Privacy Policy

Mobile App and Website Privacy Policy

Last modified: August 25th, 2022

Introduction

Gravystack, Inc. (“Company” or “We“) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes our practices for collecting, using, maintaining, protecting, and disclosing your personal information as well as the types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the Gravystack mobile application (the “App“) or the Gravystack website (the “Website“). The App and the Website offer financial services such as a prepaid debit card. The prepaid debit card is offered by Synapse Financial Technologies, Inc., and is offered through the App and Website. All of the services, content, offers, features, and products offered through the App and Website are referred to herein as the “Gravystack Services.” By using the Gravystack Services, you are accepting the terms of this Privacy Policy and are agreeing to the collection and use of your personal information pursuant to this Privacy Policy.

This policy applies only to information we collect in the App or on the Website, and in any e-mail, text, and other electronic communications sent through or in connection with the App or Website.

This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through this App or Website.
  • You provide to or is collected by any third party (see Third-Party Information Collection).

These websites and apps have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App and Website. By downloading, registering with, or using the App or Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the App or Website after we revise this policy means you accept those changes, so please check the policy periodically for updates.

This Privacy Policy should be read in conjunction with our Terms of Service, which contain more details about the Gravystack Services. Any terms not defined herein shall have the meanings given to them in the Terms of Service.

Children Under the Age of 13

Please see the section below entitled “Children’s Privacy Policy” to review our privacy practices with regard to children under the age of 13. Any user accounts for children under the age of 18 must be established by a parent or legal guardian.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see [Your California Privacy Rights] for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App and Website:

  • Directly from you when you provide it to us.
  • Automatically when you use the App or Website.

Information You Provide to Us

When you download, register with, or use the App or Website, we may ask you provide information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, social security number, date of birth, or any other identifier by which you may be contacted online or offline (“personal information“). We may also ask for photos of your government-issued identification, such as a driver’s license.
  • That is about you but individually does not identify you, such as the dates of birth, names and phone numbers of your family members.

This information includes:

  • Information that you provide by filling in forms. This includes information provided at the time of registering to use the App or Website, purchasing our Services, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App or Website.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Your responses to surveys that we might ask you to complete for research.
  • Feedback given for marketing purposes, whether in a Beta version or otherwise, including but not limited to feedback in pop-ups, posts on your wall, or testimonials.
  • Details of transactions you carry out through the App or Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App or Website.
  • Your search queries on the App or Website.

You may also provide information for publication or display (“Posted“) on public areas of the App or Website (collectively, “User Contributions“). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection

When you download, access, and use the App or Website, it may use technology to automatically collect:

  • Usage Details. When you access and use the App or Website, we may automatically collect certain details of your access to and use of the App or Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App or Website.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
  • Stored Information and Files. The App or Website also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
  • Location Information. This App and Website collect real-time information about the location of your device.

If you do not want us to collect this information do not download the App, delete it from your device and do not use the Website.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on or through the App or Website and how we respond to browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or computer. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or browser. However, if you select this setting you may be unable to access certain parts of our App or Website.
  • Web Beacons. Pages of the App, our emails and the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or Website or their content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies.
  • Your mobile device manufacturer.
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the App or Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the App and Website and their contents, and any other information, products or services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Give you notices about your account, including expiration and renewal notices.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when App or Website updates are available, and of changes to any products or services we offer or provide though it.
  • Facilitate any and all functionality of the app and ecosystem

The usage information we collect helps us to improve our App and Website and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our App and Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the App or Website.

