Privacy Policy
Anatomy Financial Inc., together with its affiliates (collectively "Anatomy", "we", "us", “our”) places a high priority on the privacy of individuals who visit our website, anatomy.com (“Site”) and/or who, on behalf of the businesses they represent, use our cloud-based hosted services (“you” or “User”) including our banking platform or any of our other websites, networks, applications, mobile applications, or other services provided by us (collectively, the "Anatomy Service").
When any of these activities occur, your Personal Information may be collected and processed by Anatomy. This Policy is designed to explain how we collect, use, store, retain, disclose by transmission, disseminate, or otherwise make available (collectively “Process”) your Personal Information. Please be aware that the Anatomy Service is integrated with certain third parties (“Third Party Servicers”) including, but not limited to Live Oak Bank, Member FDIC (“Live Oak”). The privacy policies of these Third Party Servicers will govern their collection, use, disclosure and processing of your Personal Information.
Our Terms of Service Agreement describes in detail why we need, and are sometimes required to, collect Personal Information. This Privacy Policy describes how we use that data, what we do with it and when we may disclose it to other parties. If at any time you have questions about our Privacy Policy, please contact us.
If you’re using Anatomy through your Company pursuant to an Agreement between Anatomy and the Company, Anatomy will process your Personal Information in accordance with the Agreement pursuant to your Company's instructions. In the event of a conflict between this Privacy Policy and the data processing terms of the Agreement, the Agreement governs.
Information We Collect
You are not required by law to provide us with any Personal Information. However, our ability to provide all features on the Site and Anatomy Service to you may be limited based on the level of Personal Information you provide us.
The Personal Information we may need to collect to provide the Anatomy Service to you includes your legal name, social security number, home and/or business address, and other identifying information about who you are. In addition to collecting information about your own identity, we also collect Company healthcare claims and financial information. Such information includes but is not limited to documents related to the organization of the Company; financial information about the Company, including real-time financial information provided to and by third parties and linked accounts; healthcare claims information, which may include PHI (Patient Health Information) such as patient name; and any information related to the compliance and/or enforcement with respect to federal and state anti-money laundering and banking laws and regulations.
We use Third Party Servicers to access, process, and collect information about the Company’s financial activity. Any time you link an account, we may receive real-time data and information associated with the linked accounts, for example, account names and transactions.
We use Third Party Servicers to access, process, and collect information about the Company’s healthcare claims data. Any time you link your data, we may receive data and information associated with your claims, for example, Claim IDs and Patient names.
De-Identified Data
“Personal Information” is any information that can be used to identify you. We may de-identify Personal Information so that it can no longer be used to identify you or your device ("De-Identified Information"). Please note that this Privacy Policy does not apply to De-Identified Information, and we may use and disclose De-Identified Information for any purposes in our discretion.
How We Collect Information
One of the ways we collect information is directly from you. If opening a bank account with Anatomy, you may be required to provide certain information about yourself and the business you are opening the Anatomy Account for.
We collect this information: through documentation you provide to us; during telephone calls or emails with you or Third Party Servicers; through the access provided to you on our websites and/or applications; in research using Third Party Servicers and in our ongoing communications with you or your business’ employees or associated persons. We may also collect your Personal Information from individuals who are listed as associated with your Anatomy Account, public sources, and other reporting organizations or exchanges that serve the financial services industries.
In other cases, your Personal Information may be provided to Anatomy indirectly, such as the IP address of the computer or device you use to connect with us online or by a Third Party Servicer from whom you seek to obtain services or are obtaining services.
How We Use Your Information
Anatomy processes your Personal Information for our operations, customer service, legal and marketing, for example:
- Onboarding activities and certain applications within the Anatomy Service;
- Maintain, provide, and improve our products and services;
- Help us better understand user interests and needs, and customize the Anatomy Service;
- Analyze and research how you interact with our Site and the Anatomy Service;
- Facilitate reporting and analyze performance of the Anatomy Service;
- Identifying, troubleshooting, and fixing bugs and errors;
- Survey your opinions through customer feedback;
- To advertise or market the Anatomy Service to you. You have the ability to unsubscribe from promotional communications at any time;
- Help identify and troubleshoot any issues with your account and answer your questions;
- Resolve support requests;
- Legal and security reasons to protect Anatomy and you;
- Investigate alleged violations of our legal terms;
- Comply in with a valid legal subpoena, request, or other lawful process;
- Communicate with you by phone, text, email, or chat;
- To provide important notices and updates, product changes, and other necessary notices such as security and fraud alerts; and/or
- Respond to your requests for information.
Disclosure Of Your Information
Anatomy may disclose your information to third parties in the following circumstances:
Disclosure by Law: Protection of Anatomy and Others. By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Anatomy, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Disclosure to Business Partners: We may share your information with our business partners to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience. We are not responsible for the privacy practices of our business partners.
