Last updated: February 22, 2019
Information Collected or Received from You
When you use the Services, we may collect personal information and other information from you as further described below.
Albert Account Information
If you create an Albert Account, we’ll collect certain information that can be used to identify you, such as your name, email address, postal address and phone number, which is personally identifiable information or “PII”.
Bank Account Information
If you want to link a bank account that you hold with a U.S. financial institution (“Bank Account”) to your Albert Account, we will collect certain information from you about your Bank Account, such as your online login credentials, for the purposes of providing the Services to you. If you give us access to your Bank Account, you acknowledge and agree that we will have access to your transaction information, amount of funds, and other information about you and your Bank Account that may be available through the online settings for your Bank Account or otherwise through the relevant financial institution (“Financial Information”) that we require in order to provide the Services to you.
For compliance purposes and in order to provide the Services to you, we may obtain from you or from a third party documentation that helps us to verify your identity and Bank Account details. For example, we may ask you to provide a copy of your government-issued photo ID, a copy of a utility bill or bank statement, or such other documentation that contains PII. We may also obtain information about you from the financial institution providing your Bank Account.
Albert Investment Account Information
In order to determine your eligibility to create an Albert Investment Account and access the Investment Services, we’ll need to collect PII, Bank Account information, and other personal information required by Apex and/or United States Federal law, such as citizenship, employment and residence information (such information, together with PII and Financial Information, “User Information”).
Information Obtained from Third Parties
We may collect PII and/or Financial Information about you from third parties such as consumer credit reporting agencies like TransUnion, Experian or Equifax.
Information Collected Using Cookies and other Web Technologies
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Information Related to Use of the Services
Our servers automatically record certain information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used. We may use third party data collection tools such as Mixpanel to provide us with analytics data regarding Users’ interactions with our Services. You may opt-out of Mixpanel’s automatic retention of data collected while using the Services by visiting https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device.
Information Sent by Your Mobile Device
We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
How We Use Information
Our primary goals in collecting information are to provide you a secure, smooth, and customized experience, to administer your use of the Services (including your Albert Account and Albert Investment Account), and to enable you to enjoy and easily navigate our Services. For example, we may use your information to verify your identity, allow you to register with Albert, improve content in the App, provide notices, communicate with you via text message or email, monitor against fraud, or provide customer support at your request.
Information that We Share with Third Parties
We will never sell User Information to any third parties. We will not share any User Information that we have collected from or regarding you except as described below:
Information Shared with Apex
We’ll share your User Information with Apex during the Albert Investment Account creation process and in connection with your use (and our provision) of Investment Services.
Information Shared with Our Services Providers
We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to your PII and Financial Information only for the purpose of performing services on our behalf.
Information Shared with our Marketing Partners
We will never share your Financial Information with our marketing partners without your express consent, but we may use your Financial Information to generate offers for financial products and services from our marketing partners that may be of interest to you. It is always your choice whether or not to apply for an offered product or service and we will never submit an application for a financial product or service on your behalf without your express consent. If you choose to pursue any of the offers that the Services present to you, you will be asked if you would like the Services to pass on your PII and relevant Financial Information to the third party marketing partner as a convenience. For example, if the Services generate an offer from a third party loan provider for you, the Services will give you the option of moving forward with that offer within the App, and if you agree to do so, the Services will pass your PII and relevant Financial Information to that third party loan provider to speed up the process of your application.
Information Shared with Other Third Parties
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. For example, we may use aggregated and non-identifying information to derive statistics about the spending habits of our users, our users’ investment choices, and performance of Albert Investment Accounts, and to publish blog posts, articles, or other communications on our Site and social media channels.
Information Disclosed in Connection with Business Transactions
Information that we collect from our users, including PII, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, may be disclosed or transferred to a third party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
We offer you choices regarding the collection, use and sharing of your PII and we’ll respect the choices you make. Please note that if you decide not to provide us with the PII that we request, you may not be able to access all of the features of the Services.
Modifying Your Information
Responding to Do Not Track Signals
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
Links to Other Sites
Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.
Our Policy Toward Children
Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13 we will take steps to delete such information from our files as soon as possible.