We use location information we collect to facilitate certain functionality of the app and ecosystem.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

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

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gravystack, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gravystack, Inc. about our App and Website users is among the assets transferred.
  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the App EULA, terms of sale, Terms of Use, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Gravystack, Inc., our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • We will use your feedback in pop-ups, posts on your wall, or testimonials for our marketing purposes. When posting feedback, posts or testimonials we will only disclose your first name, if provided.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures over your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the App or Website to collect information through other tracking technologies via email. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App or Website may then be inaccessible or not function properly.
  • Location Information. You can choose whether or not to allow the App or Website to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App or Website may become inaccessible or not function properly.
  • Promotion by the Company. If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt-out via email. You can also always opt-out by logging into the App or Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email or text message stating your request to [email protected]
  • Promotion by Feedback, Wall Posts or Testimonials. When we are promoting our services by using your feedback in pop-ups, posts on your wall, or testimonials, you will not be able to opt-out. However, if opting-out is not available we will not disclose your contact information in such posts, only your first name, if provided.
  • Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out via email. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected]
  • Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out via email. You can also always opt-out by logging into the App or Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [email protected]

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see [Your California Privacy Rights] for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App or Website and visiting your account profile page.

You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the App or Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App or Website users. Proper access and use of information provided on the App or Website, including User Contributions, is governed by our terms of use.

California residents may have additional personal information rights and choices. Please see [Your California Privacy Rights] for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccp....

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App or Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected][ or write to us at: 1 North 1st Street, Suite 790, Phoenix, Arizona 85004.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App and Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App and Website like message boards. The information you share in public areas may be viewed by any user of the App and Website.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App and Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Children’s Privacy Policy

Gravystack, Inc.’s commitment to raising financially-educated children runs deep. As a part of educating them about money, it is part of our mission to educate them about online privacy. This Children’s Privacy Policy demonstrates our unwavering commitment to make sure that your child’s privacy is protected and that our privacy practices comply with the Children’s Online Privacy Protection Act.

For any child under the age of 18, their parent or guardian must register the child with us. We verify the status of the parent using photo identification, a social security number, and/or other verification methods designed to prevent anyone under the age of 18 from setting up an account on their own. All consent to the collection or use of a child’s personal information must come from the parent.

All child accounts must be established as a sub-account of the parent or guardian’s account. Once the parent has set up the account and established information use and collection parameters, the child may begin using the App or Website.

Parents and guardians can access the personal information of their child under 18 at any time through either the App or the Website. Parents and guardians, as primary account holders, have access to all transaction details in any of their sub-accounts. Sub-account holders cannot see the personal information or transaction details of another sub-account without being specifically authorized by the sub-account holder or the primary account holder.

The primary account holder may provide access to their child’s personal information to third parties in order to use our services for which we use partners, such as banking and debit card services, fulfillment providers; insurance providers, cloud hosting providers, and other service providers.

You should also be aware that your mobile carrier and/or internet service provider may have access to any information transmitted through the App or Website.

Parents and guardians may change, update or delete their child’s personal information at any time. You may call 1 (213) 406-7621 or you may visit the account settings page to change the privacy options. If you ask us to delete any personal information we will delete as much as we are allowed to by law. We will only retain any personal information as is necessary to close the account, remove the personal information from the databases of our service providers, resolve payment or other issues with the account, conduct a fraud investigation, enforce our rights under any agreement such as the Terms of Use of the App or Website, or take other actions permitted by law. There may be regulatory recordkeeping obligations that keep us from deleting all information related to a sub-account or primary account.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by a notice on the Website and an in-App alert the first time you use the App after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

1 North 1st Street, Suite 790

Phoenix, Arizona 85004

or via phone:

1 (213) 406-7621

To register a complaint or concern, please contact us at [email protected]




Privacy Policy for California Residents

This Privacy Policy for California Residents supplements the information contained in Gravystack, Inc.’s Mobile App and Website Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

CategoriesExamplesCollected

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.
Yes
C. Protected classification characteristics under California or federal lawAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Yes
D. Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Yes
E. Biometric informationGenetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.No
F. Internet or other similar network activityBrowsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.Yes
G. Geolocation dataPhysical location or movements.Yes
H. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.No
I. Professional or employment-related informationCurrent or past job history or performance evaluations.No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.No
K. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.No

