ALLIO PRIVACY POLICY

Last Updated: June 7, 2022

This Privacy Policy describes how Allio Finance (“Allio” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”). We may provide different or additional notices of our privacy practices with respect to certain products or services, in which case this Privacy Policy will not apply. 

If you have applied for an account, please also review our GLBA Consumer Privacy Notice.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you create an account, fill out a form, submit or post content through our Services, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of information about you that we collect include:

• Identification Information: We collect your name, email address, phone number, mailing/billing addresses, date of birth, and government identification documents (i.e., your driver’s license, passport, or state identification card). 

• Financial Information: We may collect your financial information necessary to provide the Services, such as your credit history, employment history, income, loan amounts, and net worth. 

• Payment Information: Our payment processor(s) will collect the information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers.

• Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback.  

• Commercial Information: We may retain a history of the products you browse and/or purchase using the Service.

• Demographic Information: We collect your age, gender, income level, and ideal age of retirement.

• Social Media Information: We may maintain a social media presence on platforms like Instagram, Facebook, and LinkedIn (“Social Media Pages”). When you interact with us on social media, we may receive personal information that you provide or make available to us based on your settings, 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. We may also receive information from social media platforms if you link your social media accounts with your account on our Services. The type of information we receive depends on your settings with the relevant platform but may include things like your handle and followers list.

Information We Collect Automatically

We automatically collect certain information about your activities on our Services or interactions with us or our Services, including:

• Transaction History Information: We collect information about the financial accounts you link to the Service through Plaid, a third party financial API, and any related transactions, such as the name of the financial institution, the account type, and the date, location, and amount of the transaction.

• Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services. 

• Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).

• Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we may use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We may obtain information from other sources. For example, we may collect information from third parties, including identity verification services, advertising networks, data analytics providers, and mailing list providers. Additionally, if you create or log into your Allio account through a third-party platform (such as Facebook or Google), we will have access to certain information from that platform, depending on your settings and the authorization procedures set by the platform.

USE OF INFORMATION

We use the information we collect through our Services for purposes described in this Privacy Policy or disclosed to you on, or in connection with, our Services. We also use the information we collect to:

• Provide our Services, including giving you an accurate picture of your financial health and helping you meet your financial goals with our savings and investment services;

• Maintain, improve, and develop new products and services, including to debug and repair errors in our Services 

• Personalize your experience with us;

• Send you technical notices, security alerts, support messages and other transactional or relationship messages; 

• Communicate with you about products, services, and events offered by Allio and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);

• Monitor and analyze trends, usage, and activities in connection with our products and services; 

• Personalize the advertisements you see when you use our Services based on information provided by our advertising partners;

• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; 

• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Allio and others;

• Comply with our legal and financial obligations, such as Know-Your-Customer and Anti-Money Laundering laws; 

• Create de-identified, anonymized or aggregated information; and

• Carry out any other purpose described to you at the time the information is collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy: 

• We share personal information with vendors that access personal information to perform work for us, such as companies that assist us with web hosting, payment processing, fraud prevention, customer service, and marketing and advertising.

• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Allio, our users, the public, or others.

• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

• We may share personal information with third parties such as financial institutions and other partners for marketing and other commercial purposes.

• We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. 

• Personal information is shared between and among Allio and our future parents, affiliates, and subsidiaries and other companies under common control and ownership.

• We share personal information with your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you. 

ADVERTISING AND ANALYTICS 

We may engage others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Allioand others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We may also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Allio is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we will take steps to ensure that your personal data receives an adequate level of protection in accordance with applicable law.

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by contacting us. If you wish to deactivate your account, please contact us, but note that we may retain certain information as required by law or for our legitimate business purposes.

Location Information

When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. 

Communications Preferences

You may opt out of receiving promotional emails from Allio by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at legal@alliofinance.com.