AcuFi is dedicated to ensuring that end consumers have significant control over their data.  This section outlines AcuFi’s data practices in relation to the processing of data about you.  In the Summaries of Processing Activities section at the conclusion of this Policy, we also offer summaries of our practices that are categorized by the type of data collected and by the product.

Data We Collect and Categories of Sources

As described in more detail below, the data we collect, use, and share depends on the AcuFi products and services that you, and/or the app you have connected to, use. Depending on which of AcuFi’s products or services you or your app use, AcuFi may collect the following:

• Data you provide to us;
• Data from financial institutions when you connect your financial account;
• Data from the electronic device you use to connect your financial account using AcuFi or to otherwise interact with AcuFi;
• Data from the developer of the app you have connected to;
• Data from our affiliates to provide support to you or to provide you with a better user experience; and/or
• Data from other sources, including service providers and identity verification and fraud prevention services.
• Data you provide to us. When you use AcuFi’s products or services (like when you use AcuFi to connect your financial accounts to an app), we collect the following data from you as needed to power your particular app or AcuFi product or service:
• identifiers like name, email address, date of birth, Social Security number, and phone number;
• login data when required by the provider of your account, like your username and password, account and routing number, or a security token;
• any additional information needed to connect your accounts, including security questions and answers, and one-time password (OTP);
• information from documents or statements that you provide to AcuFi, like bank statements or pay stubs; and/or
• information related to your use of our services, including which of our services you use, the dates and times of your use, and which financial institutions and apps you connect using AcuFi.
• When you provide login data and additional information needed to connect your accounts, you also give AcuFi permission and authority to act on your behalf to access and transmit data to and from your financial institution.

Data we collect from financial institutions about and from your accounts.   Depending on which AcuFi products or services you, or the developer of your app use, as well as what, and how information is made available, we may collect the following data from your financial institutions:

• Account data, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, account number, routing number, and sort code;
• Data about an account balance, including current and available balance;
• Data about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
• Data about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
• Data about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
• Identifiers and data about the account owner(s), including name, email address, phone number, date of birth, and address information;
• Data about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and/or
• Data from your payroll and tax documents, including data about your income and employer, in cases where you’ve connected your payroll accounts or provided us with your pay stub or tax form information.

Depending on the AcuFi service you or the developer of your app use, and the manner in which the data is made available, the data collected from your financial accounts may include data from all accounts (e.g., checking, savings, credit card, and joint accounts) accessible through a single set of account credentials. For more specifics about data collected in connection with different products and services. Data we receive from your devices. When you use a device, like your smartphone, tablet, or computer, to interact with our services (including through a developer’s app), we may collect the following data about that device:

• internet protocol (IP) address;
• time zone setting and location, device location;
• hardware model and operating system;
• features within our services you access;
• browser data;
• network data; and
• other technical data about the device (such as settings and preferences).

Data we receive about you from the developers of apps powered by AcuFi. When needed for AcuFi to provide a service (like verifying your identity, protecting against fraud or risk, or enabling a bank transfer), the developers of the apps you use may provide us with identifiers and commercial information about you, like your name, Social Security number, email address, phone number, or information about your financial accounts and transactions. Data from our affiliates to provide support to you or to provide you with a better user experience. We may collect data from our affiliates (these are companies related to us by common ownership or control) to provide support to you or improve your experience. For example, if you elect for AcuFi CRA to remember financial accounts associated with your phone number, we may collect the following data from AcuFi CRA in order to help you connect to your accounts faster when using our services:

• identifiers like name, email address, and phone number;
• login data when required by the provider of your account, like your username and password, bank name, account and routing number, or a security token;
• when needed, data to help verify your identity and connect your accounts, including your date of birth, security questions and answers, and one-time password (OTP); and/or
• data from your device (as explained in more detail above).

Data we receive about you from other sources. When needed to provide a service, identify your device, or to help prevent fraud, abuse, or security threats, we may also receive data about you directly from third parties, including your wireless carrier, agents and our service providers. Information we derive from the data we collect. We may derive additional information about you from the data we collect. For example, we may infer your geolocation, your annual income, or the type of account or subaccount you’ve chosen to connect‚Äïsuch as when you connect your loan accounts, so we can let the developer know whether the account is for a mortgage, student loan, or credit card.

