Effective Date: March 31, 2018
collected through our website www.qapital.com, (the “Site”) and our mobile application (collectively, “Qapital Technology” ), and how we use and share that
information in connection with our services offered through Qapital
Technology (the “Services”). Unless otherwise indicated, this policy only applies to personal information collected through Qapital Technology by Qapital, Inc., Qapital Invest, LLC (“Qapital Invest”), or any of their respective affiliates (collectively, for purposes hereof, “Qapital”).
By visiting the Site and/or using Qapital Technology, you agree to be
Further, by signing up, accessing, and/or using our Services, you explicitly
applicable customer agreements separately agreed by you.
Information We Collect
1. Information You Provide
Certain areas and features of our Qapital Technology or Services are available to you without registration or the need for you to provide to us any personal information. Some features of Qapital Technology or the Services may require registration, which involves provision of your personal information, including:
- E-mail address
- Telephone number
- Other information
When you use certain features of the Services, we may collect a variety of other personal information from you. Although this personal information varies depending on how you use the Services, it may include information such as your:
- Mailing address
- Telephone number
- E-mail address
- Social Security Number
- Date of birth
- Financial account information, including login credentials
- Any information obtained about you in connection with providing a financial service or product to you
In some instances, such as with identity verification, we may also collect scanned copies of documents containing such personal information. Examples of such documents might include your driver’s license or a copy of a utility bill as required by some financial institutions.
From time to time we may request additional personal information in order to provide you with other benefits of the Services. In such instances, you will receive notice of this newly proposed use or purpose, and you will have a choice as to whether to provide the requested information for those limited purposes.
2. Investment Information
When you sign up for Qapital Invest,
we ask each client a series of questions to assess, among other things,
risk tolerance, investment goals, age, investment time horizon, current
assets, and income (collectively “Investment Information”). We may also
collect Investment Information through your use of the Qapital Technology.
3. Device and Technical Information
When you access Qapital Technology, we may collect technical information, such as web browser type and version, service-provider identification, IP address, the website or online service from which you came to our website, and the website or online service to which you navigate from our website. We may also collect information about the computer or mobile device used to access Qapital Technology and related details about the way Qapital Technology is being used by your device.
“Cookies” are text files that are inserted and stored by your web browser on your computer’s hard drive. Cookies used with Qapital Technology are encrypted and do not contain personally identifiable information. Qapital may set and access cookies on your computer to track, gather and store information about your preferences in using Qapital Technology. Note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Services may not be available to you.
How We Use Information We Collect Through Qapital Technology and Services
1. General business operations
Qapital may use information collected through Qapital Technology to conduct basic business operations, including:
- analyze site usage and improve the Services;
- deliver to you any administrative notices, alerts and communications relevant to your use of the Services;
- except for Apple Health Kit data, to market products and services that we believe may be of interest to you (you may opt out of this use of your information);
- to fulfill your requests for certain products and services; for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
- to advise you about your portfolio;
- to solicit your feedback;
- to render your personal information anonymous and create aggregated data;
- for our internal business purposes and to enforce our Terms and Conditions;
- to fulfill our contractual obligations to you or subsequent requests for support by you; and
2. Business analytics
We also use contracted third party analytics providers to measure traffic and usage trends, and to help us better understand your use of and interaction with Qapital Technology and Services. Sometimes we may combine personal information collected from you through Qapital Technology and Services with information we collect from other offline and line sources for purposes of enhancing your experience or improving our products. An example of such sources are interviews or surveys you may have completed about the Services or Qapital Technology. This combination of information can also include any information you provide to us while using our Services as well as when, where, and how you make payments, purchases and transfers; your use of our website, mobile application or services; or any other Services provided by our partners.
We May Use Third Party Providers to Target Online Advertising
The Services also enable authorized third party tracking mechanisms for use in online behavioral advertising. For example, authorized third parties may use the fact that you used Qapital Technology to target online ads for Qapital services to you on non-Qapital websites. In addition, our third party advertising networks might use information about your use of the Services to help target non-Qapital advertisements based on your online behavior. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
Do Not Track Disclosure and Related Options.
