Effective Date: January 23, 2025
This privacy policy (the "Privacy Policy”) discloses how CBW Law ( “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of our websites, web applications, mobile applications, and any other online service locations that post a link to this Privacy Policy (collectively, the “Service”) or offline location that provides a copy of this Privacy Policy.
If you use our Service or interact with us offline, we will collect, use and disclose your personal data as described in this Privacy Policy. If you do not want us to use your personal data as described in this Privacy Policy, please discontinue use of the Service.
If you are contacting us about a potential claim, we will request certain information from you as described in more detail below. You may always choose not to provide the requested information, but if you do not provide the information you will not be contacted regarding the merits of your potential claim. You can access, update, or remove any information you submit to us about a potential claim, or request at any time that we not share it with our lawyer clients by e-mailing support@cbwlaw.com.
If you are a California resident, Nevada resident, Colorado resident, or data subject located in the European Economic Area, please see the additional disclosures at the end of this Privacy Policy. If you have any questions about our privacy practices, please contact us as set forth in the Section 10 below.
It is important that you read and understand these entire Privacy Policy before using the Service. For ease of review, below is a table of contents that links to each section. Please note that the complete provisions and not the headings shall govern. You can click on the headings to be taken to the full explanation.
1. Information Collection | We collect various categories of personal data about you in different ways, including directly from you and automatically as you access our websites. |
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2. Use and Disclosure of Information | We may use and disclose your personal data for various purposes, including for purposes consistent with your use of the Service. |
3. How to Exercise Your U.S. Privacy Rights | We describe how residents of certain U.S. states can exercise their privacy rights. |
4. Data Security | We use reasonable and appropriate technical and organizational measures to protect your personal data. |
5. Children’s Privacy | The Service is not intended for use by children under the age of 18 and we use reasonable age verification measures to limit access to the Service. |
6. International Transfers | Your personal data may be transferred to the U.S. and other countries. |
7. Changes to This Privacy Policy | Changes to this Privacy Policy will become effective on the date they are posted. |
8. Contact Us | You may contact us for comments or questions in various ways. |
9. Nevada Privacy Notice | We provide additional disclosures and rights to Nevada residents. |
10. California Privacy Notice | We provide additional disclosures and rights to California residents. |
11. Colorado Privacy Notice | We provide additional disclosures and rights to Colorado residents. |
Summary of Lead Client Information Collection Practices
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal information includes “personal data” as that term is defined in applicable privacy laws, as may be further described in Sections 9-12 of this Privacy Policy. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. For more information how we collect and use the information in the following table, please review Sections 9-12 We may disclose non-personal information, such as aggregated user statistics, to third parties. Our use of aggregated, anonymized, and de-identified data is not subject to this privacy policy.
The chart below explains how and why we may use different types of personal information as well as with whom we may share personal information.
Categories of Personal Information Collected | Examples | Processing Purposes Linked to Categories | Categories of Third Party Recipients (Excluding Services Providers and Affiliates) |
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Identifiers | · First and last name · Phone number · Postal address · Email address · Certain social media account information including user ID · IP address · Unique device identifiers · Device operating system information | · To contact you and provide information · Customer service · For identity and age verification as required under applicable law · To provide and maintain the Service · To facilitate interactive features · For internal analytics · Marketing our products and services · Marketing the products and services of others · For internal business purposes, including general business administration · Audit, compliance, legal, policy, procedure, and regulatory obligations · User claims and fraud investigation and prevention · Systems and data security · Protecting the safety of our employees and others · Targeted Advertising · Profiling · For any purpose consistent with your preferences | · Third-party advertising and marketing platforms · Our legal industry customers and other individuals with your consent |
Customer Records | · Information about your potential claim, such as injury to a person or property and associated information | · For internal business purposes, including general business administration · Customer claims and fraud investigation and prevention · Systems and data security · Protecting the safety of our employees and others · Internal analytics | · Our legal industry customers and other individuals with your consent |
Commercial information | · Commercial activity, including products and services purchased or considered · Information about your interests and preferences | Same purposes as noted for “Identifiers” | · Third-party advertising and marketing platforms · Co-branded partners · Our legal industry customers and other individuals with your consent |
Internet or other electronic network activity information | · Browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages · Content and information about your communications through the Service · Information using cookies and tracking technologies as described below · Claim data, including information about your potential claim, such as injury to person or property and associated information, all of which is clearly labeled at the time of collection · Mobile operating system information · Mobile internet browser type · Device connectivity and configuration data, including data about the type of device or browser you use | Same purposes as noted for “Identifiers” | · Third-party advertising and marketing platforms · Co-branded partners · Our legal industry customers and other individuals with your consent |
Geolocation Data |
| · For internal business purposes, including general business administration · Customer claims and fraud investigation and prevention · Targeted Advertising · Profiling · Systems and data security · Protecting the safety of our employees and others · Internal analytics | · Third-party advertising and marketing platforms · Co-branded partners · Our legal industry customers and other individuals with your consent |
