Last updated: July 21, 2022
Custodia Bank, Inc. (“Custodia” or “we”, “us” or “our”) respects your privacy. We will only use your Personal Data in accordance with the terms of this Privacy Notice (“Notice”). This Notice describes how we collect, use, protect and disclose Personal Data received from your use of our website, www.custodiabank.com, along with the features, functionalities, applications, browser extensions and other services available through our website (collectively, our “Website”) and our products and services (our “Services”). We refer to our Website and Services collectively as our “Platform.”
You can access and interact with our Platform in many ways, including from a computer or mobile device. This Notice applies regardless of how you access or interact with our Platform. Depending on how you interact with our Platform, there may be some cases where we need to provide you with additional information about how we use your Personal Data and/or what options you have regarding our use of your Personal Data. We may provide this additional information via notices on the Platform or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Notice.
Please read this Notice carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Notice, please do not use our Platform, provide us with your Personal Data or authorize a third party to make your Personal Data available to us. By using the Platform, providing us with your Personal Data or otherwise making your Personal Data available to us, you acknowledge that you understand that we may use your Personal Data as described in this Notice. If you have any questions about how we collect, use, protect, disclose or otherwise process Personal Data, including whether we have received your Personal Data from a third party, please contact us by email at [email protected].
WE COLLECT PERSONAL DATA AND USAGE INFORMATION
Our primary goals in collecting Personal Data are to verify the identity of individuals who are principal owners of entities that apply for and maintain a financial account with us, provide and improve our Platform, conduct our operations, communicate with you and enable visitors to our Platform to enjoy and easily navigate it. This section describes what Personal Data we collect.
When we refer to “Personal Data” in this Notice, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
Categories of Personal Data We Collect. Depending on the type of activity you are performing on the Platform or how you use or interact with our Platform, we may collect and disclose the following Personal Data:
Usage Information. Depending on how you access, interact with, or use our Platform, the Usage Information that we, or third parties acting on our behalf, collect may include:
For more information about how we collect Usage Information, please see the “How We Collect Usage Information” section below.
HOW WE COLLECT YOUR PERSONAL DATA
Directly From You. When you engage with us in connection with our Platform, such as requesting information, creating an account, communicating with us or otherwise interacting with us, we may ask you to provide certain Personal Data. Some of the Personal Data we request may not be required, however, we will specifically indicate what Personal Data is required to engage in such activity.
From Third Parties. We, or third parties acting on our behalf, may collect Personal Data about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Data from these Third Party Sources can occur in a variety of ways, including, without limitation:
Our collection, use, disclosure, and storage of the Personal Data we receive from Third Party Sources will be as described in this Privacy Notice.
Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more Third Party Sources.
HOW WE COLLECT USAGE INFORMATION
We, and third parties acting on our behalf, collect Usage Information in a variety of ways. Some Usage Information, such as the IP address of a device attempting to access, use or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Information, such as information about which features of our Platform are popular, helps us improve and advertise our Platform. The primary systems and technologies used to collect Usage Information in connection with our Platform are:
the systems we use to make our Platform available to you, including the systems we use to help us identify and address technical issues and errors. When you access, use, or interact with our Platform, these systems automatically record certain information that your browser or device sends whenever you visit a website or utilize an online application as well as information about how long your device is connected to our Platform and the activities that device engages in while connected. These systems also automatically collect information about your actions and activities on our Platform.
other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Platform, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
HOW WE USE YOUR PERSONAL DATA AND USAGE INFORMATION
This section describes the primary purposes for which we use the Personal Data we, or third parties acting on our behalf, collect.
Operational Uses and Disclosures. We may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including:
Marketing Purposes. We may use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers and events e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Notice) and use such linked information for Marketing Purposes.
Anonymized Data. Please note, we may use and disclose aggregated, anonymized or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Notice. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Notice.
HOW – AND WHY – WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES
We will not, without your permission, sell, publish or share information you entrust to us that identifies you or any person, except as described below.
We may share your Personal Data with certain third parties under the following circumstances:
MANAGING YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data. This section describes the mechanisms available to you to control the Personal Data we use about you in connection with our Platform.
PROTECTING YOUR PERSONAL DATA
We are committed to protecting the security of your Personal Data. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the transmission of information via the internet and mobile platforms. Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose online, and you do so at your own risk.
We do not direct or target any piece of our Platform to children under the age of 18. If we learn that we have collected the Personal Data of anyone under the age of 18, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 18 and discover that your child has submitted Personal Data to us, please contact us at [email protected]. We will make reasonable efforts to remove such information from our databases.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Data third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Custodia Bank, Inc. Attn: CA Privacy Rights Request 2120 Carey Ave. Cheyenne, WY 82001
Personal Data collected in connection with the use and operation of our Platform is initially collected in the United States and may be stored or processed in any jurisdiction where our service providers are located. This means that your Personal Data may be collected, stored, or otherwise processed in a jurisdiction outside of where you reside, including, without limitation, in the United States. Please note, the United States has not been assessed as having adequate privacy laws by some countries and economic regions.
Because the methods used to protect your Personal Data and the Services we provide are continually evolving, this Notice may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Notice, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Notice has been updated.
Your continued use of our Platform after any changes to this Notice become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Notice.
We welcome your questions, comments and concerns about privacy. Please email us at [email protected] with any questions or feedback you have pertaining to our privacy practices.