We are committed to keeping your information safe, secure, and private.
Information We Collect, How We Collect It, and Whether We Store It
We ask for information when you create an account on Fresh EBT. This varies by state but can include:
- Your name, EBT card number, Social Security number, and date of birth.
- Your zip code and, if you provide us access to it through your device, your GPS location information.
- Your EBT account user ID and password.
- Your email address and/or phone number.
We also collect the following information from the EBT processor portal:
- EBT balance.
- EBT transaction data.
Lastly, we collect information automatically from your use of Fresh EBT. This information includes:
- Device information, including your IP address, MAC address, and device ID.
- App usage information, including what content you see, what content you tap on, and how much time you spend using Fresh EBT.
Some of the information you provide is stored locally on your device, some is stored on our servers, and some is never stored at all and is only passed to the EBT processor portal. Please see Exhibit A below for specifics on information that is collected and whether we store it.
What We Do With Your Information
We use your information:
- to create an account in the EBT processor portal.
- to login to the EBT processor portal and provide your account information, including balance and transaction history.
- to show your transaction history and operate other features of the application.
- to send you emails, texts, or push notifications if you allow these communications.
- to promote goods and services that may be relevant to you.
Please see Exhibit A for specifics on what we do with your information.
If you opt in to receiving marketing email, you may choose to stop receiving emails by following the unsubscribe instructions included in these emails. If you provide your phone number to receive updates about Fresh EBT, standard text message rates apply. You can stop receiving text messages from Fresh EBT by replying ‘STOP’ to any text message. You may also request to have your contact information removed from our system at any time by emailing firstname.lastname@example.org.
How We Share Your Information
We will only share and disclose information submitted, collected, received, or generated from and/or about you consistent with applicable law and in connection with Fresh EBT as follows:
- EBT processor portals and IVR hotlines: We pass along your information in order to access your balance, transaction history, and other EBT account information.
- Contractors and Service Providers: We may employ other companies, vendors, service providers and individuals to perform functions or services for us or otherwise act on our behalf. These third parties may have access to your information to the extent needed to perform their functions on our behalf.
- Aggregated Data: We may publish and otherwise disclose aggregate data (including derivative information and analyses) relating to your use of Fresh EBT. This information does not include your name, address, birthdate, EBT account or card number, or any other information that individually identifies you.
- Business Transactions: We may share your information with parties to business transactions such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, your information may be shared, sold, or transferred, and it may be used subsequently by a third party. This does not include personal information that we do not store, such as your EBT card number, PIN, SSN, or user ID and password.
- Compliance with Law and Protection of Company and Others: We reserve the right to disclose your information when it is believed disclosure is appropriate to comply with the law, judicial proceeding, court order, subpoena or other legal process; detect, prevent, or otherwise address fraud, security, emergency situations or technical issues; enforce or apply the Terms of Service and other agreements, rights and remedies; or protect the rights, property, or safety of Propel, our employees and contractors, users, or others.
Exhibit A. Data Collection, Use, and Sharing Overview
|Type of information||What information do we collect? How do we collect it?||Do we store it on our servers?||How do we use information?||Who do we share information with?|
|Personal information used to create an account on the EBT processor portal||This varies by state. It can include:|
- EBT card number
- Date of birth
We ask for this information at registration.
|No, we do not store name, EBT card number, or SSN.|
We do store the participant’s year of birth.
|We transmit this data through our server in order to create an account on the EBT processor portal.|
Note: if a name appears in an EBT processor portal, we may also display the name to the participant inside of Fresh EBT. We do not store names.
|We pass this information it onto the EBT processor portal so they can verify the participant’s identity through their existing methods.|
We do not otherwise share this data with anyone.
|Location information||We collect ZIP codes at registration.|
We also ask for location permission to use certain features, for example a map of nearby SNAP authorized retailers. This is optional.
|Yes, we store ZIP codes.|
We do not store current location.
|We use the ZIP code to customize content in the app (for example, displaying a local job opportunity near or locating a participant on the map).||We do not share this data with anyone.|
|Credentials used to sign into the EBT processor portal||These vary by state. It can include:|
We ask for this at registration and login.
|No, we do not store credentials on our server.|
Credentials are stored on user phones, fully encrypted.
|These are used to sign into the EBT processor portal. When Fresh EBT is opened, the user’s phone sends credentials through our server to the EBT processor portal, allowing us to update balance and transactions.||We pass this information onto the EBT processor portal so they can verify the participant’s identity.|
We do not otherwise share this data with anyone.
