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BBVA Compass ClearSpend Service Privacy Policy

Effective date: February 22, 2016

This Privacy Policy describes our practices related to the use, storage and disclosure of information we collect from or about you in the course of providing the ClearSpend Service. We reserve the right to modify this Privacy Policy at any time and without prior notice. The privacy policy links within the online and mobile channels will direct your device to the most recent version of this Privacy Policy. This Privacy Policy is not a contract and does not create any legal rights or obligations. Terms defined in the BBVA Compass ClearSpend Mobile Application Terms of Use shall have the same meaning in this Privacy Policy, unless otherwise stated below.

Through both the Mobile and online services, you may use your Eligible Device to (i) view balances and recent transactions for each Account; (ii) make immediate, one-time transfers of funds between your Accounts; and (iii) access additional services that may be available through the ClearSpend Service.

What information does the ClearSpend Service obtain and how is it used?

User Provided Information – The ClearSpend Service obtains the information you provide when you download the Mobile App and register either on the Mobile App or online . Registration with us is mandatory in order to be able to use the basic features of the ClearSpend Service. During registration, you generally provide: name, email address, phone number, user name, password and other registration information. We use this registration information to create a unique user profile for you, which is required to access and use the ClearSpend Service. We may also use the contact information you provide us to notify you from time to time of important information and updates related to the ClearSpend Service or other banking services. 

When using the ClearSpend Service, you generally provide information we must use to complete requested transactions. Such transaction-related information may include: account information, transfer amounts, dates, and frequency. 

Automatically Collected Information and Device Access - In addition, when using the ClearSpend Service, we may collect certain device information automatically, such as the type of device you use, your device’s unique device ID, the IP address of your device, the geographic location of your device, your operating system, and certain information about the way you use the ClearSpend Service. The ClearSpend Service may also access the following information when needed to perform services that you request: access to location information based on cellular network database and GPS; access to phone operations to call phone numbers without user’s intervention, access to phone information (e.g. phone number and serial number of device, whether a call is active, the phone number being called); internet access to create network sockets; access to contact (address) data stored on the phone or computer; access to information about the state of Wi-Fi and all networks; access extra location provider commands; access to device storage to write, modify, or delete content. This information is only accessed to provide the services necessary within the ClearSpend Service that you choose to use.

Does the ClearSpend Service collect precise real time location information of the device?

Unless you have opted-out through your device settings, the ClearSpend Service may collect precise information about the location of your device. Location information is accessed when you choose to use location-based services. Location information is obtained from technologies like GPS, Wi-Fi, or cell tower proximity. You may at any time opt-out from allowing the ClearSpend Service to have access to your location data through your device settings. We do not control your location information preferences from within the ClearSpend Service. For more information, please see the section below regarding “opt-out rights.” 

We use your location information to provide requested location-based services, such as finding ATMs and branches nearest to you and displaying them on a map in relation to your location.

Do third parties see and/or have access to information obtained by the ClearSpend Service?

Yes. Subject to applicable law and regulation, we may share information collected by the ClearSpend Service with third parties only in the ways that are described in this Privacy Policy. 

We may disclose user-provided and automatically collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and
  • with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Privacy Policy.

How is information collected by the ClearSpend Service used?

We use the information collected about you and your device to maintain and provide you with the ClearSpend Service, to respond to your questions and instructions, to maintain the integrity of our network and address security issues, to detect fraud, to investigate or take action regarding violations or suspected violations of law or our terms, and to improve the ClearSpend Service.

What are my opt-out rights?

You may at any time opt-out from allowing the ClearSpend Service’s access to your location information by disabling location tracking features in your device settings. Turning off your device’s location tracking features will prevent the ClearSpend Service from performing location-based services, such as finding nearby ATMs and branches. You may also refrain from using ClearSpend Service features that collect specific types of information. 

You can stop all collection of information by uninstalling the ClearSpend Service. You may use the standard uninstall processes available as part of your device or via the removal features provided in your ClearSpend Service store or network. Once you have uninstalled the ClearSpend Service, any preferences that you previously set within the ClearSpend Service are deleted, such as location permissions and whether you allowed us to send you push notifications.

How does the ClearSpend Service respond to Do Not Track signals?

Do Not Track (DNT) is a privacy preference that users can set in recent versions of most major web browsers, including Firefox 5+, Internet Explorer 9+, Safari 5.1+, and Chrome. DNT allows users to inform web services that they do not want certain information about their webpage visits collected across websites. 

Whether you have turned on DNT or not, the ClearSpend Service does not collect personally identifiable information (PII) about your online activities over time and across third party websites or online services. Nor do third parties use the ClearSpend Service to collect PII about your online activities over time and across third party websites. For these reasons, the ClearSpend Service does not respond to DNT signals.

Data Retention

Our operational systems will store user-provided data for as long as you use the related feature of the ClearSpend Service, unless you choose to delete it. Please note that some or all of the user-provided data may be required in order for the ClearSpend Service to function properly, and we may be required to retain certain information by law. If you close your profile established for Online and Mobile Banking, we will retain certain account data, such as transaction history and account balances, for a reasonable time to facilitate any request to reopen your profile.

Children

We do not use the ClearSpend Service to knowingly collect data from or market to children under the age of 13. If a child under 13 has provided us with personal information without parental or guardian consent, the parent or guardian may contact us at 1-800-273-1057. We will delete such information from our files within a reasonable time and unsubscribe the child from any promotional contact opportunities.

Security

Protecting the confidentiality of your information is very important to us. We have established appropriate physical, electronic, and procedural safeguards to protect information we collect from or about our users. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our ClearSpend Service. These safeguards are regularly reviewed to protect against unauthorized access, disclosure and improper use of your information and to maintain the accuracy and integrity of that information.

Changes

This Privacy Policy may be updated from time to time, as new versions of the ClearSpend Service are released and the Banking Services are modified or expanded. The Privacy Policy link within the ClearSpend Service will direct your device to the most recent version of this Privacy Policy. You may also visit http://www.bbvacompass.com/compass/policy/privacy.html to view the current copy of this Privacy Policy. We will notify you electronically of any material changes to our Privacy Policy in accordance with the BBVA Compass ClearSpend Mobile Application Terms of Use. Your use of the ClearSpend Service following an update to this Privacy Policy means that you accept the updated Policy.

Your Consent

By using the ClearSpend Service, you are consenting to our processing of user-provided and automatically collected information as set forth in this Privacy Policy, now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, as necessary to provide the ClearSpendService to you.

Contact us - If you have any questions regarding privacy while using the ClearSpend Service, or have questions about our practices, please contact us at 1-800-273-1057.

A Spanish version of this document is available as a courtesy to our clients who use Spanish as their primary language. Although Compass Bank has taken every precaution possible to translate the original document correctly, the Spanish translation is only a courtesy to our clients. Please take note that all official documents from Compass Bank will be in English only. Please visit: http://www.bbvacompass.com/disclosure/online-banking/clearspend-privacy-policy to view the Spanish version.