Last updated: October 2024
This is the Privacy Policy (“Privacy Policy“) that governs how we, DailyPay, Inc. and DailyPay UK Holdings, Ltd (collectively “DailyPay”, “we”, “our”, or “us”), use personal information that we collect, receive and store about individuals in connection with the use of our On-Demand Pay (“ODP”) websites, mobile apps, and features, programs and partnerships which we offer in connection with the DailyPay ODP platform in the United Kingdom (which we offer in conjunction Level Financial Technology Limited ("Level")), and any other offerings for which another privacy policy does not govern (collectively, the “Services”). We act as a controller, joint controller, or processor of your personal information with Level in relation to the Services. You may access Level's privacy policy here to understand how they use your personal data in relation to the Services. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our information practices and the choices you can make about the way your personal information is collected, used, and shared in connection with our Services.
Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use our Services.
Hi, We’re DailyPay!
1.0 About DailyPay. DailyPay is a leading fintech provider that enables employees to harness the power of their pay and provides innovative financial products and solutions to consumers.
Personal Information Collection, Use, Disclosure and Anonymization
2.0 Information Collected. We, Level, our service providers, and our third-party non-affiliates receive and/or collect personal information from or about you in the following ways (we also provide examples of how we may use the data):
2.1 We collect personal information from you, your bank, your employer, Level and the third-party non-affiliate to whom you provide the information used to provide our Services. The personal information categories may include:
Identifiers – identifiers, such as your employee ID number
Employment/Financial – employment or financial-related information, such as pay information, information relating to the account to which the pay is directed, the number of hours worked by you, and information as to whether you have savings available;
Communications – communications with Level on our behalf via chat or phone call, to provide customer service;
Technical – other technical information including your browser type, service provider, or operating system; and
Login – login credentials for your DailyPay account.
The purposes for use of personal information within these categories are included below at 2.2 and 3.0.
2.2 Account. In order to utilize our Services, you are required to create an account (‘Account’). We may offer different options to create an Account, including:
Online Registration Form: You may choose to complete and submit an online registration form. As part of the registration process, you may be asked to provide us with an email and mailing address, mobile phone number, date of birth, proof of identity documentation, and a password that you will use to access your Account, as well as other information that may be required to open your Account. We process this information under the lawful basis of consent, contractual necessity or legitimate interest.
Third-Party Accounts: You may choose to create (or supplement) an Account by clicking on a ‘connect,’ ‘sign on,’ or an equivalent button that we may display on the site for a designated account that you have with a third-party website or service (each a ‘Third-Party Account’). Doing so will enable you to link your DailyPay Account and your Third-Party Account. If you choose this option, then we will obtain certain information, including personal information, from your Third-Party Account. The information that we obtain from your Third-Party Account is information that you have chosen to make available to us as part of your use of your Third-Party Account, and is typically identified in the privacy policy of your Third-Party Account provider. You acknowledge the Third-Party Account is governed by the terms of use and privacy policy of that account provider. Please note that to use this option, you will need to have, and may need to be signed-in to, an existing Third-Party Account. We process this information under the lawful basis of legitimate interest.
Regardless of which method you choose to register your Account, we may send an email or text message to your nominated email address, mobile phone number, or to the email address that you have designated in your Third-Party Account to instruct you how to confirm your registration.
2.3 Your Interactions with Us
Contact Us Information. If you send us a ‘Contact Us’ request, whether by calling our customer service number, submitting an online form, emailing a DailyPay email address, text messaging a company number, or interacting with the chat function that we make available on the website, you may be required to provide us with certain information such as your name, phone number, and email address. Please note that in contacting us, you may also be contacting and providing your information to Level.
Third Party Notice and Consent. When you interact with us through these channels, DailyPay, Level and our vendors may have access to the communications or your web experience. These are recorded for purposes including monitoring and improving customer service, regulatory compliance, preventing fraud and record keeping. Use of these channels reflects your acknowledgment of DailyPay, Level and our vendors having access to these communications for these purposes.
2.4 Log Files. We (or Level) may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer our Services, track users’ movement around our Services, and gather user categorical data.
2.5 Cookies and Other Tracking Technologies. Our website and mobile app may utilize cookies and other tracking technologies in order for us to provide or advertise our Services, and to enable, optimize, and analyze operation of our Services. A cookie is a small text file that may be used, for example, to collect information about website and Service activity. Certain cookies and other technologies may serve to recall information, such as an IP address, previously indicated by a user.
