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Privacy Policy

Last updated: September 6, 2023

Welcome to PocketGuard, Inc. (collectively, “PocketGuard”, “we”, “us”, or “our”). This Privacy Policy explains our practices regarding the collection, use, and disclosure of information that we receive through our website located at https://pocketguard.com/ (the “Website”) and our services accessible via our downloadable applications (“App”) (together, the “Services”). This Privacy Policy explains how we collect, protect, use, and share information that identifies, relates to, or could be reasonably linked, directly or indirectly, with a particular identified or identifiable natural person or household (“Personal Information”).

By using or submitting information through the Services, you are indicating that you agree to be bound by the terms of this Privacy Policy. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use. So, please make sure that you have read and understand our Terms of Use.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services, and we’ll update the “Last Updated” date above to indicate when those changes will become effective.

Information Collected or Received from You

When you use the Services, we may collect Personal Information and other information from you as further described below.

PocketGuard Account Information

If you create a PocketGuard Account, we’ll collect certain information that can be used to identify you, such as your name, email address, postal address, and phone number, which is Personal Information. If you choose to utilize your Apple, Google, or LinkedIn account for authentication during the registration process, please be aware that we may also collect your account ID on the respective platform for verification purposes.

Bank Account Information

If you want to link a bank account that you hold with a financial institution (“Bank Account”) to your PocketGuard Account, we will collect certain information from you about your Bank Account, such as your online login credentials, for the purposes of providing the Services to you. If you give us access to your Bank Account, you acknowledge and agree that we will have access to your transaction information, amount of funds, and other information about you and your Bank Account that may be available through the online settings for your Bank Account or otherwise through the relevant financial institution (“Financial Information”) that we require in order to provide the Services to you. You also may upload bank statements in .csv format in order to access your Bank Account’s transaction history. Another feature you can use in your account is to attach a picture of a bill or any other image to your transaction. By doing so, you consent to the storage and processing of uploaded information and images by PocketGuard.

Verification Information

For compliance purposes and in order to provide the Services to you, we may obtain from you or from third-party documentation that helps us to verify your identity and Bank Account details. For example, we may ask you to provide a copy of your government-issued photo ID, a copy of a utility bill or bank statement, or such other documentation that contains Personal Information. We may also obtain information about you from the financial institution providing your Bank Account.

Third-Party Web Beacons and Third Party Buttons

We may also implement third-party content, or advertising on the Service that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third-party content on the Service. Additionally, we may implement third-party buttons (such as Facebook “like” or “share” buttons) that may allow such third party to collect information about you through such third party’s browser cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by the third party, and PocketGuard does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

Information from Other Sources

We may also obtain information, including personally identifiable information, from third parties and sources other than the Service, such as our partners or advertisers. We may also, at your direction, receive information from third-party services that provide a mechanism to expose information you have provided to such third parties through the use of an application program interface (API), such as Google API, Facebook API, or Apple API. If we combine or associate information from other sources with personally identifiable information that we collect through the Service, we will treat the combined information as personally identifiable information in accordance with this Privacy Policy.

Information Related to the Use of the Services

Our servers automatically record certain information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used. We may use third-party data collection tools such as Mixpanel to provide us with analytics data regarding Users’ interactions with our Services. You may opt out of Mixpanel’s automatic retention of data collected while using the Services by visiting https://docs.mixpanel.com/docs/tracking/how-tos/privacy-friendly-tracking. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device.

Information Sent by Your Mobile Device

We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings, and the operating system of your device, as well as information about your use of our Services.

Location Information

When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

How We Use Information

Our primary goals in collecting information are to provide you with a secure, smooth, and customized experience, to administer your use of the Services, to fulfill or meet the reason you provided the information, and to enable you to enjoy and easily navigate our Services. For example, we may use your information to verify your identity, allow you to register with PocketGuard, improve the content in the App, provide notices, communicate with you via text message or email, monitor against fraud, or provide customer support at your request, when you permit Advisor access to your information, this information may be used by your financial advisor to provide you with financial services or analyze it.

Information that We Share with Third Parties

We will not share any User Information that we have collected from or regarding you except as described below.

