Act2 Financial Privacy PolicyLast updated: April 1, 2021Act2 Financial LLC (“Act2,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices submitted on our website https://www.act2financial.com (the "Website"), through social media, and the related mobile application ("App"). This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service. Federal law also requires us to tell you Before using submitting any Personal Data to Act2, please review this Privacy Policy carefully and contact us if you have any questions. By using our Website, submitting any Personal Data to us or using any mobile app we offer, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise submit any information to us.1. PERSONAL DATA WE COLLECTWe collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:Personal Data You Provide: The types of Personal Data we collect. We collect Personal Data when you register an account, link financial accounts and contact support. We also collect your Account Data from Third-Party Data Sources on your behalf and any other information you submit through your use of the App. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include name, email, telephone, location, the financial information necessary to ensure payments can be processed by our payment processor Stripe, Inc. (“Stripe”), and, if a user's financial accounts are connected, Account Data). Account Data may include transaction data such as the financial institute, account name, account type, account number, transaction type, identity of merchants, amount, currency. We also may collect certain information about your credit history, your investments and other similar activity. Accordingly, in addition to this Privacy Policy and our Terms of Service, information related to your purchases is also processed according to the services agreements and privacy policies of Stripe and Plaid. We will send push notifications to your device to inform you of unusual activity, reminders and/or updates or changes. To stop push notifications, you can edit your settings in the preference page or at the device level.Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.Personal Data We Receive Automatically From Your Use of the Website or App: When you visit, use, and interact with the App or our Website, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that use the App or visit our Website, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the App (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems: • Log data: Information that your browser automatically sends whenever you visit the site (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site. • Cookies: Please see the “Cookies” section below to learn more about how we use cookies.• Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. • Usage Information: We collect information about how you use our App, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.Cookies: We use cookies to operate and administer our Website, gather usage data on our Website, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.Email Pixels: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Website and enhance your experience when you use the Website. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Website and use that information to send targeted advertisements. Our Website currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so. Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:• Internet Explorer• Mozilla Firefox• Google Chrome• Apple SafariPlease note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Website and you may not be able to benefit from the full functionality of the Website.Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.If you access the Website on your mobile device, you may not be able to control tracking technologies through the settings. 2. HOW WE USE PERSONAL DATAIn this section, we list the reasons why we collect and can share your Personal Data, the reasons we choose to share and whether you can limit the sharing. We may use Personal Data for the following purposes:• To provide the App that allows ongoing monitoring of financial accounts and alerting services.• To respond to your inquiries, comments, feedback, or questions;• To send administrative information to you, for example, information regarding the App and changes to our terms, conditions, and policies;• To analyze how you interact with our App;• To maintain and improve the content and functionality of the App;• To develop new products and services;• To prevent fraud, criminal activity, or misuses of our App, and to ensure the security of our IT systems, architecture, and networks; • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties; and• To send you a newsletter or other useful information.Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our App, to improve and add features to our App, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Apps and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Apps, through cookies, and through other means described in this Privacy Policy. Act2 does share this information and you cannot limit the sharing.Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. Act2 does share this information and you can limit this sharing.3. SHARING AND DISCLOSURE OF PERSONAL DATAIn certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:• Provision of the App: Personal Data will be disclosed to users designated by you within the App.• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data. Act2 does share this information and you can limit this sharing• For joint marketing with other financial companies. Act2 does not share this information.• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Apps, or the public, or (v) protect against legal liability.• Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Act2. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy. Act2 may share this information and you can limit this sharing.To the extent applicable, Federal law gives consumers the right to limit only:• sharing for affiliates everyday business purposes - information about your creditworthiness• affiliates from using your information to market to you• sharing for non-affiliaes to market to you• State laws and individual companies may give you addiitonal rights to limit sharing.4. DATA RETENTIONWe keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is the longer.5. GRAMM-LEACH-BLILEY ACTOnce we deploy our App, we may be considered a financial company. If so, under federal law (the Gramm-Leach-Bliley Act, or “GLBA”) also requires us to tell you how we collect, share, and protect your Personal Information. Once we deploy our App, you will be amend our Privacy Policy to provide a GLBA Appendix at the end of this Privacy Policy to learn more about how we treat your Personal Information under GLBA.6. UPDATE YOUR INFORMATIONPlease contact us if you need to change or correct your Personal Data. 7. CHILDRENOur App is not directed to children who are under the age of 18. Act2 does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to Act2 through the App please contact us and we will endeavor to delete that information from our databases.8. LINKS TO OTHER WEBSITESThe App may contain links to other websites not operated or controlled by Act2, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies. 9. SECURITYYou use our Website and the App at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. In addition, we will implement any security measures mandated by federal law. However, no Internet or e-mail transmission or data storage practice is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via Social Media, the App or e-mail. Please keep this in mind when disclosing any Personal Data to Act2 via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the App, or third party websites.10. INTERNATIONAL USERSBy using our App, you understand and acknowledge that your Personal Data will be transferred from your location to our facilities and servers in the United States.11. YOUR CHOICESIn certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our App, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data. You may also delete your account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.12. CHANGES TO THE PRIVACY POLICYThe App and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our App or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.13. Who We Are (Who is Providing this notice?)Act2 Financial LLC, a Virginia limited liability company.14. CONTACT USIf you have any questions about our Privacy Policy or information practices, please feel free to contact us through the 'Contact Us' button on our Website or by email -- privacy@act2financial.com