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Blackwing

Fintech products collect financial data that carries its own rules, and your bank partners will expect your privacy terms to match theirs. We draft GLBA-aware privacy notices and the contract terms that govern how account and transaction data moves between you, your bank and your vendors. Each engagement is a flat fee, quoted before we start.

At a glance

Practice
Fintech
Pricing
Flat fee, quoted before we start
Included
6 deliverables
Process
3 steps, one named attorney
Where we work
Slack, email or a call

When founders call us

The moments that usually bring a company to us for this work.

  1. 01

    Your sponsor bank asks for your consumer privacy notice during onboarding diligence

  2. 02

    You are connecting to bank accounts through a data aggregator and need its terms reviewed

  3. 03

    An enterprise customer wants to use your transaction data for analytics or model training

  4. 04

    You are launching to consumers and your general website privacy policy does not mention financial data

What you get

Scoped in writing before we start. One flat fee for all of it.

  1. GLBA-aware consumer privacy notice aligned with your actual data sharing
  2. Data use and sharing clauses for bank program and processor agreements
  3. Review of data aggregator and open banking access terms
  4. Customer-facing consent language for account linking and data use
  5. Safeguards-related contract provisions for vendors that handle customer financial data
  6. Short memo on where GLBA, state privacy law and your contracts overlap for your product

How it works

  1. 1

    Inventory the data

    We work from a short questionnaire on what you collect, from whom and who receives it.

  2. 2

    Draft the documents

    We prepare the notice, consent language and contract clauses as one consistent set.

  3. 3

    Align with partners

    We reconcile your documents with your bank's and vendors' requirements and finalize.

Mistakes we help you avoid

The ones we see most often, and catch before they cost you.

  • Avoided

    Publishing a privacy notice that promises less sharing than your bank or vendors actually receive

  • Avoided

    Assuming a general website privacy policy satisfies GLBA notice expectations for consumer financial products

  • Avoided

    Granting customers or partners broad data rights that conflict with your bank program agreement

  • Avoided

    Leaving vendor contracts silent on safeguards and incident notice for customer financial data

Data & Privacy for Fintech: questions founders ask

GLBA can reach non-bank companies that are significantly engaged in financial activities, which covers many fintech products. Whether and how it applies depends on what you offer and to whom. When it does, it brings privacy notice requirements and, for many non-banks, the FTC Safeguards Rule.

A website privacy policy describes data practices across your site and service generally. A GLBA privacy notice is a specific disclosure to consumers about how their nonpublic personal financial information is shared, including opt-out rights where they apply. Many fintechs need both, and they need to be consistent.

Possibly, but it depends on your privacy notice, your consents, your bank program agreement and any data aggregator terms. Each of those can restrict secondary use. We review the chain of permissions and draft language that matches what you intend to do.

No. We draft and negotiate the legal documents and contract terms around data handling. Security assessments and audits are done by technical assessors, and we can align your contracts with their findings.

Get a flat-fee quote for Data & Privacy for Fintech.

A short call with an attorney. You leave with a written scope and one fixed price.

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Attorney advertising. The information on this site is general and is not legal advice. Contacting Blackwing or using this site does not create an attorney-client relationship. Prior results do not guarantee a similar outcome.