Effective Date: June 23, 2023
Financial Products or Services and Related Notices/Consents: If you apply or sign up for, or otherwise use, a financial product or service from us, we will use and share any “nonpublic personal information” (as such term is defined under the Gramm-Leach-Bliley Act or “GLBA”) that we collect from or about you in accordance with our Qapital Consumer Privacy Notice, which offers you certain choices with respect to the collection, use, sharing, and processing of your nonpublic personal information by financial institutions. This includes information we collect when you access or use the Qapital Services to manage or conduct transactions. Please see our Qapital Consumer Privacy Notice to learn how we use your “nonpublic personal information” and your choices relating thereto.
We may need to share certain information with financial institutions and our other third-party partners to provide portions of the Qapital Service 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 to establish a connection between your financial account and your Qapital Accounts and thereby obtain access to your financial records.
Similarly, if you link your Qapital Accounts to other services (such as a third-party fitness application), we may share your personal information to provide the features you have requested. 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.
Note that Qapital will also have access to information in connection with the use of third parties, including those described in the Note on Certain Third-Party Relationships below. In general, we may share your personal information with third parties (or use information from such 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; to manage our business; or as otherwise permitted under applicable law.
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 which can be found at the bottom of this page: https://www.qapital.com/terms/terms-qapital-spending/.
Personal Information We Collect
The personal information we collect from, and about, you may vary depending on how you engage with the Qapital Service and the information you provide voluntarily.
- Information You Provide
We may collect personal information directly from you or otherwise in connection with your use of the Qapital Service, including:
- Contact Information, including your name, contact details (such as a postal address and email address), and communication preferences.
- Inquiry Information, including information provided in messages sent through forms or surveys, to our email addresses, or via phone. This also may include information provided when you sign up for our newsletters.
- Testimonial Information, including your contact information along with a statement regarding the Qapital Service.
- Information that We Collect Automatically
We and our third-party partners may use various technologies to automatically collect certain information when you access or use the Qapital Service, including:
- Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on the Qapital Service, and any errors that may occur during the visit to the Qapital Service). “Device Data” may overlap with the other categories of data below.
- Analytics Data, including the path taken to the Qapital Service, through our the Qapital Service, and when exiting the Qapital Service, usage and activity on or in connection with the Qapital Service (including transactions made therein, to the extent not related to our financial products and services), metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below).
- Location Data, including the precise or coarse geographic location we or our third-party providers may collect, such as via permissions within app operating system or browser functionality.
- Advertising/Advertising Measurement Data, including data associated with your view of, or click on, advertisements served on the Qapital Service, cookie IDs or other digital or proprietary identifier (e.g., iOS IDFA, Google AAID) assigned to such device, and device metadata, analytics data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns.
- Information from Third-Party Sources
We may receive personal information about you from third parties and combine this information with other information we have.
- Affiliates. We may receive personal information from other companies owned or controlled by Qapital and other companies owning or under common ownership with Qapital. This includes any subsidiaries (i.e., any organization we own or control) or our parent company (i.e., any organization that owns or controls us) and any subsidiaries it owns.
- Service Providers and Business Partners. Our service providers that perform services on our behalf, such as email marketing providers, and other business partners collect and share personal information with us in connection with the facilitation of the Qapital Service or for the advertising of such Qapital Service or other third-party services or products that may be of interest with you.
- Social Media and Professional Networks. When an individual interacts with us through various social media and professional networks, such as when someone communicates with us through LinkedIn, we may receive some information about the individual that they permit the network to share with third parties. The data we receive may be dependent upon an individual’s privacy settings with the network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and networks before sharing information with us or the social media and professional network platform.
- Information Providers. We may from time to time obtain information from third-party information providers to correct or supplement other personal information we collect. For example, we may obtain updated contact information from third-party information providers to connect (or re-connect) with individuals.
- Publicly Available Information. We may also collect personal information from publicly available sources, such as government records or publicly available websites, to supplement other personal information we collect.