How We Share Information Collected Through Qapital Technology and the Services
1. Services Providers
Qapital and its affiliated companies use contracted third party service providers to help us manage and improve the Services and Qapital technology. We also use such third parties to host features of our Services and Qapital Technology; to help us target and implement our email communications and direct mailings; to help us manage our relationships with the people and companies that use our services; to process payments; and to assist us with market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity.
2. Other Third Parties
We may also share your personal information with other contracted third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
3. Financial Institutions
We may share certain information with financial institutions and our other partners to provide the Service features that you elect to use. For example, if you provide your online login information for financial accounts to us, we may disclose that to your financial institution or its intermediary in order to establish a connection between your financial account and your Qapital account, and thereby obtain access to your financial records. Similarly, if you link your Qapital account to other services (such as a third party fitness application), we may share your personal information in order to provide the features you have requested. And if you apply for a financial product or service, such as the Qapital Visa® Debit Card or Qapital Invest, we will disclose any personal information that the financial institution requires to complete the transaction in question or as needed to meet any legal requirements.
We may share the information described in this policy with our affiliates.
5. Anonymized or Aggregated Data
From time to time, Qapital may anonymize or otherwise aggregate personal information in order to disclose or analyze information without disclosing identities or otherwise compromising the privacy and security of that information.
6. Legal Process and Suspected Fraud
We may share or disclose information collected through Qapital Technology when Qapital determines, in its sole discretion, that the disclosure of such information is necessary or authorized under the law; to comply with applicable law or a court order, subpoena, or other legal process; to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party; to establish, protect, or exercise our legal rights or defend against legal claims; or to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets. Whenever applicable, possible and allowable under the law, Qapital will provide you notice of such requests or use of your personal information as described in this paragraph.
7. Sale or Merger
Third Party Services and Content
If you choose to sign up for the Qapital Visa® Debit Card, you understand that such card is issued by Lincoln Savings Bank and you confirm acceptance of Lincoln Saving Bank’s privacy practices.
Accessing Your Information and Deleting Your Account
1. Accessing and Maintaining Your Information
It is your responsibility to keep your personal information up to date by updating your profile in the mobile application or by contacting our Customer Success team at email@example.com. We are not responsible for costs or other issues arising from your failure to keep your personal information up to date.
2. Deleting Your Account
You may request that we delete your account for the Services. To request deletion of your account, email firstname.lastname@example.org, requesting a deletion of your account. Merely deleting the mobile application from your device does not constitute a request to delete your account. Once your request to delete your account has been processed, we will promptly disconnect any connection we may have established to your Account Information and delete all account credentials. Please note that we may need to retain your data beyond your account deletion date as required by federal, state or local law.
1. Security Measures
We utilize commercially reasonable physical, technical, and administrative security measures to help protect information under Qapital control against loss, misuse, and alteration. For example, we use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session, your personal information and to protect Qapital accounts and systems from unauthorized access. While we implement the above security measures with Qapital Technology, please be aware that 100% security is not always possible.
2. You Are Responsible for Keeping Your Login ID and Password Secure
Retention of Your information
Qapital Technology and Services are intended for adult use only. We do not knowingly collect information provided by children under the age of 18. If you believe that a minor in your care has provided us with information, or if you desire to provide a minor in your care access to Qapital Technology and Services, please contact us at email@example.com.
VISA® Account Updater Service
If you have a Qapital Visa® Debit Card, your account is automatically enrolled in the Visa Account Updater Service (VAU). This service is provided by Visa as a benefit in order to facilitate uninterrupted processing of recurring charges you have authorized. Under the VAU service, we provide notice to Visa when your card number or expiration date change (i.e., when renewing an expiring card). If you have authorized a participating merchant to bill your card for recurring payments, Visa notifies the merchant of your new card number and expiration date. Card numbers are only supplied to merchants who participate in the VAU service. Because not all merchants participate in the VAU service, you should still notify each merchant when your card number changes in order to permit recurring payments to continue to be charged to your account. If you’d prefer not to have your card information updated automatically, you can opt out. If you’d like to opt out, please contact us at firstname.lastname@example.org.