Audio, electronic, visual, or similar information | · Call center recordings for customer service and quality assurance · Photographs | · For internal business purposes, including general business administration · Customer claims and fraud investigation and prevention · Systems and data security · Protecting the safety of our employees and others · Internal analytics | N/A |
Professional or employment related information | · Employer name · Occupation · Tyle · Length of employment | Same purposes as noted for “Identifiers” | · Our legal industry customers and other individuals with your consent |
Education information | · School attended · Years of attendance · Tuition · Graduation status | · Same purposes as noted for “Identifiers” | · Our legal industry customers and other individuals with your consent |
Characteristics of protected classifications | · Age · Gender · Disability, including mental and physical information · Health conditions and treatments · Religious affiliation · Military service and/or veteran status | · For internal business purposes, including general business administration · Customer claims and fraud investigation and prevention · Systems and data security · Protecting the safety of our employees and others · Internal analytics · Targeted Advertising · Profiling | · Third-party advertising and marketing platforms · Co-branded partners · Our legal industry customers and other individuals with your consent |
Sensitive information or sensitive data | · Mental or physical health condition or diagnosis · Personal data collected and analyzed concerning health | · Provide customer service · Provide and maintain the Service · Internal analytics · Market our products and services · Market the products and services of others · Internal business purposes, including general business administration · Audit, compliance, legal, policy, procedure, and regulatory obligations · Targeted Advertising · Profiling · For any purpose consistent with your preferences | · Our legal industry customers and other individuals with your consent · Third-party advertising and marketing platforms |
Inferences about you using any of the above | · Information drawn from any of the information above categories of information | · For any of the purposes listed above | · Third-party advertising and marketing platforms · Co-branded partners · Our legal industry customers and other individuals with your consent |
Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.
We collect information you provide, such as when you submit a potential claim for review. We may use Service Providers (defined below) to collect this information. The categories of information we collect and have collected in the last 12 months, include the following:
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
In addition, we automatically collect information when you use the Service. We may use Service Providers to collect this information. The categories of information we automatically collect and have collected in the last 12 months includes: Service use data, including data about the pages you visit, the e-mails and advertisements you view, the time of day you browse, and your referring and exiting pages; device connectivity and configuration data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address; and location data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).
We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:
Please note that our websites implement measures to help ensure that we do not use Cookies for individuals accessing our services from Connecticut, Nevada, or Washington.
We also collect information from other sources. The categories of sources we collect and have collected information from in the last 12 months include publicly available sources (such as through internet searches) and social media platforms. To the extent we combine information from other sources with information we have collected through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data.
We collect and use your information to conduct a preliminary analysis of your potential claims. We may contact you to verify your information and further explore your potential claims. Other business purposes for collecting and using information, including in the last 12 months, include to: Provide and manage our Service.
We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we share and have shared information with in the last 12 months, include the following:
We use analytics services, such as Google Analytics, to help us understand and analyze how you access and use the Service and other services. In addition, we work with agencies, ad networks, advertisers, and other technology services to place advertisements about our products and services on the Service and on other services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of the process, we and other parties may incorporate Tracking Technologies as described In Section 1(c) on our Service (including in our e-mails and advertisements) and other services. Some of these technologies track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and other services after you have left the Service (“Interest-based Advertising”).
We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). For example, we use Facebook Custom Audiences to serve Matched Ads. This is done by us incorporating a pixel from the technology service on our own Service or uploading data (such as the email address you provided us when submitting a potential claim for review) to the technology service, and the technology service matching common factors between our data and their data.
As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
Where we work with other parties to engage in Interest-Based Advertising, these parties are often members of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative ("NAI"). These programs offer centralized locations where users can make choices about the use of their information for Interest-based Advertising. To learn more about the DAA’s Self-Regulatory Program for Online Behavioral Advertising and your opt-out options for their members, please visit https://www.aboutads.info/choices. To learn more about the NAI and your opt-out options for their members, please visit https://www.networkadvertising.org/choices/.
To opt-out of us using your data for Matched Ads, please contact us as set forth in the Section 8 below and specify that you wish to opt-out of Matched Ads. We will remove your information from the Matched Ads or request that the applicable technology service not serve you Matched Ads based on information we provide to it. Alternatively, you may also contact the applicable technology service to opt-out.
Please note that any opt-outs only apply to the specific browser or device from which you opt-out. Further, opting-out through the DAA or NAI only means that the selected members should no longer deliver certain Interest-Based Advertising to you, and does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their practices or programs.
