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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.
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.
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:
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.
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.
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.
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.