Hi there! At Portabl, Inc. (“Portabl”, “we”, “us” or “our”), we’re committed to maintaining your confidence and trust. As part of that commitment, we want you to understand our personal information practices. This Privacy Policy (or this “Policy”) is provided to you to explain how we collect, use, and disclose personal information about you in connection with your use of our services including our website at https://www.getportabl.com/ (or other of our websites that may link to this Policy), as well as our mobile apps, and any other services we may offer (collectively referred to as our “Services”).

You may print a copy of this Privacy Policy by pressing print on your browser. If you have a disability and Dneed to access or receive a copy of this Privacy Policy by alternative means, please contact us at privacy@getportabl.com.

“Personal information” is used in this Privacy Policy to refer to any information that relates to a specific natural person, who may be identified in or reasonably identifiable based on the information.

If you have any questions or concerns about this Privacy Policy or our information practices, please contact us at hello@getportabl.com.

Portabl collects personal information for a variety of purposes, and the kinds of personal information that we collect about you depends on how you use or interact with our Services. (For example, personal information we collect about website visitors is different from the personal information we collect about mobile app users.)

Depending on how you use or interact with our Services, we may collect the following kinds of personal information about you:

1. Personal identifiers, contact and biographical information. This is personal information such as your name, home address, e-mail address, or telephone number, as well as demographic information, such as date of birth, your photograph, or information about your employment, finances,.

2. Government identification information. This includes your Social Security number, driver’s license number, or ID numbers from other government documents, and for some Services, we may collect copies of government-issued photo IDs, such as a driver’s license or passport.

3. Payment information. We may collect credit card information or other means of payment, if you use any Services that require payments.

4. Financial information. This includes information about your income, expenses, transactions, or debt, or your credit score and other information from your credit report. If you choose to connect a bank account to Portabl, we will also collect financial account numbers, transaction information, account balances, and other information about your banking activities that you or your bank may make available to us.

5. Social media handles. If you contact us through a social media platform, we may collect your username or social media handle, or other information about you that is available on social media.

The information described above is generally collected directly from users of our Services – as when you submit information to us through our website, mobile apps, or other Services that we offer.

In some of the cases described above, we will collect information that you submitted to third parties from those third parties. For example, this could be from your bank or other financial services you use, from credit reporting agencies, or through social media sites. We may also collect personal information about you from an identity verification service, if you request Services that require us to confirm your identity, and if your traditional ID (such as a driver’s license) cannot be verified, or if there are other issues confirming your identity.

In addition to the personal information described above, we also collect information automatically, whenever any person visits our website or uses our other Services. This automated technical information, which may also be personal information about you, includes:

1. Technical and usage information. When you visit and navigate through the Portabl website, mobile apps or other Services, we automatically collect technical and usage information about your computer or device, and your activities when you interact with our Services, such as your IP address, device identifiers, browser type, operating system, geolocation, web pages that visit before and after accessing Portabl webpages, the specific Portabl webpages, links, or features you viewed or used and the times those were viewed or used, and other usage statistics and “clickstream” data.

2. Data collected through cookies, pixel tags and similar technologies. A cookie is a small text file stored on your computer or device when you visit our website or other Services. We use cookies to identify you or your device to our Services, and for security purposes, to facilitate site navigation, to perform analytics, and to personalize your experience while visiting the website. We also use pixel tags, which are small files embedded in webpages and email. We use pixel tags to track whether users visit specific pages of the website, downloaded a particular document, or opened a Portabl email.

To provide the Services and operate our business. We generally use the personal information we collect to manage and operate our business, and to provide our Services, as described in the following purposes of use:

1. To provide our Services.

2. To communicate with users of our Services, including communications that are part of the use of the Services as well as other administrative communications.

3. To verify your identity where it’s necessary to do so to provide our Services.

4. To facilitate banking or other financial transactions for users of our Services.

5. To provide customer support and customer service, including answering any questions and responding to requests that we receive.

6. For payment purposes, if you use any Services that require payments.

7. For marketing purposes, including communications about Portabl’s Services, company developments and news, or about other third-party products or services that you may be interested in.

8. For internal business operations and business management.

9. To perform research and analysis, which is used to develop and improve our Services and the delivery of our Services, or to better understand our users’ interest in third-party products and services.

For legal, safety, and security purposes. We may also use personal information to comply with law or for safety and security reasons, as follows:

1. We may use and share personal information as we believe necessary or appropriate to comply with laws that apply to Portabl and to support our bank partners’ compliance with applicable law, including anti-money laundering (AML) and sanctions screening rules.

2. We may use and share personal information to respond to lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities.

3. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (i) protect our or others’ rights, privacy, safety or property (including by making and defending legal claims); (ii) audit our internal processes for compliance with legal and contractual requirements; (iii) enforce the terms and conditions that govern the Services; and (iv) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create anonymous data. We also use personal information to generate aggregated, deidentified or otherwise anonymous data, which does not directly identify and could not reasonably be used to identify any specific individual. We use this anonymous data to understand, develop, improve, and market our Services, and it may be used or shared with third parties for any lawful purpose.

For other disclosed purposes and with consent. We may also use personal information for other purposes that are disclosed at the time you provide personal information, or purposes where we obtain your consent.