Information Shared with Your Financial Advisor

If you registered the account via the invitation link provided by your Advisor and granted access to your information to them, this Advisor also has access to your Personal Information and Financial Information subject to your permission. This Personal Information and Financial Information will be used by your Advisor, in conjunction with our Services, to analyze information and provide customized financial services to you. Your Advisor’s use of your information is governed by their privacy policy or other applicable document provided by your Advisor to you which regulates the usage of your Personal Information and Financial Information. Please contact your financial advisor if you have questions about their privacy policy or other applicable privacy documents.

Information Shared with Our Services Providers

We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to your Personal Information and Financial Information only for the purpose of performing services on our behalf.

Information Shared with our Marketing Partners

We will never share your Financial Information with our marketing partners without your express consent, but we may use your Financial Information to generate offers for financial products and services from our marketing partners that may be of interest to you. It is always your choice whether or not to apply for an offered product or service and we will never submit an application for a financial product or service on your behalf without your express consent. If you choose to pursue any of the offers that the Services present to you, you will be asked if you would like the Services to pass on your Personal Information and relevant Financial Information to the third-party marketing partner as a convenience. For example, if the Services generate an offer from a third-party loan provider for you, the Services will give you the option of moving forward with that offer within the App, and if you agree to do so, the Services will pass your Personal Information and relevant Financial Information to that third party loan provider to speed up the process of your application.

Information Shared with Other Third Parties. Aggregated and De-identified Information.

We may create aggregated, de-identified, or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and disclose, share, or sell to third parties for our lawful business purposes or any other purposes, determined in our discretion, unless otherwise prohibited by applicable law, including but not limited to analyzing, building, and improving the Services and promoting our business, provided that we will not disclose such data in a manner that could identify you.

Neither Aggregated Information nor De-identified Information (defined below) is personal information.

“Aggregated Information” refers to information about a group of individuals from which the personally identifiable information has been removed so that such information can no longer be linked to you or your device. For example, the statistics of how many people purchased our Premium Subscription last month.

“De-identified Information” means information subjected to reasonable measures to ensure that the de-identified information cannot be associated with the individual. For example, instead of using real names, user profiles are replaced with unique, artificial codes or pseudonyms, making it impossible to link the data back to a specific individual. We maintain De-identified information in a de-identified form and do not attempt to re-identify it, except that we may attempt to re-identify the information just to determine whether our de-identification processes function correctly. We prohibit vendors, by contract, from attempting to re-identify our De-identified Information.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate:

to respond to claims, and legal processes (including subpoenas);
to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general;
to stop any activity that we consider illegal, unethical or legally actionable activity.

Pass-Through Requirements

PocketGuard may use services of certain third parties that may require additional pass-through terms such as the Salt Edge Privacy Policy. PocketGuard agrees to include and abide by such Privacy Policies as part of these Terms.

We encourage you to read the Salt Edge Privacy Policy.

California Privacy Rights

California residents may seek disclosures as to the categories or specific pieces of Personal Information PocketGuard collects, processes, and stores about them, and may contact us regarding their rights to access and request deletion of their Personal Information. Please refer to the California Consumer Privacy Act (CCPA) Privacy Notice for further information.

Canada Privacy Rights

PocketGuard operates in Canada and has Canadian users, which results in the collection and processing of Canadian residents’ Personal Information in the same ways as described above. PocketGuard takes seriously its obligations to protect such personal information and to comply with Canada’s Personal

Before PocketGuard engages in the collection, use, and/or disclosure of Personal Information, it obtains consent from you. When you use Services, you give us consent to collect Personal Information.

Personal information shall be kept only as long as it remains necessary or relevant for the identified purposes or as required by law. When this Personal Information is no longer required, it shall be destroyed, erased, or made anonymous pursuant to the requirements of PIPEDA.

Personal information will be as accurate, complete, and up-to-date as is reasonably possible and as is necessary for the purposes for which it is to be used.

Any questions, user’s requests to obtain access to Personal Information, or concerns regarding the handling of Personal Information under Canada’s PIPEDA, or related to revocation of consent to collect, process, transfer, or disclose their personal information should be directed by email to PocketGuard’s Privacy Officer:

privacy@pocketguard.com

All communications to PocketGuard should include the user’s name and contact information (such as e-mail address, phone number, or mailing address), and a detailed explanation of the request. PocketGuard will endeavor to respond to all reasonable requests in a timely manner and, in any case, within any time limits prescribed by applicable local law.