Browser Control. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
Website Control. You may also set your cookie preferences on our website. If you are not logged in or your IP address is blocked, you may have to re-set your preferences on a subsequent visit when you are logged in or your address is unblocked. You may also have to do so on each device from which you access our Services.
2.6 Data Providers. We (or Level) may obtain information about you, such as mailing address, gender, age, marital status, ethnicity, and information about your home and automobile from third-party data providers. We may use this information for marketing purposes and research purposes.
Marketing. We may use this info to market our products and services to you.
Research. We may use this info to provide aggregated, anonymized insights to third-party entities for the purpose of determining the impact of Services on user financial wellness.
3.0 Purposes/Use of Personal Information and Legal basis for processing. If you submit or we collect personal information through the Services, then such personal information may be used by us in the following ways:
3.1 We may use or share with our subsidiaries, service providers, contractors, third-party nonaffiliates, or employer partners these categories of personal information collected for purposes of:
Personal Information Categories Collected | Purpose for the processing of personal data | Lawful basis |
Identifiers Employment/Financial | Offering a wage access platform and associated services | Contractual necessity Legitimate interest |
Identifiers Employment/Financial Technical Login | Data security and integrity, including fraud or illegal activity prevention and detection | Contractual necessity Legitimate interest |
All | System maintenance and repair | Contractual necessity |
Identifiers Employment/Financial- Communications Technical Login | Account maintenance or service | Legitimate interest |
Identifiers Employment/Financial | Customer service | Consent Legitimate interest |
Identifiers Employment/Financial | Processing or fulfilling transactions | Contractual necessity |
Identifiers Employment/Financial Login | Verifying customer information | Contractual necessity Legal obligation |
Identifiers Employment/Financial | Processing payments | Contractual necessity |
Communications | Research and development of new products or improvement of existing products | Legitimate interest |
Communications Technical | Service quality assurance or enhancement | Contractual necessity Legitimate interest |
Identifiers Employment/Financial- | Creation of Third-Party Account(s) | Contractual necessity Consent |
3.2 We may use your personal information to provide and improve our Services, to create insights about our users, to contact you in connection with the Services and certain programs, features or offerings that you may have registered for, to advertise our Services, and to identify and authenticate your access to the parts of the Services that you are authorized to access under the lawful basis of contractual necessity or consent, or legitimate interest.
3.3 We may use your designated email address or mobile phone number to: (i) send you updates or news regarding the Services; and/or (ii) respond to a Contact Us or administrative requests (for example, to change your password), through Level under the lawful basis of legitimate interest.
3.4 We may transfer your personal information to our subsidiaries, affiliates, vendors or employer clients to provide our Services. When we share personal information with our service providers and non-affiliated companies that perform support services for us, the information may be used for improvement of fraud analysis, identity verification, risk management services for which we engage them, or other services for which we engage them under the lawful bases of contractual necessity, legal obligation or legitimate interest when such service providers act as our processor. If they act as a separate controller, the legal basis will be decided by them.
3.5 Level may collect and use your personal information for marketing and advertising purposes under the lawful basis of consent when using opt-in means of collecting personal data or legitimate interest when personal data is collected on an opt-out basis. Please consult Level’s Privacy Policy here for additional information:
Direct marketing. Level, either directly or through your employer, may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opting Out section below or opt-in during the sign-up process through your employer.
Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads promoting our and other services across the web. These companies may use cookies and similar technologies to collect information about your interaction (including the data described above) over time across the Internet and use that information to serve online ads that they think will interest our business clients or prospects. You may opt-out of this interest-based advertising as described further in the Opting Out section below, but you may receive less relevant ads instead.
3.6 We may disclose your personal information if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) to administer our Services; (ii) comply with any applicable law, regulation, legal process or governmental request; (iii) enforce our Terms, including investigations of potential violations thereof; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to the rights, property or safety of DailyPay, our users, yourself or the public. The lawful basis for such disclosures will be contractual necessity, compliance with a legal obligation or our legitimate interest.
3.7 If we or any of our subsidiaries are involved in a merger, acquisition, or sale of all or a portion of assets, you will be notified via email and/or a prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may do this under the lawful basis of consent or legitimate interest.
4.0 Use of Anonymous Information. We may create anonymous data from personal information by excluding information that makes the data personally identifiable, and use that anonymous data for our lawful business purposes, including to provide workforce insights to our employer clients.