How We Use Your Data

We use your data for the following business and commercial purposes:

• Provide Services: To operate, provide, service, process, and maintain our products and services.
• Develop Existing Services: To improve, enhance, modify, add to, and further develop our services.
• Help Prevent Fraud, Verify Your Identity, or Protect Privacy: To verify your identity and help protect you, developers, our partners, AcuFi, and others from fraud, malicious activity, and other privacy and security-related concerns.
• Develop New Services: To develop new products and services.
• Develop Insights: To develop insights based on the data we’ve collected about you. This includes your transaction data, other financial data, data about which financial accounts you have connected to which apps, and data from other sources, to help us, your financial institutions, and the developers of your connected apps provide services and/or a better user experience to you, like providing you with a faster connection and onboarding experience, faster access to your funds, to help detect and prevent potentially fraudulent activity, or personalize their services to you.

• Provide Support: To provide support to you or to developers, including to help respond to your inquiries related to our services or developers’ apps.
• Communicate With You: To communicate with you and send you things like technical notices, updates, security alerts, and messages.
• Investigate Misuse and Misconduct: To investigate any misuse of our service or developers’ apps, including violations of our Developer Policy, criminal activity, or other unauthorized access to our services.
• For Legal Purposes: To comply with contractual and legal obligations under applicable law and for other legal purposes such as to establish and defend against claims.
• With Your Consent: For other notified purposes with your consent or at your direction.

We also collect, use, and share data that has been aggregated or anonymized in a manner that does not identify you personally for any purpose permitted under applicable law. This includes creating or using aggregated or anonymized data to develop new products or services, to facilitate research, and for analytics purposes to help assess the speed, accuracy, and/or security of our services.

How We Share Your Data

We share your data for the following reasons:

• With the developer of the app you are using and as directed by that developer;
• To enforce any contract with you;
• With our data processors and other service providers, partners, agents or contractors in connection with the services they perform for us or developers;
• With financial institutions to help establish, maintain, or manage a connection you’ve chosen to make between your financial institution accounts and the products or services you use, as well as to help them protect your financial accounts and offer you personalized services such as returning user experiences;
• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (like a court order or subpoena);
• In connection with a change in ownership or control of all or a part of our business (like a merger, acquisition, reorganization, or bankruptcy);
• Between and among AcuFi and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;
• As we believe reasonably appropriate to protect against and prevent actual or potential fraud, unauthorized transactions, claims, other liabilities, or otherwise protect the rights, privacy, safety, or property of you, developers, our partners, AcuFi, and others; or
• For any other notified purpose with your consent or at your direction.

We do not disclose your data to non-affiliated third parties except in accordance with the law (as authorized by 12 C.F.R. § 1016.14 and 1016.15).

We exclusively disclose your personal financial information to third parties in order to facilitate the services you have requested, when you provide your consent, and/or to safeguard against deception.

We may either allow third parties to collect this cookie data from our sites or collect and share it with them when you visit our website. Please see our Cookie Policy and All Audience Privacy Statement for more details.

Our Retention and Deletion Practices

We only retain your data for the duration necessary.  In order to ascertain the necessity of the data, we evaluate the purpose for which it was collected and utilized, as well as any legal obligations to retain it.  We periodically evaluate your data to confirm that it is still required to fulfill the purpose for which it was collected or to satisfy any other legal obligations.  AcuFi’s systems are configured to automatically eliminate your personal data in the event that a developer terminates your connection to your data in their application. However, there are specific limitations under which we may continue to retain your information.

The following are exceptions to this policy: 

(a) you have established a connection with another developer’s app through AcuFi that is still active;
(b) AcuFi requires your data to continue providing you with a requested AcuFi product or service;
(c) AcuFi is legally obligated to retain your data;
(d) AcuFi requires your data to assist in the prevention or detection of fraud, privacy, or misconduct, provide support, or investigate misuse and misconduct;
(e) AcuFi has anonymized your data to ensure that it cannot be reidentified; or
(f) we request your explicit consent to retain your data for an extended period.

Your data will be processed exclusively in compliance with this Policy or as mandated by law.

Please refer to the “Your Data Protection Rights” section of this Policy for options that may be available to you, including how to request deletion of your data. The “Your Additional Privacy Controls” section of this Policy also provides details about tools available to you to help you view and manage the connections you’ve made using AcuFi. You can also contact us about our data retention practices using the contact information in the “Contacting AcuFi”  section below.

Protection of Data

AcuFi’s security policies and procedures are intended to safeguard the confidentiality and integrity of your data.  AcuFi enforces controls that restrict access to this data to personnel who have a legitimate business need to know it and prohibits its personnel from unlawfully accessing, using, or disclosing it.