Depending on how you use or interact with our Services, we may share personal information with third parties as follows:

1. Service providers. We share personal information with third-party service providers that perform business-related functions on our behalf, such as website hosting and support, conducting research and data analysis for us, and performing marketing functions for us. We will only disclose personal information to service providers as needed for them to provide services. Our service providers are only permitted to use this personal information on our behalf, to provide services, and they are obligated to protect the confidentiality of personal information.

2. Bank partners and other partner organizations. When you use certain of our Services, we will need to share your personal information with our partner banks or technology providers and those partners will maintain and independently control copies of your personal information. In these cases, we will notify you of the relationship and obtain your consent in order to share this information.

3. Business transfers. We may share your personal information with another entity during the negotiation of or as a result of a merger, acquisition, reorganization, sale or other change of control of our business. In the event that such a transaction occurs, your personal information may be part of the assets transferred to the other entity.

4. As required by law. We may use and share personal information as we believe necessary or appropriate to comply with laws that apply to Portabl and to support our bank partners’ compliance with applicable law, and to respond to lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

5. For legal, compliance, safety, and security purposes. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (i) protect our or others’ rights, privacy, safety or property (including by making and defending legal claims); (ii) audit our internal processes for compliance with legal and contractual requirements; (iii) enforce the terms and conditions that govern the Services; and (iv) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

6. At your direction or with your consent. We may also share your personal information with third parties at your direction or with your consent.

No sale of personal information. We disclose the categories of personal information as described above for our business purposes. We do not sell personal information to third parties.

No disclosures for third parties’ direct marketing. It is our policy not to provide your personal information to third parties for those third parties’ direct marketing purposes, without your consent.

We retain personal data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases, we retain personal information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain anonymous or aggregated information, in a form that does not and could not reasonably be used to identify any specific individual.

In your use and interaction with our Services, you have certain choices and controls with respect to the use of your personal information, which are described here.

1. Update Your Personal Information. If your personal information changes (for example, to change your email address), you can update the information directly through the mobile app.

2. Choose not to provide personal information or not use the Services. You can always decide not to provide us with personal information or not to use certain Services that require your personal information. But please understand that if you choose not to provide personal information to us, you may not be able to create an online account with Portabl or use Services that we offer.

3. Opt out of marketing emails. We may use your name and email address to send Portabl-related promotional emails to you. You can direct us to stop sending promotional emails by following the “unsubscribe” or similar instructions that are included in any Portabl-related promotional email you receive. Your opt-out request will be processed within 30 days of the date on which we receive it. Please understand that, even if you opt out of marketing emails, you will still receive service-related, account-related, or other non-promotional emails from Portabl.

4. Delete or close your account. You close your account by clicking “REMOVE ACCOUNT” from your Portabl profile. After you delete your account, you will not be able to log into the Portabl website, apps or access any of your Personal Information. After you close your account, we will work to remove your information from our systems. However, it is not always possible to completely remove or delete all of your personal information, as personal information may be retained to comply with legal requirements or for necessary business functions, or may remain in archival data. Also, if we shared your information with partner organizations as described in this Privacy Policy, those companies may not be required to delete your information. (Also, you can open a new account at any time, if you choose to do so.)

5. Cookies. As described in this Privacy Policy, we use cookies to gather information and enhance users’ experience of the Services. You may configure your internet browser to reject or disable cookies, as described in documentation for your browser. Please understand, however, that rejecting or disabling cookies may affect your experience of our website or other Services, or interfere with your ability to access our Services.

We take information security seriously, and we have implemented an information security program that includes physical, technical, and procedural safeguards that are reasonably designed to protect the personal information that we collect or that you may provide to us.

You may store certain of your personal information in a “vault” either on Portabl’s cloud-based systems or on your mobile device. Data stored in either location is encrypted and can only be accessed by you. In addition, we restrict access to any of your personal information stored outside the “vault” to only authorized employees for permitted business purposes, and we require our third-party service providers to protect your personal information and use it exclusively for the purpose of performing certain business functions on our behalf.

However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Although we take steps to secure your information, we cannot ensure or promise that the information you transmit to us will remain secure.

You are also responsible for the security of your Portabl account. You also need to maintain the confidentiality of your personal information too. You should be careful in how you share personal information with others and avoid sending any sensitive personal information through unsecure, unencrypted email. Do not provide your username and password to the Portabl website or apps to others. If you become aware of any suspicious activity associated with your online account on the getPortabl.com website, contact us immediately at privacy@getportabl.com.

Portabl’s Services, including our website, and web and mobile apps, are not directed to children. We do not knowingly collect personal information through the Services from children younger than 18 years of age. If a parent or guardian becomes aware that his or her child younger than 18 has provided us with personally identifiable information without his or her consent, he or she should contact us at privacy@getportabl.com. If we become aware that we have unknowingly collected personally identifiable information from a child younger than 18 years of age, we will make reasonable efforts to delete such information from our records.

We maintain offices and facilities in the United States, and personal information may be transferred to the United States or other locations outside of your state, province, or country of residence, where privacy laws may not be as protective as those in the state, province, or country you resides.

We may update this Privacy Policy from time to time to reflect changes in our information practices. If we make material changes to the Privacy Policy, we will provide notification by updating the “Effective Date” date at the top of the Privacy Policy and posting the new Privacy Policy to our website or other Services. We may also notify you about updates through email (sent to the email address specified in your account) or other reasonable means to alert you to changes. We encourage you to periodically review the Portabl website or app for the latest information on our privacy practices.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at privacy@getportabl.com.