Last Updated 3/30/23
This Site is designed and intended to be used by adult persons at least twenty-one (21) years of age. If you are not 21 years old or older, please leave this Site immediately.
We do not, and without your consent will not sell, lease, or rent your information to third parties for monetary or other valuable consideration. You may exercise your right to be forgotten at any time by contacting us here [email protected].
We may use analytics software to improve our Users’ experience with the Site such as “Google Analytics.” This software may use or collect non-personal activity such as what pages a User viewed or how long a User viewed a page, the type of personal device a User used to access the Site, or some general geolocation information. No personal or identifiable information is used or collected by analytics software.
We collect categories of personal data and information, the general purposes of which, include these (we sometimes refer to the personal data and information we collect as “Personal Data”):
Personal Data You Provide: Generally this data or information establishes your account, method/means of identifying institutions in your personal financial network, and potentially also your methods and means of payment, services and other data related to our relationship with you.
You may share this Personal Data when you visit the Site, register to use the Service, in connection with your use of the Service, and in other instances where you may provide it to us. The Personal Data collected during these interactions may vary based on what you choose to share with us and generally will fall into the categories described below.
User Data. It includes but may not be limited to this information:
Administrative Data. This information may include device and system information, product license information, and/or usage and preference information including how you want us to communicate with you. This data helps us to understand and best serve your expectations, needs, interests and requirements.
Security Data. This data may include specifics about your financial accounts or transactions, location data and other information you provide to organize your personal financial network. Any data we collect is stored in secure systems. Our Site is running on a secure, encrypted network, so your data is safe during transmission. We encourage you to use complex passwords or other unique credentials to access the Site and we discourage you from sharing your unique credentials with other persons.
Diagnostic Information. If and as you use our Services and platform we may capture and preserve application crash reports, information you share regarding your customer experience as necessary to troubleshoot any malfunctioning Services. For example, when you call, in message, chat, email, or otherwise communicate with us, we may retain and review recordings and records and the contents of the communications as required or permitted by law and our recording and information management policies.
Data We Receive Automatically From Your Use of the Service: When you visit, use or interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Google Chrome, Microsoft Internet Explorer, etc.), and geographical location information. In particular, the following information may be created and automatically logged in our systems:
Your Choices: On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off or otherwise manage them. Company has no control over your choice of browser or the policies and practices of the browser companies. Please assure you review any browser companies’ own policies and procedures. For your convenience here are links to a number of browser companies where you can review the policies and procedures each has:
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Service and the choices you make about setting cookies may have an impact on the scope of functions associated with features of the Service you are able to access.
If you access the Service on your mobile device, the configuration of the applications or technology on your mobile device may, through no control of Company, limit your opportunities to control tracking, advertising or other settings.
Consistent with applicable law and choices and controls that may be available to you, we may use all or some of the Personal Data we collect from you or from devices associated with you, for purposes including the following:
Marketing. By providing your contact information to us you are giving us permission to use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving marketing emails at any time by following the instructions contained in each promotional email we send you. You can also change your permissions regarding marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. Please understand that any changes in your communication preferences will take effect prospectively and will be processed within a reasonable timeframe after you contact us to notify us regarding a change. We may use a third party resource to email you from time to time such as MailChimp and we encourage you to review Mail Chimp’s privacy practices and data security standards.
Our platform is designed to facilitate communications between you and financial institutions you tell us about that are in your personal financial network. Accordingly, we will share your Personal Data with those financial institutions in accordance with your use of our Service, including to facilitate payments from you to such financial institutions. In certain circumstances we may share your Personal Data with third parties, subject to applicable laws, as set forth below:
Please log in to your account or contact us if you need to change or correct your Personal Data.
Our Service is not directed to children who are under the age of 18. Company does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Service please contact us and we will endeavor to delete that information from our databases.
You use the Service at your own risk. We implement reasonable technical, administrative, and organizational measures designed to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites. You must contact us if you suspect any information or the Service has been misused or if you notice anything suspicious happening while you use the Service.
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to verify your age, identity or to use some features of our Service, those features of our Services may be unavailable to you. You can also contact us to ask us any questions, make recommendations, or to seek assistance in updating or correcting your Personal Data.
Notice to California Residents: If you are a California resident, you may have certain additional privacy rights that are described in more detail here [make hyperlink]
Special notice for California residents:
Effective January 1, 2020, the CCPA allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information.
We do not sell your personal information.
We disclose personal information for business purposes.
From businesses that disclose personal information for a business purpose, you have the right to request:
(1) The categories of personal information that the business collected about you; and
(2) The categories of personal information that the business disclosed about you for a business purpose.
The right to request the business to delete the personal information it has collected from you, subject to certain legal exceptions, for example, when the personal information is necessary to complete a transaction for which we collected it or to comply with a legal obligation.
The right to be protected from discrimination for exercising your CCPA rights. Businesses are prohibited from discriminating against you for exercising your rights under the statute, including by: (A) denying you goods or services; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price, rate, level, or quality of goods or services. Nothing prohibits a business from charging a different price or providing a different level or quality of service if the difference is reasonably related to the value provided to the consumer by the consumer’s data.
Submitting a Request
To submit a request under the CCPA, please contact [email protected]. You may be asked to verify your identity in order for us to process your request, including by:
If you are using an authorized agent to submit a request on your behalf, we ask that you:
To protect your privacy, your request may be denied if we are unable to verify your identity, or your agent’s authorization to act on your behalf.
Please note that Company may comply with CCPA through one or more legal exemptions applicable to certain types of personal information.
Additional Disclosures Under the CCPA
List of categories of personal information collected about consumers and disclosed for a business purpose (we explain below what “business purpose means):
Business purpose(s) when used here means and can include such things as these: providing our Services, maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, performing analytics and quality control, auditing transactions, researching and testing features and improvements, detecting and preventing fraud and security incidents, debugging or repairing technical errors, and marketing our Services.
For additional information on any of the above or if you wish to exercise one or more of your rights under the CCPA, please contact [email protected]
Please know that as you browse our website we may collect information about you and the pages you view through cookies and web beacons. You can opt out through your browser, but then you may not have access to all the functions of our website.