Privacy Policy

This privacy policy describes the types of information Upward Financial Inc. (collectively, “Upwardli,” “we,” or “us”) may collect from you, or that you may provide when you use, access or interact with our Services described in our Terms of Service.

This privacy policy describes our practices for collecting, using, maintaining, protecting, and disclosing that information. It also describes the choices available to you regarding our use of your personal information and how you may access and update this information. Please read this policy carefully to understand our practices regarding your information and how we may treat it.

This Policy gives you notice about how Upwardli collects, uses, and share information in connection with your access and use of our Services. This policy does not cover the privacy practices of third parties that we do not own or control, including by any third party, including through any application or content that may link to or be accessible from or on the Service. Your use of the Upwardli Services you may also be covered by the Cross River Bank Privacy Notice and certain other privacy agreements set forth below.

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How We Collect Your Information

If you open an account or use the Upwardli Services, we may collect the following types of information:

• Personal information - your name, date of birth, Social Security number, address, phone, email, third-party application IDs, and other similar information.
• Financial information - bank account online login information, bank account numbers, bank account details including transaction history, routing numbers and/or debit card numbers and credit card numbers that you link to your Upwardli account or you give us when you use the Services. Before permitting you to use the Services, we may require you to provide certain information, including but not limited to your date of birth, social security number. We may use this information or other information you provide to verify your identity in accordance with applicable banking laws.
• Information about your use of the Service - we automatically collect certain information about how you access and interact with our Services (“Usage Information”). This Usage Information is a key part of how we offer and improve our Service and provide you with personalized financial insights and service recommendations. we may collect information sent to us by your computer, mobile phone or any other device. This information may include your IP address, device information including but not limited to identifier, name and type, operating system, location, mobile network information and standard web log information, such as your browser type, traffic to and from our site, the pages you accessed on our website, and any other available information. We may also collect information about your use and interaction with our website, application or the Service
• Non-Personal Information: This is information about you or your household that doesn’t identify you personally, like your gender, income or what types of financial services products you may be interested in.

When we combine information that isn’t Personal Information (like Non-Personal Information or Usage Information, defined below) with Personal Information or Financial Information, we will treat it like Personal Information provided that it remains combined with Personal Information.

INFORMATION WE AUTOMATICALLY COLLECT

We may collect:

1. Device Information. This is information about how you access our Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device. We may also integrate with built-in device features such as facial recognition or other biometric access for your account via our apps.
2. Log Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with our Services, such as which features you visit or click on. This Log Information may also include things like your IP address, browser or device configuration, date and time of access and cookie information.
3. Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). We may also request to use location-enabled services on your device to enhance our Service with your consent.

We and our partners may use various technologies to collect and store Usage Information in connection with our Services. These may include things like cookies, Google Analytics, session recording, browser web storage (e.g., HTML5), web beacons and similar technologies.

At this time, we do not respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser. Please note that blocking cookies may affect your browsing experience on many sites and may limit your ability to use certain features of our Services, including many of the personalized features we provide for our members.

INFORMATION THIRD PARTIES PROVIDE ABOUT YOU

Our Service relies on information about you that we collect and verify from third parties, such as the credit reports and credit scores requested on your behalf from credit bureau partners and identity databases. We may also work with different third party partners to supplement Usage Information and other information we collect directly from you. For example, our partners may provide us with information about products or offers available based on your Account Information or credit profile so that we can give you more useful, personalized recommendations. We may also collect information from other users of our service through things like our member referral program.

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How We Use Your Information

We use the information we collect from you and third parties to operate our Services, communicate with you, conduct research and development to improve or enhance our Services and our users’ experience, and promote our Services.

To create your account and provide our Service. We use the information we collect to create and secure your account, create and maintain your Account Information, and to provide the Services to you.

To provide Service features and personalized to you. We use the information we collect to provide you with personalized financial service recommendations, credit report and credit score monitoring, and financial education and personalized financial insight.

To improve our Service. The information we collect also helps us tailor our content and improve the way we match you to recommended services and financial insights.

To communicate with you. We use information we collect to provide you with member support or to send you things like service-related announcements, credit score movement notifications, personalized insights, product or service recommendations, offers from our partners and other updates or promotions. We communicate electronically, via email, push notification and offline via physical mail.

To conduct research and to enhance our Services. We use the information we collect to conduct research and to improve or enhance and promote our Services.

To maintain regulatory compliance. Certain of our Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our Services in order to comply with anti-money laundering laws. We must collect and store that information.

For legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to: (a) comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law; and (b) enforce our Terms of Service

To prevent or detect fraud. We use the information to protect the safety, integrity, rights or security of our members, our Services or equipment, or any third party; detect, prevent or otherwise address fraud, security or technical issues related to our Services or our partners.

