Our Privacy Policy

Last Updated: March 21, 2019

Under Technologies Inc, dba Rho Technologies, together with its affiliates ("Rho", "we", "us") values the privacy of individuals who visit our banking platform, and any of our other websites, applications, or services that link to this Privacy Policy (collectively, the "Service"). The Service allows users that have created an account with us ("Users", "you") to banking and credit services from Rho. This Privacy Policy ("Policy") is designed to explain how we collect, use, and share information from Users of the Service. This Policy is incorporated by reference into our Terms of Service. By agreeing to this Policy in your account setup or by using the Service, you agree to the terms and conditions of this Policy.

INFORMATION WE COLLECT

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Information You Provide Us

We collect any information you provide to us when you use the Service. You may provide us with information in various ways on the Service.

Registration: When you register for an account, you are required to provide us with certain personal information including: name, address, phone number, and email address and to designate a password. You are also required to provide us with information that helps us verify your identity to facilitate compliance with applicable legal requirements, including: social security number, date of birth, proof of identity, such as driver’s license or passport, tax documents, occupation, and employer.

Financial Information: Users may make transfers to and from their account. To facilitate these transactions we will collect necessary financial information, such as your bank's routing number and your account number or your credit card information.

Communications: If you contact us directly, we may receive additional information about you. For example, when you email our Customer Support Team, we will receive your email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.

Referrals: The Service may offer a referral program so you can tell your family and friends about the great services we offer. By participating, you may provide us with certain information about the person to whom you refer our service, such as name and e-mail address. You represent that you have the authority to share this information with us, which we will treat in accordance with this Policy.

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Information We Collect Automatically From Your Use of the Service

When you use our Service, we may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Service, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, location data, and information about your usage of our Service.

We may use this information, for example, to ensure that the Service functions properly, to determine how many users have visited certain pages or opened messages, or to prevent fraud. We also work with analytics providers which use cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. If you do not want information collected through the use of cookies, there is a procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Service.

HOW WE USE IT

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How We Use Your Information

We may use the information we collect:

  • To facilitate online bank account creation and administration of the account, and to validate your actions to perform secondary actions, such as wire transfers, on your behalf.
  • To prevent fraud and other illegal activity on the Service. We may also connect your meta-data to your personal information for this purpose only.
  • To operate, maintain, enhance and provide features of the Service, to provide services and information that you request, to respond to comments and questions, and otherwise to provide support to Users.
  • To understand and analyze the usage trends and preferences of our Users, to improve the Service, and to develop new products, services, features, and functionality.
  • To contact you for administrative or informational purposes, including by providing customer service or sending communications, including changes to our terms, conditions, and policies.
  • For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest.
  • To personalize your experience on the Service by presenting tailored content.
  • We may aggregate data collected through the Service and may use and disclose it for any purpose.
  • For our business purposes, such as audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention.
  • To enforce our Terms of Service or other legal rights.
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How We Share Your Information

We disclose information that we collect through the Service to third parties in the following circumstances:

  • To credit bureaus and other third parties who provide Know Your Customer and Anti-Money Laundering services.
  • To our third party service providers, including SynapseFI and Evolve, who provide services such as website hosting, payment processing, data analysis, customer service, email delivery, auditing, advertising, and other services.
  • With marketing services companies so they may market directly to you. You may opt out of this if so desired by emailing help@rho.co.
  • To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
  • If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

In addition, we may use third party analytics vendors to evaluate and provide us with information about your use of the Service. We do not share your information with these third parties, but theses analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different websites. For example, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners.

We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose, unless we are prohibited from doing so under applicable law.

YOUR PROTECTION

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Social Security Number Protection Policy

Rho collects social security numbers as necessary to meet legal banking requirements and to facilitate our services. We will protect the confidentiality and security and prohibit the unlawful disclosure of all social security numbers that we collect. Access to these social security numbers will be limited to those employees who need such access to perform their job and we will document when employees can keep, access, and transport social security numbers from Rho’s facilities.

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Other Important Information

THIRD PARTY SERVICES

We may display third-party content on the Service. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of and/or interacting with the third-party content on the Service. This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Service link. The inclusion of a link on the Service does not imply endorsement of the linked site or service by us or by our affiliates.

SECURITY

We use certain physical, organizational, and technical safeguards that are designed to maintain the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. It is important that you maintain the security and control of your account credentials, and not share your password with anyone. In addition, we offer our Users two-factor authentication which is designed to protect their account. We will store your personal information under these security safeguards for seven (7) years after your account is terminated.

YOUR CHOICES

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. Users may update, correct, or delete certain account information at any time by accessing your account preferences page. Some account information may not be changed due to legal banking requirements. From time to time, we send marketing e-mail messages to 5 Users. If you no longer want to receive such emails from us on a going forward basis, you may opt-out via the "unsubscribe" link provided in each such email.

USE OF SERVICE BY MINORS

The Service is not directed to individuals under the age of eighteen (18), and we request that they not provide personal information through the Service.

INTERNATIONAL CROSS-BORDER DATA TRANSFER

Rho uses servers hosted in the United States. Please note that we may be transferring your information outside of your region for storage and processing in the United States and around the globe. By using the Service you consent to the transfer of information to countries outside of the United States, which may have data protection rules that are different from those of the United States.

UPDATES TO THIS PRIVACY POLICY

We may make changes to this Policy. The "Last Updated" date at the top of this page indicates when this Policy was last revised. If we make material changes, we may notify you through the Service or by sending you an email or other communication. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices. Your use of the Service following these changes means that you accept the revised Policy.

CONTACT US

If you have any questions about this Policy, please contact us at help@rho.co.