Last updated: November 19, 2020
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.
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.
Albert currently utilizes Plaid, a third-party service provider, to retrieve information from your linked Bank Account. Plaid offers a secure method of transmitting your banking information, and Albert does not see or store your bank credentials. For more information on Plaid, please see our Financial Data notice.
For compliance purposes and in order to provide the Services to you, we may obtain information from you or a third party, including the financial institution providing your Bank Account, to help us to verify your identity or 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 Personal Information.
In order to determine your eligibility to access certain Services, we’ll need to collect Bank Account information and other Personal Information as required by United States Federal law such as citizenship, employment and residence information, and social security number.
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 in order to help improve our Services and provide you with a more convenient and customized experience.
“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 Personal Information
Our primary goal in collecting Personal Information is to provide you a secure, smooth, and customized experience, to administer your use of the Services, and to enable you to enjoy and easily navigate our Services. For example, we may use your Personal Information to verify your identity, allow you to register with Albert, determine your eligibility to use the Services, customize offers for you, facilitate a transaction in connection with your use of the Services, improve content in the App or Site, provide notices, communicate with you via text message or email, monitor against fraud, or provide customer support at your request. We may also use Personal Information to personalize, measure, and improve our marketing and advertising.
Information that We Share with Third Parties
We will never sell your Personal Information. We will not share any Personal Information that we have collected from or regarding you except as described below:
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 Personal Information and Financial Information only for the purpose of performing services on our behalf. For example, we share your Personal Information with Apex Clearing Corporation during the Albert Investment Account creation process and to execute trades on your 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 Personal Information and relevant Financial Information to the third-party marketing partner as a convenience. For example, upon your request, we will send your Personal Information to an insurance partner to process your request for a quote or continue with an insurance policy application.
Aggregated and Non-Identifying 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 Company Transactions
Information that we collect from our users, including Personal Information, 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 Personal Information, 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.
California Privacy Rights
Subject to certain limitations and exemptions, California residents may seek disclosures as to the categories or specific pieces of Personal Information Albert collects, processes, and stores about them, and may contact us regarding their rights to access and request deletion of their Personal Information. It’s important to note that the California Consumer Privacy Act (CCPA) does not apply to nonpublic personal information collected by financial institutions, including Albert, in connection with providing a financial product or service. Please refer to the CCPA Privacy Notice for further information.
We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
Communications and Opt-Out
Modifying Your Information
You can access and modify the Personal Information associated with your Albert Account, including your name, address and Bank Account details, through your Albert Account settings in the App.
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 Personal Information) 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 Personal Information may be transferred to and maintained on computers located outside of your state or the United States, where the privacy laws may not be as protective as those in your jurisdiction. Please note our Services are currently designed for individuals based in the United States. If you’re located outside the United States while accessing the Services and choose to provide your Personal Information to us, we may transfer your Personal Information 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 Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.