Service Providers: In the course of doing business, we employ other companies and individuals to provide us services across our business, for example, data storage or marketing. These service providers may have access to information about you if it is needed to perform their services and are prohibited from using your information for other purposes. It is our policy to limit their use of your information to perform those services on our behalf.
Business Transfers: We may share your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of our business to such business entities. We will require any such successor business entity to honor the terms of this privacy policy.
By supplying your Personal Information to Anatomy either directly or indirectly, you consent to your information being transferred across international borders to Anatomy and its affiliates, Third Party Servicers, and agents. Vendors and other outside contractors we engage are subject to our contractual requirements for safeguarding Personal Information.
Information Security
At Anatomy, security is a priority. We use certain physical, organizational, and technical safeguards that are designed to protect Personal Information submitted to us, and we employ appropriate measures, including advanced technology, to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. These measures may include, among others, administrative security measures, data encryption, firewalls, and other appropriate technologies. Anatomy reviews and enhances its security systems as necessary.
Notwithstanding Anatomy’s efforts, no security measure is perfect or impenetrable and no method of transmission over the internet or electronic storage is 100% secure. Therefore, Anatomy cannot guarantee complete security of the transmission or storage of your Personal Information. It is important that you maintain the security and control of your account credentials, and not share your password with anyone. We ask our customers to use multi-factor authentication to protect their data and accounts.
Log Files
Any time you visit any of our Websites, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user's session. This gives us an idea of which parts of our site users are visiting.
Cookies & Web Beacons
We use "cookies" to keep track of some types of information while you are visiting our Website or using our services. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to our Website and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track user trends. We rely on cookies for the proper operation of our Website; therefore if your browser is set to reject all cookies, the Website may not function properly. Users who refuse cookies assume all responsibility for any resulting loss of functionality. "Web beacons" (also known as "clear gifs" and "pixel tags") are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our Website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers. By using the Services, you agree to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Policy.
Emails and Telephone Calls
We require an email address from you when you register for our services. We use your email for both transactional and promotional purposes. E-mail messages we send you may contain code that enables our database to track your usage of the emails, including whether the email was opened and what links (if any) were clicked. We reserve the right to send you certain communications relating to our services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. We may also contact you by telephone or text message in connection with our services. If you would rather not receive telephone calls or text messages from us, you may change or delete your number from your account preferences page(s), or ask to be removed from our contact list if you receive a call or text message from us. We fully comply with the requirements of the U.S. CAN-SPAM Act.
Linked Third Party Websites
As a convenience to you, this Website may contain links to other sites that we believe may offer useful information. The terms of usage and other conditions of use posted on those sites, and not the policies and procedures we described here, apply to those sites. Your linking to any other websites is at your own risk, and you are responsible for learning about and complying with the terms of usage and other conditions posted on those websites.
Your Rights and Choices
Depending on your jurisdiction of residence, and subject to applicable legal exceptions, you may be able to ask us to take action on a variety of privacy issues such as, providing access to certain information we hold about you and asking us to update or delete that information. If you request these rights, we will need to verify your identity and your relationship with us for security. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include complying with a legal obligation.
Notice of Right to Opt Out of Sales of Personal Information and Sharing/Processing of Personal Information for Targeted Advertising Purposes
As explained in detail in the "Cookies & Web Beacons" section above, we allow third-party vendors to collect information from your device and online browsing activities for online targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding the Anatomy Service. The disclosure of your information to these third parties to assist us in providing these services may be considered a “sale” of Personal Information under applicable law or the processing/sharing of Personal Information for targeted advertising purposes.
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your Personal Information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” for purposes of targeted advertising, please email the email address below.
Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Usage under the age of 13
Anatomy is intended for business use only and is not directed at persons under the age of 13. If you are a parent or guardian and believe we may have collected information about a person under the age of 13, please contact us at the email address below. If we determine that we have inadvertently collected Personal Information from a person under the age of 13, we will promptly delete such information from our records to the extent permitted by applicable law.
Retention of Your Information
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
Changes To This Privacy Policy.
The "Last Updated" date at the top of this page indicates when this Policy was last revised. From time to time, Anatomy may make changes to this Policy, so we encourage you to check back and review it regularly to ensure you are aware of current practices. Changes will be communicated through the Website or through your Anatomy Service account. Your continued use of the Anatomy Service and/or the Website following the effective date of any change, constitutes your consent to any modification to this Policy.
Contact Us
If you have any questions about this Policy, or you want to make a complaint regarding any breach of your privacy by us, or you want to correct or update your Personal Information in our possession, or you want to opt-out of any of the sharing mentioned above, you may contact us by email at privacy@anatomy.com.