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Till Financial’s Privacy Notice

Last updated 25 March 2020


Till Financial, Inc. (“Till,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. Through our mobile application (the “App”), we give families tools to teach young people to spend, save, and invest more intelligently by allowing them to set financial goals and move money across accounts (such services, including https://tillfinancial.io/ (the “Site”) and the App, are referred to collectively in this Privacy Policy as the “Service”).

This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.

Before using the Service or submitting any Personal Data to Till, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

1. WHAT INFORMATION DO WE COLLECT?

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

Personal Data You Provide: We collect Personal Data when you create an account, interact with the Service, and communicate with us. The Personal Data collected during these interactions may vary based on who you are (i.e., whether you are the owner/administrator of an account, the beneficiary, or a community member) and what you choose to share with us, but it will generally include your name, email address, and phone number. If you are an account owner/administrator, we will also collect your address, date of birth, and Social Security number. You may also provide additional information in the course of signing up for and using the Service, such as bank account details for the funding account and logon credentials. This additional information is maintained by third-party service providers described below.

Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Instagram, Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Personal Data We Receive Automatically From Your Use of the Service: When you visit, use, and interact with the Service, we automatically 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., Chrome, Firefox, Microsoft Internet Explorer, etc.), generalized estimates of location derived from IP addresses, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

  • Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your IP address, browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
  • Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
  • Transaction Data: We collect information relating to transactions associated with accounts you link to the Service, such as the amount, location, type, date, and time of the transactions.
  • Location Data: If you give the App permission to access your location, we may collect your location information through the App using WiFi, Bluetooth, and the GPS coordinates (e.g. latitude/longitude) of your mobile device and store the resulting history. With your permission, we may collect your device’s location even if you are not using the Service. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the App’s access to your location data.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

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. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

  • Internet Explorer
  • Mozilla Firefox
  • Google Chrome
  • Apple Safari

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

Email Pixels: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site [and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

2. HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:

  • To provide the Service and help families teach financial skills to young people;
  • To respond to your inquiries, comments, feedback, or questions;
  • To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
  • To analyze how you interact with our Service;
  • To maintain and improve the content and functionality of the Service;
  • To develop new products and services;
  • To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Data to tell you about products or services we believe may be of interest to you. For instance, we may analyze your Personal Data to show you relevant advertisements within the App (such as a discounted offer from a bike shop if we know the beneficiary associated with an account is saving money to purchase a bicycle). In addition, 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 emails by following the instructions contained in each promotional email we send you. You can also control the 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.

3. SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of [hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services]. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is the longer.

5. UPDATE YOUR INFORMATION

Please log in to your account or contact us if you need to change or correct your Personal Data.

6. CHILDREN

Our Service is available to and used by children who are under the age of 13. After obtaining verifiable parental consent, we collect, use and share Personal Data relating to such children as described in the “Personal Data We Collect,” “How We Use Personal Data,” and “Sharing and Disclosure of Personal Data” sections of this Privacy Policy.

The following third parties may collect, receive, or maintain Personal Data from children in connection with the operation of the Service:

  • Auth0 Inc.
  • Twilio, Inc.
  • Plaid, Inc.
  • Amazon Web Services, Inc.

Please contact us if you have questions about these third parties’ data practices.

In addition, parents or guardians can contact us to:

  • request copies of the Personal Data we collected about their child;
  • direct us to delete the Personal Data we collected about their child;
  • direct us to stop collecting or using Personal Data regarding their child; and
  • prohibit the disclosure of Personal Data regarding their child to third parties not needed to provide the Service.

7. LINKS TO OTHER WEBSITES

The Service may contain links to other websites not operated or controlled by Till, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures 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 Till 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.

9. YOUR CHOICES

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.

10. CHANGES TO THE PRIVACY POLICY

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

11. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@tillfinancial.io.

PRIVACY NOTICE

FACTSWHAT DOES TILL FINANCIAL, INC. ("TILL") DO WITH YOUR PERSONAL INFORMATION?
Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number and account balances
  • Transaction history and overdraft history
  • Account transactions and checking account information

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Till chooses to share; and whether you can limit this sharing.

Reasons we can share your personal informationDoes Till share?Can you limit this sharing?

For our everyday business purposes
such as to process your transactions, maintain
your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates' everyday business purposes — information about your transactions and experiences

No

We don't share

For our affiliates' everyday business purposes — information about your creditworthiness

No

We don't share

For our affiliates to market to you

No

We don't share

For nonaffiliates to market to you

No

We don't share

Questions?

Go to https://tillfinancial.io.

Who we are?

Who is providing this notice?

This notice is being provided on behalf of Till Financial, Inc.

What we do

How does Till protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Till collect my personal information?

We collect your personal information, for example, when you

  • Open an account or provide account information
  • Give us your contact information or invite others to join your account
  • Use the service

We also collect your personal information from other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only

  • sharing for affiliates' everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Till has no affiliates.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Till does not share with nonaffiliates so they can market to you.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Our joint marketing activities involve credit card companies and banking partners.
Other important information

California Residents Only: We will not share information we collect about you with nonaffiliates, except as permitted by law, including, for example, with your consent or to provide financial services you have requested.