Last updated: February 16, 2023
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.
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.
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
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://mixpanel.com/optout/. 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.
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
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
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling, and other similar purposes.
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.
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
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 Information Protection and Electronic Documents Act (“PIPEDA”).
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:
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.
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 [email protected]. 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.
PocketGuard does not keep personal data any longer than is necessary for the purposes for which it is being processed.
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.
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.
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
Responding to Do Not Track Signals
Our Site 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.
Links to Other Sites
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.