someone has visited the Website or opened an email from Sila. Web beacons help Sila improve Website performance and understand whether any particular visit to the Website is directed from certain external sources, like an online advertisement displayed on a third-party platform application or website or an email marketing campaign. Web beacons are largely reliant on cookies to function properly, so blocking or rejecting cookies may impair web beacon functionality and, in turn, Website performance.
2. ‍Local Shared Objects. From time to time, the Website may also use “Flash cookies” (or “local shared objects” or “LSOs”) to collect and store information about your use of the Website and Sila’s services, and to prevent fraud, support other Website operations, and more. Flash cookies are stored locally on your computer and interact with your Adobe Flash Player, which is typically installed as a widget or add-on to your web browser. The Website uses Flash cookies to support the functionality of some Flash applications that may be used in connection with the Website or Sila’s services or other online content. If you do not want the Website to use Flash cookies on your computer, then you can adjust your Flash Player settings to block Flash cookie storage. You can also use your Flash Player’s global storage settings panel to prevent Flash cookies from being placed on your computer without your explicit opt-in, or to Block them unless being delivered by a website or webpage you are accessing at any given time. Learn more about your Flash Player settings manager from Adobe at macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
3. ‍Targeted Advertising. Third-party companies may use cookies, web beacons, or other technologies in connection with your use of your computer or mobile device to send or display advertisements to you via the Website. These companies may collect information about your visits to the Website and other websites or webpages as necessary to provide relevant advertising materials about goods or services in which you may be interested, and to measure the effectiveness of the advertisements. The information collected by these companies does not enable either those companies or Sila to identify your name, contact information, or other personally identifiable information unless you choose to provide these details.

5. Children’s Privacy

The Website is directed at a general audience but not at children under the age of 16. Sila does not knowingly collect or solicit personal information from any person under the age of 16 or knowingly allow them to use Sila’s products and services. If you are under 16, please do not visit the Website or use any of Sila’s products and services. If Sila obtains actual knowledge that the personal information of a child under age 16 was or is being collected through the Website, then Sila will delete that information as quickly as possible. If you believe the Website might have collected any information from or about a child under 16, then please contact Sila by privacy@silamoney.com.