WalletFi Privacy Statement

I.          Scope of this Privacy Statement

Welcome to StartStopMove, Inc. dba WalletFi (“WalletFi”, “us,” “we” or “our”) and our Service, as described in the WalletFi Terms of Use located at https://www.walletfi.com/home/terms 

This Privacy Statement describes the types of personal information collected, used and disclosed when you access or use the website located at www.walletfi.com or mobile application provided by us (collectively, the “Site”). This Privacy Statement does not govern our collection of personal information through any website, mobile application or other means, other than through the Site.

By accessing the Site or using the Service, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not access or browse the Site, or use the Service.

We encourage you to review this Privacy Statement whenever you access the Site or use the Service, to stay informed about our personal information practices and the ways you can help protect your privacy.

II.        Personal Information We Collect

A.        Information You Give Us

The types of personal information we may collect from you may include:

  • User-provided Information.  When you create an account or use the Service, you may provide and we may collect what is generally called “personally identifiable” information, such as your name and e-mail address, mailing address, mobile phone number, and demographic information such as gender, interests and location.  For example, you may provide us with personal information when you register for an account, use the Service, interact with other users of the Service through communication or messaging features, or send us customer service related requests.  Depending on the type of device you are using, we may also allow you to identify yourself when logging on to the Service by providing your thumbprint.

  • Financial Institution Aggregation. In order for you to benefit from the full functionality of our Service, our Service require access to your financial institution (“FI”) account data, including transaction history, balances, and account information. We may access directly, or we may use a third party service provider to facilitate the collection of your FI account data from your FIs, including, but not limited to, accessing your FI account data, including financial transaction data, balances, and activity, and retrieving your FI account data from such third party financial institutions. We do not store your FI account login information.

  • Information from Other Sources. We may also obtain information, including personally identifiable information, from third parties and sources other than the Service, such as our partners or advertisers. For example, we use Plaid Technologies, Inc. (“Plaid”) to gather your data from financial institutions.  By using our Service, 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’s Privacy Policy (located at https://plaid.com/legal).  We may also, at your direction, receive information from third party services that provide a mechanism to share information you have provided to such third party through the use of an application program interface (API), such as Facebook Connect or the Twitter API. If we combine or associate information from other sources with personal information that we collect through the Service, we will treat the combined information as personal information in accordance with this Privacy Policy.

  • Additional Information: Additional information that you provide to us, including through comments and feedback, messages, emails, posts to public discussion boards, or answers to surveys or questionnaires that you may submit.

B.        Automated Information Collection

We may collect certain information about your use of the Site or the Service through the use of tracking technologies or by other passive means. This passively collected information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

  • Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser. 
  • IP Address.  IP address can reveal a web user’s general location (city, state, country).
  • Links. The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our products and design.
  • URLs. When you visit or access the Site, we automatically receive the URL of the site from which you came and the site to which you are going when you leave the Site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Site.
  • Cookies. When you visit or access the Site, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of the Site by storing user preferences and tracking user trends. Most web browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some customized features available through the Site.
  • Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1x1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Site and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.
  • Aggregate Information. We may compile certain personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of people who have visited the Site and other user demographics. Such aggregate information does not identify you individually.

III.       How We and Our Affiliates Use Personal Information

Personal information collected through the Site or Service may be used by us and our affiliates for purposes of:

  • Operating, maintaining, enhancing and providing you with the Service;
  • Responding to your questions or feedback;
  • Contacting you, whether by email, postal mail, or telephone with information about the Site, our products, or our services;
  • For such purposes as you may authorize at the time you submit the information;
  • Auditing, research, and analysis to maintain, protect, and improve the Site and our services;
  • Ensuring the technical functions of our network;
  • Improving and customizing the content and layout of the Site or our services;
  • Developing new products and services; or
  • Compiling personal information and other information collected through the Site on an aggregate basis.

IV.       Personal Information We Share

We do not sell, rent, trade, or otherwise share personal information collected through the Site, except as described below:

  • In Connection with our Offerings.  We may sharing certain personal information collected through the Site with (i) other users of the Site, and (ii) as you otherwise provide your consent. 

Information which you upload, post, e-mail, submit or otherwise transmit in connection with the Site to a public message board, chat area or other public area of the Site will be made public to users of the Site, including certain metadata related to such activities (such as timestamps).  You are solely responsible for any such information you choose to post on or through the Site.  All information that is posted to a message board, chat area, or other public area of the Site may be shared by us with others.

  • Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our administrative and business purposes.
  • Service Providers. We work with third parties that provide services on our behalf. Such services may include website, application development, hosting, maintenance, and other services for us. We may share personal information and non-personal information with these third parties for the purpose of enabling them to provide these services. We do not bear any responsibility for any actions or policies of these third parties.
  • Consent. We may share personal information in accordance with any consent you provide.  For example, if you are transferring your payment card account to another FI, we will require you to expressly consent to our sharing your transaction history, balances, and account information with the new FI you have selected.
  • Required by Law. We may disclose personal information or any information collected through the Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
  • Certain Transactions. We may disclose or transfer personal information or any information collected through the Site to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
  • Internet-Based Advertising and Content.  We may participate in Interest-based and behavioral advertising. This means that you may see advertising or content on the Site tailored to how you engage, browse or shop, or you may see advertising for us on other websites, applications and social media based on your behavior across websites, applications and social media.  We may target ads or content based on data we have collected, or data provided by third parties alone or in combination with the data we collect ourselves.  If you choose to interact with specific third parties who advertise through the Site, the information you provide to them is subject to the conditions of their specific privacy policies.

In connection with the foregoing activities, third parties, often called “ad servers” or “ad networks,” may place and access cookies, web beacons, or other tracking technology on your device to collect information about your use of the Site and your use of third-party sites. The information about your use of the Site may be combined with information about your use of third-party websites to provide targeted advertisements and content that may be of interest to you (this is known as “behavioral advertising”).  The information they collect from the Site may identify you personally, or they may associate it with personal information collected in other ways or received from other third parties.  We do not control these third parties or their use of cookies, web beacons, or other tracking technology.

By using the Site you agree to usage tracking and targeted, behavioral advertising.  If you do not wish to have cookies track your usage for these purposes please see the Section II.B of this Privacy Statement to refuse all or some browser cookies or do not use the Site. 

Some advertisers may provide you with the choice to opt-out of having your information used for behavioral advertising.  If you would like more information about behavioral advertising, or for information about how to opt-out of behavioral advertising, please visit the Network Advertising Initiative's (“NAI”) consumer Web site at http://www.networkadvertising.org/understanding-online-advertising, and in particular, NAI’s Ad Network “Opt-Out” page at http://www.networkadvertising.org/choices/.  Even if you opt-out of behavioral advertising, we may still collect and use information about your use of the Site to the extent otherwise permitted by this Privacy Statement (such as to analyze Site traffic and usage, conduct website analytics, administer the Site, etc.).  In addition, if you opt-out of receiving behavioral advertising from a particular advertiser, the advertiser may still provide advertisements to you, but the ad will not be targeted to you based on your online activities. 

V.        Aggregate Information

We may compile personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site, demographic information about users of the Site, and individual purchase preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.

VI.       Your Choices

A.        Information You Provide

You can always choose whether or not to provide information on the Site. However, if you choose not to disclose certain information, you may not be able to establish an account on the Site, which may limit your access to certain functions of the Site.

B.        Communications from Us

If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at support@walletfi.com.

C.        Do Not Track

Our Site do not honor “do not track” signals or other mechanisms. However, as described in more detail in Section II.B of this Privacy Statement, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.

VII.      Information Storage and Security

We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

VIII.    A Special Note about Children

Children are not eligible to use the Site, and we ask that minors (children under the age of 18) not submit any personal information to us. If you are a minor, you can use the Site only in conjunction with your parents or guardians.

IX.       External Links and Applications

The Site may contain links to various websites or allow access to various applications (such as, but not limited to, Apple’s iCloud Keychain) that we do not control. When you click on one of these links, or on one of these applications, you will no longer be transacting business through the Site. Third party websites and applications maintain their own privacy policies, and we do not exercise any control over any of the third party websites or applications that may be linked to the Site. If you visit a website that is linked to the Site, you should consult that website’s privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

X.         Special Admonitions for International Use

The Site are hosted in the United States and are intended for use by residents of the United States of America only. If you are not a resident of the United States, you shall not access nor use the Service. All matters relating to the Site are governed exclusively by the laws of the State of North Carolina in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.

XI.      Updates to this Privacy Statement

WalletFi in its sole discretion may revise this Privacy Statement at any time for any reason. If a change to this Privacy Statement materially modifies your rights or obligations, we will make reasonable efforts to notify you of that change. We may provide notice through a pop-up or banner within the Service, by sending an email to any address you may have used to register for an account, or through other mechanisms. Additionally, if changes to this Privacy Statement materially modify your rights or obligations, we may require you to provide express consent to those changes.  If we require your express consent to the changed Privacy Statement, changes are effective only after your acceptance and, if you do not accept the changed Privacy Statement, we may terminate your access to and use of the Service. If we do not require your express consent to the changed Privacy Statement, those changes are effective upon publication of the changed Privacy Statement and, by continuing to access or use the Service after publication, you confirm your acceptance of the revised Privacy Statement. You can determine when we last updated the Privacy Statement by referring to the “Last Updated” legend at the bottom of this Privacy Statement. We strongly recommend that you periodically visit this page of the Service to review this Privacy Statement. If you do not agree to the then current Privacy Statement for the Service, you shall not access or use the Service.

XII.      Questions Regarding this Privacy Statement

If you have any questions or comments regarding this Privacy Statement, please send us an email at support@walletfi.com.

This Privacy Statement is effective as of December 1, 2016.

Last Updated: February 16, 2018