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Last Updated: October 16, 2019
Under Technologies Inc., dba Rho Technologies, together with its affiliates (collectively "Rho", "we", "us", “our”) places a high priority on the privacy of individuals who visit our Site (as defined below) and/or who cause the businesses they represent to use our cloud-based hosted services (“you” or “User”) including our banking platform or any of our other websites, networks, applications, mobile applications, or other services provided by us (collectively, the "Rho Service"). When any of these activities occur, your Personal Information may be collected and processed by Rho.
This Policy is designed to explain how we collect, use, store, retain, disclosure by transmission, disseminate or otherwise make available (collectively “Process”) your Personal Information. Please be aware that the Rho Service is integrated with certain “Third Party Servicers” including, but not limited to Evolve Bank & Trust, Member FDIC (“Evolve”). The privacy policies of these Third Party Servicers will govern their collection, use, disclosure and processing of your Personal Information.
WHAT IS PERSONAL INFORMATION
“Personal Information” is any information that can be used to identify you. It includes, but is not limited to, name, date of birth, home address, billing and shipping address, email address, photograph, government-issued identification information (such as driver’s license number, social security number or passport number), financial information (such as bank account details, payment card numbers, credit reports), authentication details, and IP address or other device information. Personal Information does not include information that does not identify a specific person.
PERSONAL INFORMATION WE COLLECT
You are not required by law to provide us with any Personal Information. However, our ability to provide all features on the Site and Rho Service to you may be conditioned on you voluntarily providing us with your Personal Information.
We collect Personal Information in any of the following ways. The type of Personal Information we collect varies depending on the type of interaction you have with us:
WHEN PERSONAL INFORMATION IS COLLECTED AND RETAINED
As described above, in some cases you may provide us with Personal Information directly, such as by entering Personal Information into an online or offline form or application or communicating with us, including with our Customer Support Team, via phone, fax, Site or email. In other cases, it may be provided to Rho indirectly, such as the IP address of the computer or device you use to connect with us online or by a Third Party Servicer from whom you seek to obtain services or are obtaining services. We may also obtain Personal Information from publicly available sources in connection with any credit investigation or identity or account verification process, collection procedure, fraud detection process or as may be required by law.
Rho will store your Personal Information only for as long as is reasonably necessary to provide the Rho Service and to facilitate your use of Third Party Servicers’ services or to comply with applicable law, taking into consideration our relationship with you, the Third Party Servicers’ relationship with you, our or their service providers’ relationship with you, the purposes stated in this Policy, our need to resolve disputes or claims or assist with investigations, and our need to respond to requests for such information from government regulatory authorities and other organizations, or otherwise comply with legal and regulatory requirements under applicable law.
HOW WE USE YOUR PERSONAL INFORMATION
We may use Personal Information to:
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your Personal Information in accordance with this Policy, for the purposes described in Section IV. In addition:
Rho does not disclose, and has not in the preceding 12 months disclosed, Personal Information to third parties for marketing purposes without your consent.
Cookies are small data files that are stored in your device memory or on your hard drive when you visit a website. Cookies may be used as a mechanism to recognize you, record behavior, and/or customize your experience with the Site. They can also be used to monitor Site activity, mitigate risk, measure the effectiveness of promotions and prevent potential fraud. If you choose to disable cookies, your use of the Site may be limited or otherwise affected. By using this Site, you permit us to collect and use your information related to Site access and device activity. You can learn more about cookies by visiting http://www.allaboutcookies.org.
By using the Site, 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 the Rho Service.
THIRD PARTY ANALYTICS VENDORS
We may use third party analytics vendors to evaluate and provide us with information about your use of the Site and/or the Rho 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 Site 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.
INFORMATION ABOUT ONLINE TRACKING
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described more fully throughout this Policy, we limit our use and collection of your Personal Information.
For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the All About Do Not Track website: http://allaboutdnt.com.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
The Rho Service and the purposes for which your Personal Information is processed may cause your Personal Information to be processed and/or stored outside of the United States. Therefore, your Personal Information may be sent to other countries with data protection standards that differ from those of your home country. By supplying your Personal Information to Rho either directly or indirectly, you consent to your information being transferred across international borders to Rho and its affiliates, vendors, and agents. Vendors and other outside contractors we engage are subject to our contractual requirements for safeguarding Personal Information.
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.
At Rho, security is a priority. We use certain physical, organizational, and technical safeguards that are designed to protect Personal Information submitted to us, and we employ appropriate measures, including advanced technology, to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. These measures may include, among others, physical access security, administrative security measures, data encryption, firewalls, and other appropriate technologies. Rho reviews and enhances its security systems as necessary. Notwithstanding Rho’s efforts, no security measure is perfect or impenetrable and no method of transmission over the internet or electronic storage is 100% secure. Therefore, Rho cannot guaranty complete security of the transmission or storage of your Personal Information.
It is important that you maintain the security and control of your account credentials, and not share your password with anyone. We offer our Users two-factor authentication which is designed to protect their account. Please make use of this added protection.
THIS WEBSITE MAY BE LINKED TO OTHER WEBSITES
We may also create links to third-party websites (for example, the All About Do Not Track website linked above). Rho’s Policy and privacy practices do not apply to these websites and Rho is not responsible for the privacy practices employed by any of these third-party websites. Rho is not responsible for any content on websites linked from or to this Site. Rho does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked websites. Rho provides any such links as a convenience only and your connection to and use of any linked website is at your own risk.
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 Rho 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 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.
THE SITE AND RHO SERVICE ARE NOT DIRECTED AT PERSONS UNDER THE AGE OF 13
The Rho Service are intended for business use only and is not directed at persons under the age of 13. If you are a parent or guardian and believe we may have collected information about a person under the age of 13, please contact us at the email address or phone number set out at the beginning of this Policy. If we determine that we have inadvertently collected Personal Information from a person under the age of 13, we will promptly delete such information from our records to the extent permitted by applicable law.
The "Last Updated" date at the top of this page indicates when this Policy was last revised. From time to time, Rho may make changes to this Policy, so we encourage you to check back and review it regularly to ensure you are aware of current practices. Changes will be communicated through the Website or through your Rho Service account. If the amendment or revision is required in order for Rho and the Rho Service to remain in compliance with applicable laws or regulations, then the amendment or revision shall take effect as of when it is posted to the Website or your Rho Service account. If, on the other hand, the amendment or revision is not required under law, and you do not close your Rho Service account within thirty (30) days of notice of the amendment or revision on the Website or in your account, then you shall be deemed to have accepted the amendment or revision. If you disagree with the changes, you must stop your use of the Rho Service and discontinue use of our Website. Your continued use of the Rho Service and/or the Website following the effective date of any change, constitutes your consent to any modification to this Policy.
If you have any questions about this Policy, or you want to make a complaint regarding any breach of your privacy by us, or you want to correct or update your Personal Information in our possession, you may contact us by email at firstname.lastname@example.org or call us at toll free (US) at 1 855-743-8746 or through the support page in the web application.