For further information on the types of Tracking Technologies we use, please see Section 1(c).
You may access, update, or remove any information you have submitted to us about a potential claim, or request that we do not share it with our lawyer clients, by e-mailing support@cbwlaw.com. We will respond to your request to access, update, or delete your information, or stop sharing, within ten (10) business days. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Further, any request to stop sharing with our lawyer clients will not affect any information previously shared with our lawyer clients, and questions regarding their use of your data should be directed to them, not to us.
E-mails. You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the Section 10 below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or CBW Law’s ongoing business relations.
Text Messages and Calls. You can opt-out of receiving text messages or calls to your phone number at any time by (i) texting “STOP” in response to any text message you receive from us or contacting us as set forth in the Section 10 below and specifying you want to opt-out of text messages. For help, reply “HELP” to any message you receive from us or contact us as indicated under the “Contact Us” section below; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set forth in the Section 8 below and specifying you want to opt-out of calls.
Please note that your opt-out is limited to the e-mail address and phone number used and will not affect subsequent subscriptions.
Certain states provide residents with certain rights with respect to their personal information or personal data as defined under applicable law, including residents of California, Colorado, and Nevada as detailed in Sections 9 – 12. Please review Sections 9 – 12 for more information on state-specific rights and terms.
If you are a resident of California, Colorado, or Nevada, please use the following information to exercise your privacy rights. Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you are a visually impaired customer, a customer who has another disability or a customer who seek support in other language, you may access your privacy rights by emailing us at support@cbwlaw.com.
Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.
How to submit a request. If you wish to exercise any of the rights in Sections 9 - 12 , please send your request(s) using one of the following methods:
Webform: Link
Mail:
CBW Law, PLLC
2355 E. Camelback RD, Suite 330
Phoenix, AZ 85016
We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Depending on applicable law, you may be limited in how many verifiable or authenticated consumer request you make within a twelve (12) month period. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Generally, a rights request must include:
We cannot respond to your request or provide you with personal data if we cannot verify or authenticate your identity or authority to make the request and confirm that the personal information relates to you.
You are not required to create an account with us to submit a verifiable or authenticated consumer request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
We implement and maintain commercially reasonable administrative, physical, and technical security measures designed to prevent the loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction of your information. We carefully limit access to the database in which your information is stored. Additionally, we share and transfer your information only in the ways set forth in this Privacy Policy. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.
The Service is not directed to children under eighteen (18) years of age. CBW Law does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) from children. If you are a parent or guardian and believe CBW Law has collected such information, please contact us as set forth in the Section 10 below. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
We are based in the U.S. and the information we collect is governed by U.S. law. If you are located outside of the U.S., please be aware that the information we collect may be transferred to, stored, used, and otherwise processed in the U.S. and other jurisdictions in accordance with this Privacy Policy, and you agree to such processing. Data protection laws in the U.S. and other jurisdictions may differ from those of your country of residence.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your e-mail address
If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:
By e-mail: support@cbwlaw.com
By mail:
CBW Law, PLLC
2355 E. Camelback RD, Suite 330
Phoenix, AZ 85016
If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at support@cbwlaw.com.
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as set out in the “Contact Us” section above.
This California Privacy Notice provides additional information regarding the personal information as defined in Section 1 about California residents that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding to California residents’ rights, and our responsibilities, under the California Consumer Privacy Act and its amendments in the California Privacy Rights Act (“CCPA”), and other relevant California laws and regulations.
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information, as well as rights to access, correct, delete, and restrict the sale, use, and disclosure of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA.
This section applies to any California residents about whom we collect personal information, as defined in Section 1, from any source, including through the use of the Service, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”). “Personal information” also includes personal information as described in California Civil Code Section 1798.80(e), which includes “Customer records” as described in Section 1.
For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public either through widely distributed media or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at support@cbwlaw.com.
We may collect, use, and disclose personal information from or about you as described in Section 1.
In the past 12 months, we have collected the following categories of personal information listed in the CCPA, as further detailed in Section 1 of this Privacy Policy:
We may collect or use personal information from you for the purposes identified in Section 1 of this Privacy Policy. To the extent we collect sensitive personal information as identified in Section 10(a) above, it may be used for all of these purposes.
For more information on information we collect, including the sources we receive information from, review Sections 1 and 2 above. We collect and use these categories of personal information for the business purposes described in Sections 1 and 2 above, including to provide and manage the Service.
The categories of sources we collect personal information from include:
We may “sell” or “share” certain personal information with third party partners as part of targeted advertising initiatives. These disclosures constitute “selling” and/or “sharing” under California law, even though we do not receive monetary payment for sharing or disclosing personal information to these third parties.