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our App or Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our App or Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your App or Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our App or Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our App or Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information in exchange for money, but we may share your personal information with third parties for marketing purposes, and such sharing may be considered a “sale” under California law. The following information may be shared with third parties for marketing purposes: your name, a unique username you would like to go by, a phone number and/or your email address. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Company has sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information CategoryCategory of Third-Party Recipients
Business Purpose DisclosuresSales
A. IdentifiersMarketing partners and banking partnersMarketing partners
B. California Customer Records personal information categoriesMarketing partners and banking partnersMarketing partners
C. Protected classification characteristics under California or federal lawMarketing partners and banking partnersMarketing partners
D. Commercial informationNoneNone
E. Biometric informationNoneNone
F. Internet or other similar network activityNoneNone
G. Geolocation dataNoneNone
H. Sensory dataNoneNone
I. Professional or employment-related informationNoneNone
J. Non-public education informationNoneNone
K. Inferences drawn from other personal informationNoneNone

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

  • Calling us at: (213) 406-7621
  • Emailing us at [email protected]
  • Visiting www.gravystack.com
  • Changing your account settings on the App.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by any of the above methods.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include providing photo ID or a social security number.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [CONTACT].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically [EXPECTED FORMAT DESCRIPTION].

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us via email at [email protected]

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at [email protected]

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and App and update the notice’s effective date. Your continued use of our Website or App following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Gravystack, Inc. collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: tel:+1(213) 406-7621

Website: www.gravystack.com

Email: [email protected]

Postal Address:

GravyStack, Inc.

Attn: Customer Success

1 North 1st Street, Suite 790, Phoenix, Arizona 85004



If you need to access this Policy in an alternative format due to having a disability, please contact [email protected] or 1 (213) 406-7621.

Synapse Privacy Policy

Last Revised: March 2020

Our mission is to enable companies to build and launch best-in-class financial services. In order to do so, we provide the technology link between our partner bank(s) and our partners (Platforms), enabling our Platforms to enable users like you to have access to certain banking services.

This Privacy Policy applies to you if you are (i) using a website or phone application that uses Synapse to provide to end-users like you such certain banking services or (ii) using our website synapsefi.com (“Website”).

By using our services, you agree to Synapse’s Privacy Policy. We may update this PrivacyPolicy from time to time and the continued use of our services means acceptance of this Privacy Policy. If you do not agree to the Policy as last revised, do not use (or continue to use) the Services (as defined below).

As a technology company nestled in the financial services industry, we take privacy and security very seriously as provided herein. To demonstrate our commitment to privacy and security, we have developed this Privacy Policy to explain how we may collect, retain, process, share, and transfer your information

  • Policy Overview

1.1. In this Policy, “Services”refers to any products, services, content, features, technologies, or functions made available to you by Synapse as a technology service provider of our partner bank(s) via the website and/or phone application of the Platform. The terms “Synapse,” we”, “us” or“our” shall refer to Synapse Financial Technologies, Inc. The terms “you” or“your” shall refer to any individual or entity who accepts this Policy.

1.2. We may, in our sole and absolute discretion, change or modify this Policy, and any policies or agreements which are incorporated herein, at any time, and such changes or modifications shall be effective immediately upon posting to the Website. No revision or update will apply to a dispute which we had actual notice of prior to the date we posted the changes or modifications. We will notify you of such changes or modifications by posting them to the Website, and your use of theServices after such changes or modifications have been posted (as indicated by a “Last Revised” date) shall constitute your acceptance of the Policy as last revised. If you do not agree to the Policy as last revised, do not use (or continue to use) the Services.

  • Applicability and Scope

2.1. This Privacy Policy applies to your information when you visit the Website or use the Services via a Platform and does not apply to online websites or services that we do not own or control, including websites, mobile applications or services of our Platforms. This means that this Policy does not explain what our Platforms do with any of your information that we provide to them (or any other information they collect directly from you, their end user).

2.2. Information provided to third parties, such as our Platforms, shall be controlled by their respective privacy policies. We encourage you to review the privacy policies or notices of the Platform or other third parties for information about their practices.

  • Collection of Information.

3.1. We collect public and non-public information (i) when you visit our Website; (ii) when you communicate with us via our customer support channels; (iii) when you apply or sign up to use any of our Services via a Platform; (iv) when you communicate with our partner bank(s) or Platform; (v) we collect through third-party service providers and other sources; (vi) through online research on social media and websites, which may not be publicly available; and (vii) when you use any of our Services directly or via a Platform.

