Effective Date: January 1, 2020
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:
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:
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.
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.
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.
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
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.
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 firstname.lastname@example.org, 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 email@example.com. 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.
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.
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.
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.
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.
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.
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.
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.
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 firstname.lastname@example.org. We are not responsible for costs or other issues arising from your failure to keep your personal information up to date.
You may request that we delete your account for the Services. To request deletion of your account, email email@example.com, 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.
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 firstname.lastname@example.org
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 email@example.com to request a copy of the personal information our website databases currently contain.
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 firstname.lastname@example.org. 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.
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).
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.
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.
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 email@example.com.
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.