To the extent “sale” or “share” under the CCPA is interpreted to include the activities in this Privacy Policy, such as those disclosed in Sections 1 and 2 above, we will comply with applicable law as to such activity. The only category of third parties with whom we may share your personal information is third-party advertising and marketing platforms for the limited purpose of providing you with tailored digital advertising. We disclose the following categories of personal information for commercial purposes: Identifiers, Characteristics of protected classifications (except disability information), Commercial information, Internet or other electronic network activity information, Geolocation data, and Inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review Sections 1 and 2 above for more information about how we disclose your personal information.
We will not collect additional personal information from you or use your personal information for additional purposes that are incompatible with our original purpose for collection without providing you with notice.
We retain your personal information, including sensitive personal information, for as long as reasonably necessary to provide you with the products or services you have requested from us, as may be required by law, as may be required to achieve any of the other purposes listed in Sections 1 and 2 above, or until such time that you exercise your privacy rights. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.
If you are a California resident, subject to applicable law, you have the following rights under California law:
You may exercise or designate an agent to exercise the above rights by following the instructions in Section 3.
We may "sell" or "share" share certain personal information with third-party partners as part of targeted advertising initiatives. That sharing may constitute "selling" and/or "sharing" under California law, even though we do not receive monetary payment for sharing or disclosing personal information to these third parties. We do not otherwise "sell" personal information as defined under California law.
If you wish to opt-out of our sharing of the limited data that is gathered when you visit our Websites and other web-based services for purposes of cross-context behavioral advertising, you may do so in one or more of the following ways:
Please review Section 2(c) for more information about opting out of seeing targeted digital advertisements.
We do not offer financial incentives involving the collection of personal information through the Service at this time. Should we offer any financial incentives in the future, we will update this Privacy Policy and notify you.
This Colorado Privacy Notice provides additional information regarding the personal information as defined in Section 1 about Colorado residents that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding to Colorado residents’ rights, and our responsibilities, under the Colorado Privacy Act (“CPA”), and other relevant Colorado laws and regulations.
The CPA provides Colorado residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information, as well as rights to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data, as well as rights to delete, correct, and affirmatively consent to the use, disclosure, and sale of certain personal data we collect about them. Colorado residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CPA.
This section applies to any Colorado residents about whom we collect personal data, as defined in Section 1, from any source, including through the use of the Service, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).
For purposes of this section, “publicly available information” means information that is lawfully made available from federal, state, or local government records, or widely distributed media and information that a business has a reasonable basis to believe the consumer has lawfully made available to the general public.
If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at support@cbwlaw.com.
We may collect, use, and disclose personal data from or about you as described in Section 1.
Certain of the information we collect constitutes “sensitive data” as defined under Colorado law, including:
We may collect or use personal data from you for the purposes identified in Section 1 of this Privacy Policy. To the extent we collect sensitive data as identified in Section 11(a) above, it may be used for all of these purposes.
For more information on information we collect, including the sources we receive information from, review Sections 1 and 2 above. We collect and use these categories of personal data for the business purposes described in Sections 1 and 2 above, including to provide and manage the Service. The categories of sources we collect personal data from include those described in Section 11(c) above.
We may “sell” certain personal data with third party partners as part of targeted advertising initiatives. These disclosures constitute a “sale” under Colorado law, even though we do not receive monetary payment for sharing or disclosing personal data to these third parties.
To the extent “sale” under the CPA is interpreted to include the activities in this Privacy Policy, such as those disclosed in Sections 1 and 2 above, we will comply with applicable law as to such activity. The only category of third parties with whom we may share your personal data is third-party advertising and marketing platforms for the limited purpose of providing you with tailored digital advertising. We disclose the following categories of personal data for commercial purposes: Identifiers, Characteristics of protected classifications (except disability information), Commercial information, Internet or other electronic network activity information, Geolocation data, and Inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review Sections 1 and 2 above for more information about how we disclose your personal data.
We retain your personal data, including sensitive data, as detailed in Section 10(e) above.
If you are a Colorado resident, subject to applicable law, you have the following rights under Colorado law:
You may exercise or designate an agent to exercise the above rights by following the instructions in Section 3.
We use Plaid Inc. (“Plaid”) to provide identity verification services. Plaid collects and processes certain personal information to verify your identity and prevent fraudulent activity. By using our services, you agree to Plaid’s collection and use of your personal information in accordance with their Privacy Policy.
When you verify your identity through Plaid, certain data you provide (such as your full name, address, date of birth, and identification documents) is securely transmitted to Plaid for verification purposes. We do not store or have direct access to your sensitive personal information collected by Plaid.
For more information about how Plaid handles your data, please review their Privacy Policy: https://plaid.com/legal/#consumers.