How We Use Personal Information We Collect
We use the personal information we collect for our business purposes, including the following:
- To provide, analyze, and improve the Qapital Service;
- To market products and services that we believe may be of interest to you, whether products or services that are part of the Qapital Service (e.g., new or improved products or services) or third-party products or services, and measuring the effectiveness of such marketing;
- To communicate with you, such as to respond to your comments and questions, provide customer service or feedback, troubleshoot problems, or for any other purposes in connection with the Qapital Service;
- For market and demographics/audience research and project planning;
- To prevent, investigate, detect, and protect against error, fraud, or other criminal activity;
- To solicit your feedback;
- To render your personal information anonymous or pseudonymous and create aggregated data;
- For our internal business purposes and to enforce our Terms and Conditions;
- To comply with our legal obligations;
- For any other lawful, legitimate business purpose.
How We Share Information Collected
We may share your personal information in the following ways:
- Service Providers and Business Partners. We use third-party service providers and business partners to help us manage and improve the Qapital Service. We also use these third parties to host or facilitate portions of the Qapital Service, target and implement our email communications and direct mailings, manage our relationships with the people and companies that use the Qapital Service, process payments, and assist with market research, security, connecting to other services, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal or malicious activity.
- Data Analytics Providers. We share information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to the Qapital Service. These data analytics providers produce reports and make suggestions for our customer and business strategy based on the personal information and other information analyzed.
- Marketing Partners. We coordinate and share personal information with our marketing partners (including brands, social media providers, or advertising technology companies) to communicate with individuals about the Qapital Service or third-party products and services, including by serving ads that may be of interest to you (e.g., ads for the Qapital Service on third-party digital properties, ads for third-party products or services on the Qapital Service) and to measure the effectiveness of such marketing campaigns.
- Legal Process and Suspected Fraud. We may share or disclose information collected through the Qapital Service 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.
Qapital may share de-identified, anonymized, or otherwise aggregated personal information in order to use, analyze, or provide information.
You can stop receiving marketing email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt out of transactional or service-oriented messages, as such messages are required to respond to your requests or to provide goods and services.
You may request to delete your Qapital Accounts:
- By clicking ’Delete my Qapital profile’ within the Qapital App’s Membership Page and following the process thereafter; or
- By requesting deletion via email to (a) firstname.lastname@example.org for your Goals Account and Spending Account or (b) email@example.com for your Invest Account.
In either case, we will delete your Qapital Accounts (to the extent applicable) within a reasonable time after receiving your request. Please note that, after such deletion, we may still retain your personal information as reasonably necessary for legal compliance purposes, the establishment, exercise, or defense of any actual or potential legal claims, internal recordkeeping, or other business purposes.
Use of Tracking Technologies
Certain browsers may allow an individual to: (i) change their browser settings to notify the individual when they receive a cookie, which may let the individual choose whether or not to accept it; (ii) disable existing cookies; or (iii) set their browser to automatically reject cookies. Note that similar controls may exist for other tracking technologies, such as the ability to restrict the collection of certain mobile advertising technologies under certain device settings. Please check your device or browser settings and related documentation for more information.
Additional Choice Relating to Third-Party Advertising
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ and you can opt-out of receiving certain interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices and downloading the mobile AppChoices app.
The Qapital Service may contain links to and from third-party digital properties or tools or services of our business partners (including advertisers and social media sites). If you follow any of these links or otherwise utilizes these tools or services, please note that these third parties have their own privacy policies and that we disclaim all responsibility or liability for their policies. We strongly recommend that you read their policies to understand how they collect, use, and share information. We are not responsible for the privacy practices or other practices of a third party.
We utilize measures to help protect information under our control against loss, misuse, and alteration. Please be aware that 100% security is not possible and that you assume the risk with respect to any information that you provide to us.
Retention of Personal Information
The length of time Qapital intends to retain personal information is for as long as reasonably necessary to carry out Qapital’s business purposes for such information. Please note that we may also need to retain your data beyond your account deletion or closure date as reasonably required, in our discretion, by federal, state, or local law or any recordkeeping or reporting obligations.
Qapital does not knowingly collect or solicit any information from anyone under the age of 13 on the Qapital Service. In the event that we learn we have inadvertently collected personal information from a child under age 13, we will endeavor to promptly delete that information. If you believe that a minor in your care has provided us with information, please contact us at firstname.lastname@example.org.