Urban FT Privacy Policy

Effective 2/22/2017

This document explains how Urban FT collects, uses, discloses and protects your information, including any nonpublic personal information. This policy applies to information collected when you use a website or mobile wallet application (collectively referred to as “services”) operated by Urban FT under the brand name of the firm that has a customer relationship with you. The firm with which you have a customer relationship has a separate privacy policy.

Urban FT may change this privacy policy from time to time and the date at the top of the policy will indicate the most recent revision. This privacy policy applies to services provided by Urban FT, Inc., which is also referenced in this document as “we” or “us”.

Information You Provide to Us

We collect nonpublic personal information that you provide to us when you create a mobile wallet account that is operated by us or when you communicate with us about your mobile wallet. The types of information we may collect include your name, address, phone number, email address, date of birth, bank account information, username, password and any other information you choose to provide.

Information About Your Transactions

As you use your mobile wallet to perform financial transactions, we collect nonpublic personal information in connection with each transaction, including transaction time, dollar amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions.

Information We Collect Automatically

When you access or use our services, we automatically collect:

• log information about your use of our services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our services;
• information about the computer or mobile device you use to access our services, including the hardware model, operating system and version, unique device identifiers and mobile network information;
• your location information from your mobile device, with your prior consent;
• information on our services and other websites; this may include sending cookies to your computer or mobile device.

We allow Do Not Track browser configurations, however, your Do Not Track status may alter the availability of services in certain browsers or when tracking functionalities are necessary to provide those services.

Use of Information

We may use your information, including nonpublic personal information to:

• provide, maintain and improve our services;
• provide and deliver the services you request;
• send you technical notices, updates and administrative messages;
• respond to your comments, questions and requests and provide customer service;
• communicate with you about services, offers, promotions, rewards and provide news and information we think will be of interest to you;
• monitor and analyze trends, usage and activities in connection with our services;
• personalize and improve our services and provide advertisements, content or features that match your profile or interests;
• link or combine with information we get from others to help us understand your needs and provide better service; and
• carry out any other purpose for which the information is collected.

Disclosure of Information

We may disclose any information we collect about current and former customers, including nonpublic personal information, to:

• financial service providers, including the financial institution (identified in the cardholder agreement) that provides a prepaid card in connection with your mobile wallet;
• another user, when you sign up for a mobile wallet via a referral link. The user that referred you may receive information indicating that you have established a mobile wallet;
• non-financial companies, such as email service providers that perform marketing services on our behalf;
• other nonaffiliated companies for our everyday business purposes.

We may also share aggregated information which cannot reasonably be used to identify you. For example, we may share transaction zip codes and merchant names with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.

Security

Urban FT takes reasonable measures to protect information about you from loss; theft; misuse and unauthorized access; disclosure; alteration; and destruction. Access to your nonpublic personal information is limited to employees that have a business reason to know such information.

If you have any questions about this policy, please contact us at:

Urban FT, Inc.
Attention: Chief Compliance Officer
75 Broad St, Suite 2410
New York, NY 10004

compliance@urbanft.com