Data We Collect and Categories of Sources

Depending on the products or services used, AcuFi CRA may collect the following:

• Data you provide to us;
• Data from our affiliates to provide support to you or to provide you with a better user experience;
• Data you provide to us from your financial institutions when you connect your financial account;
• Data from the electronic device you use to connect or interact with AcuFi CRA;
• Data from Consumer Report Users; and
• Data from other sources, including service providers or identity verification and fraud prevention services.

Data you provide to us. When you use AcuFi CRA’s products or services, such as to create and share a consumer report, we may collect the following data from you:

• identifiers like name, email address, and phone number;
• login data when required by your financial institution, like your username and password, bank name, account and routing number, or a security token; and
• 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).

When you provide this data, you also give AcuFi CRA permission and authority to act on your behalf to access and transmit your data to and from the relevant bank or financial institution that holds your financial account (we’ll call them “financial institutions” in this Policy).

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 to provide support to you or improve your experience. For example, if you elect for AcuFi to remember financial accounts associated with your phone number, AcuFi CRA may collect the following data from AcuFi in order to help you connect to these accounts faster to AcuFi CRA’s 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
• data from your device (as explained in more detail below).

Data you provide to us from your financial institutions when you connect your financial account. Depending on the AcuFi CRA products or services used, as well as what and how information is made available by your financial institutions, we may collect the following data from financial institutions when you connect your financial accounts with or through AcuFi CRA:

• Account data, including financial institution name, account name, account type, account ownership, branch number, 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; and
• Data about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction.

Depending on the AcuFi CRA service used, 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.

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 Consumer Report User’s application), 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; and
• which features within our services you access, browser data, and other technical data about the device.

Data we receive about you from Consumer Report Users. When needed for AcuFi CRA to provide a service, Consumer Report Users may provide us with identifiers and commercial information about you, like your name, address, email address, phone number, or information about your financial accounts and account transactions.

Data we receive about you from other sources. When needed to provide a service or to help prevent fraud, abuse, or security threats, we may also receive data about you directly from third parties, including our service providers or identity verification and fraud prevention services.

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, your employer, or the type of account or subaccount you’ve chosen to connect (such as 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, and maintain our services, such as creating consumer reports about you and providing scores to Consumer Report Users.
• Develop Existing Services: To improve, enhance, modify, add to, and further develop our services.
• Help Prevent Fraud or Protect Privacy: To help protect you, Consumer Report Users, financial institutions, our partners, AcuFi CRA, 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.
• Provide Support: To provide support to you or to Consumer Report Users, including to help respond to your inquiries related to our services and prepare disclosures that you may request or to facilitate reinvestigation of disputes that you initiate under the Fair Credit Reporting Act.
• Investigate Misuse and Misconduct: To investigate misuse of services, including violations of our terms of use (such as 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.

How We Share Your Data

The following are the reasons for which we share your data:

• In accordance with the user’s instructions, Consumer Report Users;
• To enforce any contract with you;
• In connection with the services they provide for us or Consumer Report Users, our data processors and other service providers, partners, or contractors;
• Financial institutions can assist in the establishment, maintenance, or management of a connection that you have chosen to establish.
• If we are of the opinion that disclosure is necessary to comply with applicable law, regulation, or legal process (such as a court order or subpoena) or to respond to a request from a regulator, government authority, or law enforcement authority that has authority over us;
• In the event of a change in ownership or control of all or a portion of our business, such as a merger, acquisition, reorganization, or bankruptcy;
• With our current and future parents, affiliates, subsidiaries, and other companies under common control or ownership; In order to prevent malicious or fraudulent activities, or to otherwise protect the rights, privacy, safety, or property of you, Consumer Report Users, our partners, AcuFi CRA, and others; For any other notified purpose with your consent or at your direction.

We do not share your data with non-affiliated third parties except as permitted by law (as authorized by 12 C.F.R. s 1016.14 and 1016.15).

We may 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 services or to facilitate research, to the extent permitted under applicable law.

We may collect and share cookie data with third parties when you visit our website, or we may allow third parties to collect this cookie data from our sites.

Our Strategies for Retention and Deletion

We only retain your data for the duration necessary, and we conduct periodic reviews to verify that it is still required.  AcuFi CRA may retain your data if: (a) AcuFi CRA requires your data to continue providing a service you requested; (b) AcuFi CRA is legally obligated to retain your data or retention is required by our compliance program to demonstrate compliance with the law; (c) AcuFi CRA determines that it needs to retain your data to assist with AcuFi CRA’s compliance with the law or regulatory requirements, including the Fair Credit Reporting Act; (d) AcuFi CRA requires your data to help prevent fraud, protect privacy, provide support, or investigate misuse and misconduct; or (e) we request (and you specifically agree) to retain your data for an extended period.

Your data will be accessed, shared, and retained exclusively in compliance with this Policy or as mandated by law.

Data Protection

The confidentiality and integrity of your data, as well as any other data we collect about you, are safeguarded by AcuFi CRA’s security policies and practices.  Controls are implemented by AcuFi CRA to restrict access to this data to personnel who have a legitimate business need to know it and to prevent them from unlawfully disclosing it.