3.2. As a third-party service provider and agent of the bank partner(s) we collect data on behalf of the partner bank(s) to comply with applicable law and financial services regulation.

3.3. We also collect information in order to verify your identity when you apply or sign up to receive a service from us or our partner bank(s).

  • Types of Personal Data Collected

4.1. The information we collect may vary according to the Service we will be providing to you and your use of the Services.

4.2. We may collect the following information about individuals or businesses (“Data”):

4.2.1. Individuals’ Information: name or aliases, physical address, work address, phone number, email address, IP address, date of birth, gender, social security number or other tax identification number, result of sanctions screenings, government ID, photo identification, selfie, or video authorization, images of your face on your identification document (e.g., government-issued identification card) and/or video, your biometric facial identifiers, and other additional information you may provide, or additional information we may additionally request you to provide;

4.2.2. Business’ Information: entity legal name or aliases, including “doing business as” names, physical address, phone number, legal entity type, industry, organizational documents (e.g. articles of incorporation and bylaws), employer identification number, or other information relating to your authorized signors or beneficial owners, which may include the Individuals’ Information as provided above, or additional information we may additionally request you to provide;

4.2.3. External Bank Account Information: external financial institution name, account name, account type, branch number, account number, routing number, international bank account number (“IBAN”), information, data, passwords, authentication questions, materials or other content, transaction and available balance information;

4.2.4. Financial Data of Your Account With Us and Our Partner Bank: transactions and transaction history, including but not limited to ACH, Wire and card transactions, available account balance, card data, loan and debit amounts, loan types, payment plan, loan balance, linked bank accounts, salary and other income, sources of wealth, and other assets;

4.2.5. Background Check Data: background check information including credit and criminal checks, supporting research, and screenings, to the extent required or permitted by local law;

4.2.6. Recipients’ or Senders’ Data: when you send or request money through the Services, we may collect data such as name, postal address, telephone number, IP address, date of birth, and financial account information about the recipient or sender of the funds. The extent of data required about a recipient or sender may vary depending on the Services you are using to send or request money;

4.2.7. Third-Party Sources: we may obtain information from third-party sources such as Platform, merchants, recipients and senders of funds, data providers, identity verification providers, and credit bureaus, where permitted by law.

4.2.8. Digital Identity Information:

4.2.8.1. Services Metadata: when you interact with the Services, metadata is generated that provides additional context about the way you interact with the Services.

4.2.8.2. Log Data: our servers may automatically collect information about your visit to the Website and to Platform’s websites or mobile applications, including IP addresses and associated information, the address of the website visited before using the Website, browser type and settings, the date and time the Services were accessed and used, information about browser configuration and plugins, language preferences.

4.2.8.3. Device Information: your device “fingerprint” (e.g. hardware model, operating system and version, unique device identifiers and mobile network information) when you access our Website or use a Service via a Platform.

4.2.8.4. Location Information: we may receive information from you that helps approximate your location, such as using an IP address received from your browser to determine an approximate location. Further, we may also collect location information from devices in accordance with the consent process provided by your device.

  • Retention of Information

5.1. We retain your information to fulfill our legal or regulatory obligations and for our business purposes. We may retain your Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.

5.2. If you stop using the Services and close an account with a Platform, we reserve our ability to retain and access the Data as provided in this Policy. We will continue to use and disclose such Data in accordance with this Privacy Policy.

5.3. All Data are stored in encrypted format in Synapse’s database.

  • Purposes of Collection and Use of Information

6.1. We use the information we collect or receive to operate, improve, and protect the Services we provide and to develop new Services.

