Privacy Policy

This Privacy Policy (“Privacy Policy”) for ASA Financial (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about visitors of the Company’s website asa.financial (the “Website” and such individuals, a “Visitor”), individuals utilizing the ASA Vault mobile application (the “ASA Vault” and such individuals, a “Customer”). The Website, the ASA Vault, and any content, tools, features and functionality offered on or through our Website or ASA Vault are collectively referred to herein as the “Services.” For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. If you do not want information about you used as described in this Privacy Policy, please do not access or use the Services.

Updating this Privacy Policy

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. We will notify you and/or take other steps as required by applicable law. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. If you do not agree to any updates to this Privacy Policy, PLEASE DO not access or CONTINUE TO use the Services.

Company's Collection and Use of Information

In order to provide you with the Services, we may ask you to provide us with certain details or information about you. Information that you submit through the Services are:

• Contact information: Name, email address and Date of Birth. We collect basic contact details to communicate with you, provide you with the Services, respond to your queries, personalize the Services for you, improve and enhance our Services, market to you, and conduct research and analytics.
• Professional information: Company name, division, job title, and other professional information. We collect such information to explore business opportunities and provide the Services to you and prospective and/or participating financial institutions (such as banks and credit unions, “Bank Partners”) and/or financial applications providing financial technology companies (such as budgeting and investment management applications, “Fintech Partners”) (together, “Third Party Partners”).
• Account information: Account information related to your commercial account as a Visitor if you are associated with a Third Party Partners and/or as a Customer using the ASA Vault, including username, password, and security questions. We collect account information to maintain and secure your account with us, provide you with the Services (including providing assistance, consulting services, and support), enable you to request the Services according to your preferences, and administer your relationship with us.
• Demographic information: Country, city, and state/province. We collect demographic information to provide you with the Services, personalize the Services for you, and advertise to you.
• Financial-related information: Username, password, and transaction history associated with Third Party Partners, and apps provided by Fintech Partners that you downloaded. We collect this information to provide you with the Services, improve and enhance our Services, and conduct research and analytics. Bank usernames and passwords are used to authenticate your bank account and are not stored or saved by ASA.
• Information about your use of the Services: Interaction and feedback regarding the Services, including features, search queries within the Services, and certain interactions you make via the Services, such as information viewed and apps downloaded. We collect this interaction and feedback to provide you with the Services, improve and enhance our Services, conduct research and analytics, and for security purposes.
• Any other information you choose to provide: This includes product reviews, pictures, and any information you provide to us, for example, when communicating with us.

Our Services may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing the Services.

We may obtain information about you from the following third-party sources:

• Third Party Partners: Your username and password associated with the Third-Party Partners, which allow us to connect your accounts to the Services. Your transaction history and other information you choose to upload from your accounts provided by Third Party Partners.
• Service providers and other similar entities: They collect information, such as transactions posted to your accounts and possibly demographic information you authorize to share, for us our on our behalf to provide out Services.
• Your employer: Your contact information in order to provide you with access to the Services, market to you and your organization, and for security purposes.
• Social networking platforms: Your contact information and information you post on social networking platforms (e.g., LinkedIn) when you have a publicly-available profile containing information about yourself. We use this information to network with you, advertise to you, and seek business opportunities. In addition, if you interact with us on social media, we will collect information about those interactions.
• Other third parties: You may choose to elect that certain third parties share information with us, for example, when you choose to access the Services through another service, such as through Single Sign-on (e.g., Google) or link any social media platforms to your account.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 5 below for more information.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, and other tracking technologies (“Tracking Technologies”), including Google Analytics, to provide and enhance the performance of our Services, facilitate and enhance user experience, monitor and analyze trends, usage and activities in connection with the Services and conduct internal research and development. For further information about Google Analytics, please click here. We collect the following kinds of Usage Data:

• Unique device identifier;
• Device type, such as your phone, computer, or tablet;
• IP address;
• Browser type;
• Date and time stamps, such as the date and time you first accessed the Services;
• Operating system;
• Log data;
• Number of visits;
• Language of device;
• Geolocation; and
• Other information regarding your interaction with the Services, such as clickstream data.

We use the Usage Data we collect automatically to:

• Improve and provide the Services;
• Run analytics; and
• Better understand user interaction with the Services.

In addition to the foregoing, we may use all of the above information to:

• Create anonymized and aggregated data sets that we may use for a variety of functions, including research, internal analysis, analytics, and other functions;
• Comply with any applicable legal obligations;
• Detect, investigate, and prevent activities that may violate our policies or be illegal;
• Enforce any applicable terms of use; and
• Protect or defend the Services, our rights, the rights of our, Visitors, Customers or others.

How the Company Shares Information About You

In certain circumstances, we may share information about you with third parties. Such circumstances may include:

• With vendors or other service providers, such as:
• Data analytics vendors;
• Data storage providers;
• Email vendors; and
• Security vendors
• With our Third-Party Partners to enable them to transfer relevant information from your associated accounts to the Services, in order for us to provide the Services to you.
• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
• With our affiliates or otherwise within our corporate group.
• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In connection with an asset sale, merger, bankruptcy, or other business transaction
• To enforce any applicable terms of service.
• To ensure the safety and security of the Company and/or its users.
• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
• With professional advisors, such as auditors, law firms, or accounting firms.

You acknowledge that such sharing of information may occur in all of the aforementioned circumstances and is permitted by and subject to this Privacy Policy and applicable law.

Cookies and Other Tracking Technologies

Do Not Track Signals

We use cookies and other Tracking Technologies to collect information about your browsing activities over time and across different websites following your use of our Website and Services. Cookies allow us to recognize and count the number of users and to see how our Services are used. This helps us to improve our Services and the way it works. You can find more information about cookies and how to manage them through your browser settings.

Cookies and Other Tracking Technologies

We use cookies and other Tracking Technologies to collect information about your browsing activities over time and across different websites following your use of our Website and Services. Cookies allow us to recognize and count the number of users and to see how our Services are used. This helps us to improve our Services and the way it works. You can find more information about cookies and how to manage them through your browser settings.

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including general functionality, to work incorrectly. Most browsers accept cookies automatically.

Third Party Websites and Links

Our Services may contain links to other websites and/or online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed in the Services. We expressly disclaim any and all liability for the actions of third parties, including but not limited to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

Data Security

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

How to Contact Us

If you would like to reach out to ask questions regarding information about you that we collect or other questions about this Privacy Policy or your rights, you can email us at support@asa.financial.