Privacy Policy

Effective Date: July 8, 2021

This Privacy Policy explains what personal and other information is collected through our website, (the “Site”) and our mobile application (the “Mobile App,” and together with the Site, the “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, LLC, 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 bound by this Privacy Policy and our Terms and Conditions, which are hereby incorporated into this Privacy Policy. If you do not agree to any of the terms in this Privacy Policy, you may not access or use the Site and/or Qapital Technology.

Further, by signing up, accessing, and/or using our Services, you explicitly agree to the terms of this Privacy Policy, our Terms and Conditions, and any 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:

  • Name

  • E-mail address

  • Telephone number

  • Password

  • 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:

  • Name

  • 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 a Qapital investment account (your “Invest Account”), 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.

4. Cookies

“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:

  1. analyze site usage and improve the Services;

  2. deliver to you any administrative notices, alerts and communications relevant to your use of the Services;

  3. 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);

  4. 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;

  5. to advise you about your portfolio;

  6. to solicit your feedback;

  7. to render your personal information anonymous and create aggregated data;

  8. for our internal business purposes and to enforce our Terms and Conditions;

  9. to fulfill our contractual obligations to you or subsequent requests for support by you; and

  10. as otherwise set forth in this Privacy Policy.

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 the Site, Mobile App, or Services; or any other services provided by our partners.

Your Choices and Selecting Your Privacy Preferences

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Any transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

As a user of the Qapital Technology, and by your acknowledgement of the Terms and Conditions, which you grant by use of the Qapital Technology, you explicitly consent to receive emails, push notifications, and text messages from us regarding our Services. You may opt-out from receiving certain of such correspondence at any time by emailing, electing to unsubscribe as may be provided in the applicable correspondence, or updating your notification settings within the Mobile App. To opt out of correspondence and notifications associated with your Invest Account, in addition to updating your notification settings within the Qapital App, you may also email Please note that by opting out or unsubscribing, you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. For more information on text messaging, please review our Terms and Conditions.

We May Use Third Party Providers to Target Online Advertising

We may also use contracted third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity. We may permit these service providers to use cookies and other technologies to perform these services for us.

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.

Qapital Technology currently does not respond to “do not track” browser headers. However, you can limit tracking through these third party programs and by taking the following steps. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Privacy Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here.

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.

4. Affiliates

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.

7. Sale or Merger

Information collected through Qapital Technology and Services may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control, reorganization, bankruptcy, or asset sale. If we sell, merge or transfer any part of our business, part of the sale may include your personal information. Any subsequent use of your personal information shall take place in accordance with this Privacy Policy or other policy issued by the acquiring third party.

Third Party Services and Content

Your use of Qapital Technology and Services confirms acceptance of Plaid’s Privacy Policy. Plaid is one of our trusted third party service providers that facilitates the transfer of your personal information to and from financial institutions. In using Qapital Technology and Services you expressly authorize and grant to Plaid the right, power and authority to act on your behalf to access and transmit your information as reasonably necessary for Plaid to provide services to you on Qapital’s behalf.

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.

The Services contains comment fields and other features that permit you to share information publicly. The Services also may enable you to share personal information with third party websites or online services operated by third parties. For example, our website contains links and widgets for third party websites that incorporate comment and social media features. If you choose to use these features, you may disclose your personal information not just to those third party websites and services, but also to their users and the public more generally. Because these third party websites and services are not operated by Qapital, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and non-personal information on those websites and applications will be subject to the privacy policies of the third party websites or applications, and not this Privacy Policy. Depending on your use of the Services, we may also collect fitness data through Apple Health Kit. If you choose to have the Qapital Technology integrate with your Apple Health Kit, that data may be used to provide certain services, such as linking savings rules to your Apple Health activities. The Mobile App will only have access to the information you choose to link in your Apple Health Kit. Please review Apple’s privacy policy for information on how Apple Health Kit uses and shares your personal information. This Privacy Policy does not apply to the collection and use of your information by Apple Health Kit.

Important Notice About Your Health Information. You should understand that some of the personal information you provide may be related to your health, fitness, or activity levels. Qapital is not a health provider. Unless otherwise established in an agreement between Qapital and a covered entity (i.e., a health care provider, health plan, or healthcare clearinghouse) as defined by the Health Insurance Portability and Accountability Act (“HIPAA”), the Qapital Technology does not collect “Protected Health Information” as defined under HIPAA. Therefore, while your personal information will be used in strict accordance with this Privacy Policy, it will not be subject to HIPAA protection. The Services also integrate certain third party plug-ins (such as a Facebook “like” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.

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 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, 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.

Your California Rights

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. This right granted to California residents applies only to their activities within the State of California. To make such a request, please send an email to

Other than as disclosed in this Privacy Policy, the website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

California Consumer Privacy Act Compliance. If you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (“CCPA”), you are afforded additional rights with respect to your “personal information” as that term is explicitly defined under California law. Any personal information we collect is collected for the commercial purpose of effectively providing our Services to you, as well as enabling you to learn more about, and benefit from, our Services.

Access. You may email us at to request a copy of the personal information our website databases currently contain.

Prohibit Data Sharing. When applicable, you may prohibit the sharing of your personal information by submitting a request via email to In your email, please explain how you wish us to prohibit the sharing of your personal data, and which categories of third parties you want to prohibit from receiving your personal information. When such prohibitions make it not possible to provide our Services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy.

Portability. Upon request and when possible, we can provide you with copies of your personal information. You may submit a request via email to When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy.

Deletion. If you should wish to cease use of our website and have your personal information deleted from our website, then you may submit a request by emailing us at Upon receipt of such a request for deletion, we will confirm receipt and will confirm once your personal information has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

No Sale. The CCPA requires us to disclose whether we sell your personal information. We do not sell your personal information. That said, the definition of ‘sale’ under the CCPA is very broad, and guidelines from the State of California setting forth exactly how companies are required to comply with CCPA are still being developed. We will monitor those developments carefully (and will not sell your personal information without providing a right to opt out if required by California law).

No Discrimination. We will never discriminate against you or take any adverse action against you if you decide to exercise any of your rights afforded to you under California law.

Information Security

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

We recommend that you change your password periodically or any time you have reason to believe your credentials may be compromised. We also recommend that you use a unique password and don’t reuse passwords used on other sites. You are responsible for maintaining the security of your Login ID and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at, but in any event you should change your password immediately via the Services. You also agree that you control and limit access to the email account and mobile device. If your email address changes, you are responsible for informing us of that change. We are not responsible if someone else accesses your account through registration information they have obtained from you or your violation of this Privacy Policy or the Terms and Conditions.


Retention of Your information

Children’s Privacy

Qapital Technology and Services are intended for adult use only. We do not intentionally 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

For Users Outside the United States

Some visitors to and users of Qapital Technologies and Services may be located outside of the United States.  To provide you with our services, we may store, process, and transmit information in the United States, which may not have the same privacy and security laws as your country. Regardless of the country in which such information is stored, we will process your personal information in accordance with this Privacy Policy.

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

Updates to Privacy Policy

We may make changes to this Privacy Policy at any time to take into account new or changing circumstances, so please review it periodically. The date last revised appears at the top of the Policy. We will update the effective date of the Privacy Policy at the time a change is made.

Questions Regarding Privacy Policy

We take the privacy and security of your personal information very seriously and want to earn and keep your trust. If you have any questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send an email to