Web Experience
5.0 Opting In and Opting Out. You may choose to receive promotional and advertising text messages from us by providing us with your written consent directly or through your employer or Level. You may choose not to receive future promotional or advertising emails or text messages from us by selecting an unsubscribe link at the bottom of such emails or by texting STOP to opt-out of such text messages. You also control your notifications in your account settings. If you opt-out of receiving the foregoing emails or text messages, we may still send you a response to any Contact Us request as well as administrative emails necessary to facilitate your use of our Services (for example, in connection with a password reset request, an email/text message verification, or a payment-related email/text message).
6.0 Do Not Track and Global Privacy Controls (“GPC”). Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals, however we do respond to GPC signals. To utilize GPC signals, simply enable them in your browser. To find out more about “Do Not Track” or “GPC,” please visit www.allaboutdnt.com or https://globalprivacycontrol.org/, respectively.
7.0 Online Tracking Opt-Out. There are a number of ways to opt-out of having your online activity and device data collected:
7.1 Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
7.2 Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
7.3 Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers.
7.4 Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
Google: https://adssettings.google.com
Twitter: https://twitter.com/settings/account/personalization?lang=en
Sailthru: https://getstarted.sailthru.com/audience/managing-users/user-optout-levels/#Opt-out_Management
7.5 Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt- out on every browser and device that you use.
8.0 Links to and Interaction with Third-Party Products or Services. Our Services may enable you to interact with or contain links to your Third-Party Accounts and other third-party websites, mobile software applications and services that are not owned or controlled by us. We are not responsible for the privacy practices or the content of these Third-Parties. Please be aware that the Third-Parties may collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party with you choose to engage or interact with.
Access, Security, Retention and Deletion
9.0 Access/Accuracy. To the extent that you do provide us with personal information, we wish to maintain accurate personal information. You have the right to access and update the personal information we hold about you, which is set out in further detail at 13.1 and 13.2 below. You may use the tools that we make available through our Services to remove or modify certain information in your Account.
10.0 Security. The security of personal information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the personal information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security or confidentiality.
11.0 Record Retention/Deletion. We retain personal information as long as reasonably necessary to achieve the collection and use purposes disclosed in this Policy. The criteria determining retention periods are based on legal obligations and information sensitivity, security, product research and development, technical functionality, and experience improvement considerations. DailyPay may also retain information not formatted for targeted disposal. We specifically retain personal information:
to respond to or comply with court orders, subpoenas, or regulator inquiries;
as required by applicable law or regulation;
in response to or in anticipation of litigation; and
for other legitimate business purposes.
Further, DailyPay honours all verified or authenticated consumer deletion requests, which is set out in further detail at 13.3 below.
Cross-border transfer of data
12.0 Cross-border transfer of data. We may need to transfer your personal information outside the United Kingdom. Where this is the case, we ensure that your personal information is adequately protected as required by applicable law. These measures include:
12.1 ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, which means that the recipient country is deemed to provide adequate protection for such personal data;
12.2 using standard agreements approved by relevant authorities; and
12.3 requiring the use of other appropriate technical and organisational measures to protect your personal information.
Data Subject Rights
13.0 Rights available to you. You have certain legal rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us as per our contact details provided at 17.0.
13.1 Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the UK.
13.2 Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
13.3 Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us as per our contact details provided at 17.0.
13.4 Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us as per our contact details provided at 17.0.
13.5 Right to data portability: You have a right to ask us to provide your personal information to an alternative third party provider of services.
13.6 Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
13.7 Right to complain. You have the right to complain to the data protection regulator. In the UK, this is the Information Commissioner’s Office at https://ico.org.uk. We would like to help resolve your complaint in the first instance though, so please contact us as per our contact details provided at 17.0.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Miscellaneous
14.0 Children’s Privacy. Our Services are not structured to attract children under the age of 16 years. Accordingly, we do not intend to collect personal information from anyone we know to be under 16 years. If we learn that we have collected personal information from a child under 16 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact usas per our contact details provided at 17.0.
15.0 Corporate Structural Event. In the event of our acquisition, merger, restructuring, bankruptcy, or comparable event, we reserve the right to transfer or assign personal information in connection with the foregoing events.
16.0 Changes to this Privacy Policy. We reserve the right, at our discretion, to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). Your continued use of the Services thereafter means that you accept those changes.
17.0 How to Contact Us. If you have any questions or concerns at all about our Privacy Policy, please contact us at Privacy Policy Form or privacy@dailypay.com.