LAST UPDATED September 16, 2020
Information We Collect
We collect different types of information, from various sources, in order to operate effectively and efficiently, and to provide you the best products, services and experiences that we can, such as:
We collect information when you provide it to us, such as when you register, sign in, or call us for support.
We may automatically collect information when you visit our web sites, use our products or services, or complete a web form, or through technologies like cookies, beacons, web logging, software on your computer or device, or by using other technologies or analytical monitoring and reporting tools.
We may get information from other companies or third parties.
The type of information we collect may include: name and contact information; your user name and password; payment and financial data; information that includes third party content and functionality, (if you use third party-connected services); usage data (i.e. information about how you interact with various products and services, including third party products and services); contacts and relationship information; information about the devices you may use to connect to products and services; and feedback information, if you as a user provide us feedback and suggestions.
With your approval, Approve Owl automatically connects to and downloads financial information, such as current account balances and transactions, from your financial institutions, which requires Us or Our third-party partners to collect identifiers such as your username and password, or a security token. In some cases, we may also collect your phone number, email address, security questions and answers, and one-time password (OTP) to help verify your identity before connecting your financial accounts. When providing this information, you give us and our third-party vendors involved in the service the authority to act on your behalf to access and transmit your information from the financial institution or other entity that provides your financial accounts.
The information we receive from the financial product and service providers that maintain your financial accounts may vary, but, in general, we collect the following types of identifiers, commercial information, and other personal information from your financial product and service providers:
- Account information, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, and account and routing number;
- Information about an account balance, including current and available balance;
- Information about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
- Information about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
- Information about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
- Identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information;
- Information about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and
- Professional information, including information about your employer, in limited cases where you’ve connected your payroll accounts. The data collected from your financial accounts includes information from all your accounts (e.g., checking, savings, and credit card) accessible through a single set of account credentials.
We may use the information we collect about you to derive inferences. For example, we may infer your location or your projected income based on the information we have collected about you from other sources.
How We Use Your Information
We use your Information for a number of business and commercial purposes, including to operate, improve, and protect the services we provide, and to share with third-parties whom you have authorized to receive such Information. Specifically, we use your Information:
- To operate, provide, and maintain our services;
- To improve, enhance, modify, add to, and further develop our services;
- To protect you, ourselves, our subsidiaries and affiliates, our partners, and others from fraud, malicious activity, and other privacy and security-related concerns;
- To develop new services;
- To provide customer support to you or our partners, including to help respond to your or their inquiries related to our services or applications;
- To investigate any misuse of our service or applications, criminal activity, or other unauthorized access to our services; and
- For other notified purposes with your consent.
How We Share Your Information
We share your Information for a number of business purposes:
- With any third-party whom you have authorized and directed to receive Information from one of our services or applications;
- To enforce any contract with you;
- With our data processors and other service providers, partners, or contractors in connection with the services they perform for us;
- If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
- In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
- Between and among our current and future subsidiaries;
- As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, ourselves, our subsidiaries and affiliates, our partners, and others; or
- For any other notified purpose with your consent.
We may collect, use, and share Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.
We do not sell or rent personal information that we collect.
How We Retain Your Information
Please refer to the “Special Data Protection Rights” section for options that may be available to you, including the right to request deletion of Information. You can also contact us about our data retention practices using the contact information below.
Security of Your Information
We take the security of your Information seriously. We use technical and administrative security measures including, but not limited to, firewalls, encryption techniques, and authentication procedures.
International Data Transfers
Special Data Protection Rights
Under applicable law, and subject to limitations and exceptions provided by law, if you are located in certain jurisdictions, you may have special rights in relation to the Information collected about you and how it is used, including the right to:
- Access Information collected about you;
- Request that we rectify or update your Information that is inaccurate or incomplete;
- Request, under certain circumstances, that we restrict the processing of or erase your Information;
- Object to our processing of your Information under certain conditions provided by law;
- Where processing of your Information is based on consent, withdraw that consent;
- Request that we provide Information collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible; and
- File a complaint regarding our data protection practices with a supervisory authority.
Under the California Consumer Privacy Act (“CCPA”), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to Information we have collected about you that constitutes personal information under the CCPA:
- To request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes);
- To request deletion of your personal information;
- To opt-out of any “sales” of your personal information, if a business is selling your information; and
- To not be discriminated against for exercising these rights.
To exercise your data protection rights, where applicable, you can submit a request using our online form (available here), or contact us as described in the “Contact Us” section below. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.
We will consider all such requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.
We may update, amend, revise, replace, or change this Policy from time to time. If we make any updates or changes, among other things, we will post the new policy on our website, ApproveOwl.com, and update the effective date.
ThirtySixteen Group, LLC
6210 N Belt Line Rd, Ste 150
Irving, TX 75063