Privacy Rights for Residents of European Countries

If you are located in the European Economic Area, the United Kingdom, or Switzerland (the “European Countries”), you have certain rights and protections under Regulation (EU) 2016/679 (General Data Protection Regulation) and The United Kingdom General Data Protection Regulation (UK-GDPR) regarding the processing of your “personal data” as defined under applicable law. Some of the information that PocketGuard collects from you through its operation of the Service may constitute “personal data” under these laws.

Legal Basis for processing personal information

If you reside in European Countries, we will normally collect personal information from you (1) where we need the personal information to enter into or perform a contract with you, (2) where we have your consent to do so, (3) where the personal information is needed to comply with a legal obligation or requirement, or (4) where the processing is in our legitimate interests or the legitimate interests of others, and not overridden by your rights. These legitimate interests may include the operation, maintenance, and improvement of our products, platform, and services, offering a more tailored, personalized, and efficient service for our users, communication with you as necessary to provide our services to you, fraud prevention and network and information security and detecting or preventing illegal activities. We may have other legitimate interests, and if we believe it is appropriate, we will inform you of what they are.

Privacy Rights

As a resident of the European Countries, among other rights, you have the following data protection rights:

The right to access, correct, update or request deletion of your personal information.

The right to object to the processing of your personal information; ask us to restrict the processing of your personal information or request portability of your personal information.

The right to opt-out of marketing communications we send you at any time.

The right to withdraw your consent at any time if we have collected and processed your personal information with your consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.

You may also request additional information about: the purpose of the processing; the categories of personal data concerned; who else outside PocketGuard might have received the data from PocketGuard; what the source of the information was; and how long it will be stored.

If you wish to exercise any of these rights, please contact us here at privacy@pocketguard.com. We may ask you to verify your identity or ask for more information about your request.

Please note that any changes you requested will be reflected in active user databases instantly or within a reasonable period of time. PocketGuard will process your requests as soon as possible but not later than 45 days from the day of receipt. If it will be necessary, we will also notify you and a relevant supervisory authority within 72 hours of a breach related to your personal information that we hold.

WARNING! Please exercise your rights wisely and note that abuse of rights may entail your liability.

Data Retention

PocketGuard does not keep personal data any longer than is necessary for the purposes for which it is being processed.

Transfer

For transfers of personal information to countries outside the EU, we rely on the European Commission’s adequacy decisions https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en and their Standard Contractual Clauses, available here.

For transfers of personal information to countries outside the UK, we rely on adequacy regulations under section 17A of the 2018 Act and standard data protection clauses specified in regulations made by the Secretary of State under section 17C of the 2018 Act, available here https://ico.org.uk/media/for-organisations/documents/4019539/international-data-transfer-addendum.pdf.

Your Choices

We offer you choices regarding the collection, use, and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.

Opt-Out

We may periodically send you free newsletters, emails, and notifications on your mobile device that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt out” (either through your PocketGuard Account or by following the unsubscribe instructions provided in the email you receive). We do need to send you certain communications regarding the Services and you will not be able to opt-out of those communications.

Modifying Your Information

You can access and modify the Personal Information associated with your PocketGuard Account, including your name, address, and Bank Account details, through your PocketGuard Account settings in the App. If you want us to delete your Personal Information and your PocketGuard Account, please contact us via email at support@pocketguard.com with your request. You may delete the User Information associated with your PocketGuard Account by deactivating your account in the App. We’ll take steps to delete your information as soon we can from our servers, but some information may remain in archived/backup copies for our records, with third parties to whom it has been passed as permitted by this Privacy Policy, or as otherwise required by law.

Responding to Do Not Track Signals

Our Website does not have the capability to respond to “Do Not Track” signals received from various web browsers.

The Security of Your Information

We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use, or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. You can read more about technical and organizational measures we use when processing your Personal Information in the relevant section on our Website.

Links to Other Websites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

International Transfer

Your Personal Information may be transferred to and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.

Our Policy Toward Minors

Our Services are not directed to minors under 16 and we do not knowingly collect Personal Information from minors under 16. If we learn that we have collected the Personal Information of a minor under 16 we will take steps to delete such information from our files as soon as possible.