6.2. More specifically, we collect and use your information:

6.2.1. To provide the Services, perform obligations under our agreements, and carry out related business functions, including performing data and transaction processing, conducting credit checks, handling user inquiries, and managing relationship;

6.2.2. To develop, improve, enhance, modify, add to, and further develop our Services;

6.2.3. To comply with legal obligations and regulations applicable to the Services and to our partner bank(s), including but not limited to “know your customer” obligations based on applicable anti-money laundering and anti-terrorism requirements, economic and trade sanctions, customer due diligence, suspicious activity reporting, foreign exchange and international trade, tax reporting and other applicable laws, regulations, ordinances, and obligations or requirements;

6.2.4. To confirm a person’s authority as a representative or agent of a user;

6.2.5. To conduct record keeping and otherwise manage the business;

6.2.6. To verify you, your identity, that the data provided is credible, and prevent fraud;

6.2.7. To protect you, our Platforms, or Synapse from fraud, malicious activity, and other privacy and security-related concerns;

6.2.8. To provide customer support to you or to our Platforms including to help respond to your inquiries related to our Services or our Platforms’ applications or website;

6.2.9. To send you technical notices, updates, security alerts and support and administrative messages;

6.2.10. To investigate any misuse of our Services or our Platforms’ applications or websites, including criminal activity or other unauthorized access to our Services;

6.2.11. For any other purpose with your consent.

6.3. We may use raw data or aggregated and anonymized data for the purposes provided in this Policy.

6.4. We use machine learning and facial recognition to verify the legitimacy of your identification documents, verify the factualness and credibility of the information you provide to us, and avoid fraud, by, among other actions, comparing biometric data with data previously or separately obtained. Based on the submitted identification document, Synapse programmatically creates a feature vector of the face displayed in such document and stores it in encrypted format in Synapse’s database. The vector cannot be used to reconstruct the original image. When a new user creates an account, Synapse programmatically compares that user’s vector against others in its database to help detect potential cases of identity theft. As with all Data, Synapse does not sell or rent the image, likeness, or vector to anyone, including marketers or other third parties, and does not use your Data for commercial purposes other than identity verification, financial loss mitigation, and regulatory compliance.

  • Sharing Information

7.1. Synapse takes your privacy seriously. We do not sell or rent your information to marketers or other third parties.

7.2. We do share your information with third parties as described in this Policy. We may share some of your information:

7.2.1. With the Platform you are using to have access to our Services for the purposes of offering services to you and providing customer service to you. You understand that Platform may have access to all Data;

7.2.2. With our partner bank(s) in order to comply with regulation, and bank’s regulatory obligations and know your client requirements. You understand that partner bank may have access to all Data and that the partner bank(s) applicable data privacy policy or notice shall apply;

7.2.3. For our everyday business purposes, such as processing your transactions, maintaining your account(s), or reporting to credit bureaus;

7.2.4. With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, credit bureaus, or collection agencies;

7.2.5. With other parties to transactions when you use the Services, such as other users, merchants, and their service providers. We may share your information with other parties involved in processing your transactions. This includes other users that you are sending or receiving funds from, and merchants and their service providers. This information might include: (i) information necessary to facilitate the transaction and (ii) information to help other participant(s) resolve disputes and (iii) detect and prevent fraud;

7.2.6. To information technology providers or other service providers around the world that act under our instructions regarding the processing of certain data (“Vendors”). Vendors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the information, and to process information only as instructed;

7.2.7. 1To card networks in case you are issued a card by our partner bank(s). You understand that the card network may have access to all Data and that the card network applicable data privacy policy or notice shall apply;

7.2.8. To independent external auditors or other service providers around the world. Such service providers will be subject to any necessary contractual obligations regarding the protection and processing of such Data;

7.2.9. In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);

7.2.10. To support our audit, compliance, and corporate governance functions; and

7.2.11. With your consent or direction.

7.3. Subject to applicable law, we may disclose Data if required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Synapse may do business; (b) protect and defend the rights or property of Synapse; (c) act in urgent circumstances to protect the personal safety of users, Platforms, and contractors/employees of Synapse or others; or (d) protect against any legal liability. In addition, Synapse may share your Data with U.S. regulators and with other self-regulatory bodies to which we are subject, wherever Synapse may do business.

  • Protection of your Information

8.1. Synapse takes commercially reasonable measures to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we implement policies designed to protect the confidentiality and security of your nonpublic personal information.

