Privacy Policy

Collection of Personal Information

We use reasonable measures to maintain the security of your Personal Information. However, no company, organization, or online community, including the Company or the App, can fully eliminate security risks associated with personal information.

1. Information You Provide

   In order to create an account with SQRL, we require information to verify your identity as a part of the registration process including:

   • Name
   • Email Address
   • Phone Number
   • Address
   • Date of Birth
   • Social Security Number

   In some instances, for as identity verification, we may also collect proof of identity documents. Examples of such documents include a Government State I.D., Driver’s License, or a Passport.

   Information that you provide to the Company when interacting with our customer support team or other team members via phone, email, online form, or other correspondence.

   Personal information stored with third parties that you choose to provide to us, such as social media account information . By linking your third-party accounts or using third party sign-in services, you authorize the Company to have access to this information and you agree that the Company may collect and use this information in accordance with this Privacy Policy.

   Personal testimonial information or endorsements that you voluntarily provide to us and which we may display with your name on the App with your consent.

   Upon receiving a request to delete your account information, we will immediately disconnect all connections to your bank accounts, along with all personal information that you have provided upon the registration for your account. This means that the account account information that you have provided is no longer retrievable and that you will have to create a new account in the event that, subsequent to your request to delete the account, you elect to again register for the App.

2. Device Information

   We also collect the following information from your device when you use the Services, including your mobile device when you use our mobile application: your IP address, the type of device you use, your device identifier, your operating system version, the type of browser you use, your location, and the URL that you came from and the next URL that you visit.

3. Health Data

   We may also collect fitness data through Apple Health Kit / Google Fit. Please review the respective privacy policy for information on how Apple Health Kit / Google Fit uses and shares your personal information. The Privacy Policy of SQRL does not apply to the collection and use of your information by Apple Health Kit / Google Fit.

4. Application Analytics

   We use mobile analytics software to allow us to better understand the functionality of our mobile application. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may combine this automatically collected log information with other information we collect about you to provide and improve the Services.

   Please note that Anonymous Data are used to gather general statistics regarding our customers and visitors to enhance the consumer experience on the App. We may also use demographic data in a manner that does not identify you specifically but does identify certain criteria about our users in general. For example, we may inform third parties about the number of registered users, the number of unique visitors, and the pages most frequently browsed.

5. Financial Data

   Certain financial information, all of which is encrypted by the App or third parties with which we collaborate, that is necessary to transfer funds between your bank accounts.

   Disclaimer:
   

   We do not read your savings account balance. Therefore, the amount shown as money saved in the App may not be reflective of the money in your account. This information simply reflects the money that you have saved from SQRL and does not attempt to accurately state the total balance in your savings account.

6. Choice Regarding Disclosure of Personal Information

   You may choose not to provide us with any Personal Information. In such an event, you can still access and use some portions of the App; however, you will not be able to access and use portions of the App that require your Personal Information. But if you register on our App as a subscriber, you must provide us with the Essential Data or you will not be able to effectively use the App Services.

7. Confidentiality and Security of Personal Information

   Except as described in this Privacy Policy, we will not share your Personal Information with third parties, unless such disclosure is necessary (as determined in our sole discretion) to: (a) comply with a court order or other legal process; (b) protect the rights, property, and/or safety of the Company or any third party; or (c) enforce these Terms of Use.

Use of Personal Information

We collect your personal information to:

1. Provide the Services to you.
2. Notify you about your account activity.
3. Process transactions and collect fees.
4. Provide customer support and resolve disputes.
5. Verify your identity and account information.
6. Identify, prevent, and report potentially prohibited, fraudulent, or illegal activities.
7. Customize and improve your experience and the Services.
8. Personal you at your telephone number by voice or SMS to validate the telephone number or your account.
9. Notify you about important changes to the Services and/or ’s terms and conditions.
10. Provide you with news, offers, and information about the Services based on your communications preferences.
11. Any other purpose that we disclose to you in the course of providing the Services to you.

Sharing of Personal Information

We may share your personal information as follows:

1. If your transfer to your savings account fails, we may provide the recipient bank with details of the unsuccessful transfer.
2. With third parties to provide, maintain, and improve the App including fraud prevention, identity verification, analytics and marketing services, and financial institutions and other partners that are part of the payment process. These companies are authorized to use your personal information only as necessary to provide these services to us.
3. With third parties upon your request. For example, you may ask us to confirm your status as an App user with a third party.
4. If we believe that disclosure is reasonably necessary to comply with any applicable law, legal process, or government request; to investigate or bring legal action against someone who may be violating our rights, our terms and conditions, or the rights of others; or to protect the safety and security of the App or our users. Also, please be advised that certain personal information becomes public record upon the filing of documents with the state or the court. For example, the corporate name, business address and the name of the registered agent become public information upon the filing of the articles of incorporation. In many cases, the Secretary of State will provide this information to third parties for a fee. The US Patent and Trademark Office will also make public the names and addresses of trademark registrants. In some states, fictitious business names, including the name and address of the business owner, must be published in a newspaper. Our privacy policy does not cover actions by these third parties.
5. With a third party if we are involved in a merger, acquisition, or sale of all or a portion of our stock or assets. If this occurs, you will be notified of any changes to this Privacy Policy, as well as any choices you may have regarding your personal information.
6. We may share aggregated Anonymous Data, as defined below, with third parties. Other than as stated in this Privacy Policy, SQRL does not sell any of your personal information to third parties without your consent.

Service Providers

The use of SQRL confirms acceptance of Plaid’s Privacy Policy. To authenticate accounts, we’ve integrated with Plaid, a San Francisco- based financial technology ("fintech") company that builds connections with thousands of financial institutions. They're a trusted partner to companies ranging from popular fintech applications to Fortune 500 companies and major banks. These relationships require the company to have strong security controls in place, and its platform is regularly audited and tested to ensure its controls meet industry standards. For example, Plaid ensures sensitive data (both in- motion and at-rest) is encrypted, and regularly completes SOC-2 audits.

When you enter your online banking credentials, Plaid establishes an encrypted connection with your bank. This flow was designed with security in mind, as an easy alternative to entering static account and routing numbers. Once this connection is established, our application receives a token. This token enables us to get the data we need to provide our service without direct access to your bank account or credentials.

Dwolla is a powerful payments platform that securely connects bank or credit union accounts to enable the transfer of money for any individual or organization in the U.S. By leveraging Dwolla’s Access API, we are providing an integrated payments experience for seamless funds transfers for our customers, while reducing the headaches associated with fraud, exposure of sensitive financial data, and complications of using third-party processors.

Notifications

We provide you with a daily, weekly and monthly review of your progress each morning to encourage, recognize, and reward you for your activity. We highly recommend you to provide permission to send you these push notifications because they are an integral part of the experience. Additionally, we provide email notifications for any activity involving the movement of funds. This is a requirement of our API partners and it is the only way we notify you of the movements of funds, therefore disabling email communication is not an option we can provide.

Updates to Privacy Policy

We may make changes to this Privacy Policy at any time. The date of the last revision appears at the top of the Policy. We will update the effective date of the Privacy Policy when a change is made. Any changes made will be made effective immediately upon posting.

Questions Regarding Privacy Policy

The security and privacy of your personal information is very important to us. If you have any questions, feedback or concerns regarding this Privacy Policy, please contact us at support@eighty4.co.