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How We Protect Your Information

Upwardli stores and processes your information maintaining physical, electronic and procedural safeguards. We maintain physical security measures to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorize access to personal information only for those employees or agents who require it to fulfill the responsibilities of their jobs.

The security of your Personal Information is important to us. Where you have chosen, a password for access to certain features of our Service, you are responsible for keeping this password confidential. Do not share your password with anyone because it could compromise the security of your Personal Information.

When you enter sensitive information, such as your credit card number, on our order forms, we or our partners encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security or your information.

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How We Share Your Information

We do not share your personal information with third parties for the third parties’ direct marketing purposes.

We may disclose your personal information as described in this policy:

1. To contractors, service providers, and other third parties to support our business and the delivery of the Services. These parties are authorized to use your personal information only as necessary to provide these services to us.
2. To financial institutions with which we partner to process the payments you have authorized.
3. To third parties with your consent to fulfill the purpose for which you provided it, such as submission of a pre-approval application to a financial service or a request for service from that third party.
4. With third party identity verification services to confirm your identity for regulatory or anti-fraud purposes. For example:
5. We use Persona Identities, Inc. (“Persona”) to verify your identity by determining whether a selfie you take matches the photo in your government issued identity document. The information collected from your photo may include biometric data. Persona’s Privacy Policy, available at https://withpersona.com/legal/privacy-policy, describes its collection and use of personal information.
6. We use Plaid, Inc. ("Plaid") to connect your Upwardli account with your bank account, verify your bank account and confirm your bank account balance prior to approving a transaction. Information shared with Plaid is treated by Plaid in accordance with its Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.
7. As part of a business transfer. If we involved in a merger, acquisition, or sale of all or a portion of its assets. If such a transfer results in a material change in the treatment of your Personal Information, you will be notified by e-mail (using the email address on your Account Information) or by a prominent notice on our site.
8. For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes, and as permitted by law.
9. To Prevent Fraud. We reserve the right to transfer or disclose information about you to third parties to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and for required institutional risk controls.
10. With Your Consent. There may also be other limited contexts in which we share specific types of personal information with your express consent.

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

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Retention of Personal Information

We store your personal information securely throughout the life of your Account. We only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under applicable laws.

LINKS TO OTHER WEBSITES

Our Service includes links to other websites whose privacy practices may differ from ours. If you submit personal information to any of those websites, their privacy policies govern your information. Remember that any information you provide to these third parties, whether through our Service with your consent or on your own, will be subject to the third party’s privacy practices and terms and conditions.

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How to Update or Change Your Account

Accessing and Updating Your Account Information

You are responsible for maintaining the accuracy of your Account Information. You can access and make changes to certain Account Information by logging in to your account through our Services and updating your “Account Information” page.

Communications Preferences

You can manage your communications preferences by visiting your account profile. We include “unsubscribe” instructions in marketing emails. You also have the ability to adjust app- or browser-specific communications settings within the settings screen of your mobile app or browser. Note that the types of communications and communication preference options might change from time to time.

Canceling Your Membership and Deactivating Your Account

If you decide you no longer want to use our Services, you can cancel and deactivate your account on our help page. Due to our record-keeping and information retention requirements, we do not delete all information about you upon deactivation. We will, however, disable your account and stop sending you further communications.

Public Form Disclosure

The Service offers publicly accessible blogs, service reviews and community forums. You should be aware that any information you provide in these areas are posted and transmitted at your own risk and may be read, collected, and used by others who access them. We urge you to carefully consider your submissions in these public areas and ask you to take care regarding the sharing of information that could identify you personally. The information you share in these public forums may be viewed by the public or other users of the Service.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may be entitled to additional rights over your Personal Information. For more information about those rights and how to exercise them, please see our California privacy notice here, which is incorporated by reference into this policy.

CHILDREN UNDER THE AGE OF 13

Our Service is not intended for children under 18 years of age. No one under age 13 may use or provide any information to or on the Service. We do not knowingly collect Personal Information from children under 13. If you are under 13 years of age, do not use or provide any information to this Service or on or through any of the features on this Service, use any of the interactive or public comment features of this Service, or provide any information about yourself to us. If you believe we might have collected any information from or about a child under 13, please contact support@upwardli.com.

NOTIFICATION OF CHANGES TO OUR PRIVACY POLICY

We may update this privacy policy to reflect changes to our information practices at our sole discretion. If we make any material changes to how we treat Personal Information, we will notify you by email using the address provided by you in your Account Information or by means of a notice posted on the Upwardli website. You are responsible for ensuring we have an up-to-date active and deliverable email address for you in your Account Information and encourage you to periodically review this page for the updates or changes to our privacy practices.

CONTACT INFORMATION

You can contact us about our privacy policy by contacting us at: Upward Financial Inc., 2400 NW 80th Street, Suite 245, Seattle, WA 98117 or emailing us at legal@upwardli.com.