|Contact information||In some states we collect:|
- Email address
- Phone number
We store this information if given permission by the user. Users are asked for this at registration.
|Yes, we store email address and phone number (if given permission by the user).||If given permission, we use it to communicate with Fresh EBT users. For example, we may use it to let users know about changes to Fresh EBT, share relevant news, or introduce new products we build.||We do not share this data with anyone.|
|EBT balance and transaction data||This varies by state. It can include:|
- Current balance
- Past transactions
We collect this from the EBT processor portal. Our information is limited to what is displayed when a participant logs into their EBT portal.
|Yes, we store user balance and transaction information.|
However, we anonymize this information so it cannot be associated with a specific EBT card or individual’s name.
|We use this to display balance and transaction history within Fresh EBT.|
We use this data in aggregate to better understand our users’ needs.
|We do not share this data in a format that individually identifies you.|
We may share this data in aggregate form. For example, we can analyze trends in balance amount remaining during an early issuance period. This information does not include your name, address, birthdate, EBT account or card number, or any other information that individually identifies you.
|Other information||Device information:|
- IP address
- MAC address
- Device IDApp usage information. For example:
- What content is seen
- What content is tapped on
- Amount of time spent in Fresh EBTWe collect this automatically.
|Yes, we store device information and app usage information anonymously.||We use this information to analyze and improve Fresh EBT and partner content.||We do not share this data at the individual level with anyone.|
We may share anonymized and aggregated reports with organizations who publish content on Fresh EBT (for example, “50,000 SNAP participants saw content about early issuance”). This information does not include your name, address, birthdate, EBT account or card number, or any other information that individually identifies you.
We take reasonable and appropriate measures to help keep information secure and to help prevent it from becoming disclosed to individuals who are not described in this policy. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect, and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
Special Notice on Fresh Card
Information we store for your use of Fresh Card may be associated with your Fresh EBT account.
Special Notice for Coupons Feature
Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine usage of Fresh EBT, to prepare reports on activities and to analyze and improve Fresh EBT based on how it is used.
Anonymous user statistics are also collected using Google’s Firebase Analytics. The data collected cannot be used to identify individual users and is used to gather statistics on how the platform and app is used in order to obtain feedback on how to improve the app. Users can opt-out of mobile analytics by disabling Ad Tracking on their device. See the Firebase Analytics terms for more information: https://firebase.google.com/terms/analytics
We do not provide products and services to children. We do not knowingly collect or solicit information from children under the age of 13. If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personally identifiable information to us, please contact us at email@example.com.
A parent or guardian of a child under the age of thirteen (13) may review and request deletion of a child’s personally identifiable information as well as prohibit the use thereof. If we become aware that a child under 13 has provided us with personal information, we take steps to remove that information and terminate the child’s account.
Special Notice on Account Creation
To protect your privacy, we limit the amount of personally identifiable information we collect. Consequently, for users who live in certain states, Fresh EBT may automatically generate some anonymous information to create an account for you in the EBT portal. Specifically, Fresh EBT may automatically generate fictitious information for:
- Phone numbers
- Security questions
- Answers to those security questions
You may create a new account at any time directly in the EBT portal using a new User ID if you want to change any of this account information.
Special notice for Survey respondents
To improve Fresh EBT, we will occasionally post links to external surveys inside of Fresh EBT. These surveys are entirely optional. We use data collected in these surveys to inform decisions about the application, our business, and our partnerships. When you complete a survey, you consent to sharing your responses with us, including any personal information you choose to share. The surveys are hosted by third parties, and when you complete a survey, you are also agreeing to share your survey responses with these third parties and are also subject to their privacy policies. We never share any individual survey results outside of Propel. Occasionally we may share aggregated or summary results with our partners and other third parties.
We may occasionally update this policy. If we make significant changes, we will notify you of the changes through email, inside Fresh EBT, or by other means. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy.
Special Notice for Participants in the Beta Testing Program
If you agree to participate in the Beta Testing Program, you provide us your account information so that we can test features and improve the app. The information you provide is used only for testing purposes by Propel; it is never shared with third parties. We take reasonable and appropriate measures to store your information in a secure manner. If you no longer wish to participate in our Beta Testing Program, please contact us at firstname.lastname@example.org.
Effective Date: November 4, 2019