PRIVACY POLICY

Last Updated: November 22, 2022

Treasury Interactive Inc. (“ Treasury ,” “ we ,” “ us ,” or “ our ”) welcomes you.  Treasury provides services and related content through our website located at https://treasury.app (the “Website”) and our proprietary communications and informational platform (the “Platform,” and together with the Website, the “Services”)  subject to the following privacy policy (the “ Privacy Policy ”), which may be updated by us from time to time without notice to you.  By accepting this Privacy Policy, accessing or using the Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Service , which together make up the Agreement. This Privacy Policy explains what personal information we collect, how we use and share that information, and your choices concerning our information practices. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Services.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Service.

THE INFORMATION WE COLLECT AND HOW WE USE IT

 

We do not sell, rent, or lease your personal information to third parties. In the course of operating the Services, Treasury collects or receives the following types of information from you, which may include personal information.

Profile 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.

Activity Information

The Services are designed to allow Users to access Content, link financial accounts via Plaid, and make investments using their linked financial accounts. Users may post, comment on and react to such Content or join a interactive finance course or investment club and view certain Content related to such course or club through the Services. To access and use our Services, Users may 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.

By using our Services, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy available at: https://plaid.com/legal/#end-user-privacy-policy .

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.

Server Logs

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.

Cookies

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.

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

We use one or more third–party analytics services to evaluate your use of the Services, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Services you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

 

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  

Aggregate Data

In an ongoing effort to better understand our Users and the Services, we might analyze your information, including your financial activity information 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  

Business Transfers

In the event of a merger, dissolution, bankruptcy, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger, the acquiring entity, or our creditors. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Treasury and its legal successors-in-interest.

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 privacy@treasury.app 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 privacy@treasury.app.

HOW WE PROTECT YOUR INFORMATION

Treasury takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet.  In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

CHILDREN

We do not knowingly collect personal information from children under the age of 13 through the Services. If you are under 13, please do not give us any personal information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission.  If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@treasury.app, and we will endeavor to delete that information from our databases.

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 privacy@treasury.app.

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 privacy@treasury.app 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

The Services may contain links to third-party websites (“ External Sites ”). Treasury has no control over the privacy practices or the content of any such External Sites.  As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting any such External Sites.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time with or without notice to you. By accessing the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information.  Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Policy, please e-mail us at privacy@treasury.app with “Privacy Policy” in the subject line.

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