Last Updated: January 4th, 2021
THE INFORMATION WE COLLECT AND HOW WE USE IT
In the course of operating the Services, Treasury collects or receives the following types of information from you, which may include personal information.
We collect profile information on our Services; profile information typically includes your name, email address, phone number, and profile picture (collectively, “ Profile Information ”). We use such information for purposes such as registering you for an account on the Platform, providing you with information about the Services, responding to your inquiries, sending you email and text alerts (including marketing emails and text messages), or providing you the Services.
Our Platform enables you to receive daily reports regarding your financial activity that you may choose to share with others. To access and use our Services, Users will be required to link their Treasury Account to their bank account(s) through our integration with Plaid Technologies, Inc. (“ Plaid ”). When you enable the Plaid integration to connect us to your bank account(s), Treasury will receive certain financial information, including the name of your bank(s), and the withdrawals and deposits made through the bank account(s) connected to your Treasury account; we will not have access to your bank account login credentials, bank account number, credit card number, activation code, or other similar information. Every day we will provide you a report (“ Report ”) summarizing your bank account transactions for the day, including the amount of each transaction and the relevant third-party depositing or receiving the transaction amount (“ Financial Activity Information ”).
Additionally, we will receive any information you provide in messages to us. We will use this information to respond to your inquiries, and to the extent you provide us feedback, to improve, develop, and market our Services.
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Services or the pages you’ve clicked on while on our Services). We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.
We collect information using “cookie” technology and other similar technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We use both first- and third-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.
- Session Cookies : We use session cookies to make it easier for you to navigate our Services. A session ID cookie expires when you close your browser.
- Persistent Cookies : A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Services, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Services.
In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Services (e.g., email open rates, URL click-throughs).
If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies or similar technologies from us, certain aspects of the Services may not function properly or as intended.
Third-Party Analytics Providers
For Google Analytics, please visit: https://support.google.com/analytics/answer/6004245?hl=en and https://tools.google.com/dlpage/gaoptout
For Amplitude, please visit: https://amplitude.com/privacy
In an ongoing effort to better understand our Users and the Services, we might analyze your information, including Financial Activity Information, Reports, and User Content, in aggregate form to operate, maintain, manage, and improve the Services, and for other lawful purposes (collectively, “ Aggregate Data ”). This Aggregate Data does not identify you personally. We may share this Aggregate Data with our affiliates, agents, and business partners. We may also disclose Aggregate Data in order to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
- Like many businesses, we hire other companies to perform certain business-related services. The types of companies that may receive personal information and their functions are: hosting services, technical assistance, database management/back-up services, use analytics, advertising/remarketing, email marketing platforms, and customer service. We may also share your personal information with Plaid, and Plaid may request additional personal information from you to connect to your bank accounts.
- In order to provide our Services and administer promotional programs, we may share your personal information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
- We may, from time to time, share and/or license personal information to other companies who may provide you information about the products and services they or their partners offer. However, to the extent required by law, you will be given the opportunity to opt out of such sharing.
Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
OPT-OUT FOR DIRECT MARKETING; EMAIL MANAGEMENT
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to firstname.lastname@example.org or by clicking on the “Unsubscribe” link located on the bottom of any Treasury marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Services.
Additionally, you may opt out of receiving text messages from us at any time by replying STOP in any text message conversation with us or by emailing your request to email@example.com.
HOW WE PROTECT YOUR INFORMATION
IMPORTANT NOTICE TO ALL NON-US RESIDENTS
Our servers are located in the US. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Services, you do so at your own risk.
CALIFORNIA PRIVACY RIGHTS
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Treasury via email at firstname.lastname@example.org.
DO NOT TRACK
Treasury does not respond to “Do Not Track” settings or other related mechanisms at this time.
NEVADA PRIVACY RIGHTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
LINKS TO EXTERNAL WEBSITES
HOW TO CONTACT US