8.2. Unless otherwise specified in this Policy, Synapse limits access to your information to employees that have a business reason to know such information, and further implements security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.

  • California Consumer Privacy Act (CCPA) Information

9.1. The CCPA requires companies, such as Synapse, to make certain additional disclosures and provides California residents with the ability to request certain additional information about their personal information and Data collected.

9.2. CCPA does not apply to personal information and Data that is collected, processed, sold or disclosed pursuant to:

9.2.1. Gramm-Leach-Bliley Act (Public Law 106-102), the federal privacy regulation. Generally, this will apply to any personal information obtained in connection with Synapse enabling you access to the financial products or services or Synapse’s partner banks; or

9.2.2. Fair Credit Reporting Act (12 CFR 1022). Generally, this will apply to personal information and Data related to credit history or credit worthiness.

9.3. The CCPA grants California residents certain rights around the personal information and Data that is collected about them, as below:

9.3.1. Right to Know About Personal Information Collected and/or Disclosed:

9.3.1.1. California residents have the right to request information about their personal information that Synapse has collected in the preceding 12 months. Upon our receipt of a verifiable request from you, we will disclose the following information:

9.3.1.1.1. The categories of personal information we have collected about you.

9.3.1.1.2. The categories of sources from which the personal information was collected.

9.3.1.1.3. The business or commercial purpose for collecting your personal information.

9.3.1.1.4. The categories of third parties with whom we share your personal information.

9.3.1.1.5. The specific pieces of personal information we have collected about you.

9.3.1.1.6. The CCPA allows California residents to submit a maximum of two (2) requests in any 12-month period.

9.3.2. Right to Request Deletion of Personal Information:

9.3.2.1. California residents have the right to request that Synapse delete any personal information about you which we have collected from you.

9.3.2.2. This right to request deletion does not apply to any of your personal information that is subject to an exception in the CCPA, for example, where we need to retain the personal information to complete a transaction for which the personal information was collected, to prevent fraud or to comply with a legal obligation.

9.3.3. Right to Opt-Out of the Sale of Personal Information:

9.3.3.1. Synapse does not sell any Data and will not sell any Data without providing you with prior notice and an opportunity to opt-out, as required by law.

9.3.4. Right to Non-Discrimination:

9.3.4.1. Synapse does not discriminate against any California resident who exercises any of the rights described above. This includes denying goods or services; charging different prices or rates; or providing a different level of service or quality of goods or services.

  • CCPA Information Requests

10.1. California residents can submit a request, by either by sending an email to [email protected] or by calling us at +1 (833) 953-1299, Monday through Friday from 10:00 a.m. to 5:00 p.m. PST.

10.2. Synapse is required to verify the identity of the requester before answering to any request for information or deletion of Data.

10.3. California residents have the option to designate an authorized agent to submit a request on their behalf. To do this, the authorized agent must inform that an “authorized agent” is submitting the request on a consumer’s behalf and provide all of the required information for identity verification, along with proof of authorization in the form of a notarized authorization form, signed by the California resident who is the subject of the request. We will also contact the California resident directly to verify the request.

10.4. We will respond to requests within 45 days and will notify the requester if we need additional time.

  • Access of Services and Website by Children

11.1. This Website and the Services are not directed at children under 13. We do not knowingly collect Data from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Data without the parent or guardian’s consent, he or she should contact us using the information below (“Contact”).

  • Contact

12.1. If you have any questions about this Policy, please contact us by email, telephone, or postal mail.

12.1.1. Email: [email protected]

12.1.2. Telephone: +1 (415) 688-2943

12.1.2.1. Hours. Customer Service agents are available to answer your calls:

12.1.2.2. Eastern Time (USA): Monday through Friday: 10:00 AM – 5:00 PM.

12.1.2.3. Central Time (USA): Monday through Friday: 10:00 AM – 5:00 PM.

12.1.2.4. Pacific Time (USA): Monday through Friday: 10:00 AM – 5:00 PM.

12.1.3. Postal mail: Synapse Financial Technologies, Inc., P.O. Box 636, 150 Sutter Street, San Francisco, CA 94104-9991

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