At BlueGrowth, we take privacy and security seriously.

This BlueGrowth Privacy Policy (the "Privacy Policy") outlines how BlueGrowth Financial LLC and its affiliates (collectively, “BlueGrowth,” “we,” “our,” or “us”) process the information we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels.

1. INFORMATION WE COLLECT AND HOW WE COLLECT IT.

Information You Provide

We collect information you provide when you use, or apply to use, our Services or otherwise engage or communicate with us as described below.

• Identity Data: such as your name, date of birth, marital status, social security number, photos of your face and government-issued identification documents, and other data on government-issued identification documents;
• Contact Data: such as your email address, mailing address, and telephone number;
• Financial Data: such as your bank account and payment card details, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores;
• Profile Data: such as your username and password, your knowledge assessment results, your interests, preferences, feedback, and survey responses;
• Stored Content: such as photos from your mobile phone gallery or contacts stored in your mobile device or email accounts. We only collect this information with your permission;
• Additional Data You Provide: such as via focus groups, survey responses, contests/sweepstakes, customer support, data you provide in memos when using our Pay & Request Service, or other means.

Information you provide us when using our Pay & Request Service: In order to conduct a money transfer using our Pay & Request Service, we collect information (including the name and an email address or phone number) from you about the intended recipient of the payment you request us to make.

Other Information You Provide: We collect additional personal information that you choose to provide to us. If you do choose to upload your photograph to our Service, please note that all images must adhere to our App Use Standards which you are required to comply with to use any of the BlueGrowth Services. You may also provide us with information about additional authorized users, including Identity Data, Contact Data, and Financial Data relating to them.

Information We Collect Automatically or Generate

As is true of many digital platforms, we also collect certain information about you automatically when you use our Services, as described below.

Usage Information: We collect information about your activity on our Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.

Transactional Information: When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.

Location Data: We may collect the GPS location of your mobile device in accordance with your device permissions. You can stop the collection of this precise location information at any time (see the Your Controls section below for details). Google uses technologies to approximate your location, including IP address (see Google’s Privacy Policy located at https://policies.google.com/privacy to learn more about how they process this information). We also approximate your location by your IP address. If you use our credit card, Transactional Information may include merchant location.

Credit Card Rewards Information: We process information relating to the credit card rewards you accumulate and redeem as a credit card customer, including the partners and/or merchants with whom you redeem the rewards.

Information Collected Through Tracking Technologies: We and our service providers also use technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information and other similar information. For information about how to disable cookies, please see the Your Controls section below.

Inferred Data: We may also infer information about you such as your gender, based on your first name.

Information We Collect from Other Sources

We also obtain information about you from other sources as described below.

Vendors and Business Partners: We collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.

Financial Account Linking: We may receive financial account information about you from third-parties, such as your financial institutions. For example, BlueGrowth offers account linking and aggregation services through Plaid, Inc. ("Plaid"). By utilizing these services, you acknowledge and agree that the terms of Plaid's Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy-policy) will govern Plaid's use of such information, and you consent to Plaid's Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide its services. To the extent you previously utilized account linking and aggregation services through BlueGrowth's previous service provider, Quovo, Inc., you expressly authorize Quovo, Inc. to transmit any information or data arising out of those services to Plaid so that Plaid can provide its services.

Connected Services: If you link, connect, or log in to your BlueGrowth Account with a third-party service (e.g., Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

Publicly Available Data: This may include contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.

Advertising Data: We collect information in connection with our ad campaigns that surface on other platforms, such as the ads you click on and other interactions with our ads.

Data from other users: If you are in another user’s contact list and they choose to disclose that list with us, then we will collect the contact information and your association with that user.

Credit Information: We may receive credit-related information about you from third parties, such as credit bureaus. For example, if you apply for a credit card with BlueGrowth, we may collect your credit history and credit scores from credit bureaus and other partners.

2. HOW WE USE YOUR INFORMATION.

We use the information we collect for purposes described below or as otherwise described to you at the point of collection:

• Maintain and provide the Services, including to process account applications, authenticate your identity, repair our Services, support, process and record transactional information, and handle billing and account management;
• Send you transactional or relationship information, including confirmations, invoices, technical notices, updates, security alerts, and administrative messages;
• Communicate with you to provide you with updates and other information relating to our services, including by sending you service-related notifications or communications;
• Prevent and address fraud, breach of policies or terms, and threats or harm;
• Protect our, your, or others’ rights, property, and safety;
• Develop, analyze, and improve our Services and to develop new products and services;
• Determine whether to send you marketing and promotional communications (such as by email, text, or push notification), and to send such communications in accordance with your communication preferences;
• Determine your eligibility and to offer you products or services, including financial products, provided by us or by other companies;
• Provide you with recommendations, advertisements, or other information that may be of interest to you; and
• Comply with legal and regulatory obligations, and to enforce our terms and conditions, and to conduct other legal functions.

3. SHARING OF INFORMATION

We share your information as described below and in this Privacy Policy, or with your consent.

Affiliates:

We share information with our current and future affiliates, including our parent company, in accordance with applicable law.

Service Providers:

We share information with service providers who perform services on our behalf, such as account verification and fraud prevention. These providers include credit bureaus, telecommunications providers, collection agencies, and others.

Business Partners:

We share information with business partners for purposes such as offering you co-branded products or services, or to enable their functionality on our Service.

Advertising Partners:

We share information with advertising partners to help us develop and provide our ads, or to provide analytics or data collection services.

Legal and Regulatory Disclosures:

We share information as necessary to comply with applicable law, regulation, legal process, or government request, such as to respond to a subpoena or similar request from law enforcement or other government authorities. We also share information when necessary to protect the rights, property, and safety of BlueGrowth, our customers, and others, and to enforce our policies or contracts, collect amounts owed to us, or assist with an investigation or prosecution of suspected or actual illegal activity.

Corporate Transactions:

We share information as part of a corporate business transaction, such as a merger, acquisition, joint venture, sale of company assets, financing, or other similar transaction, or in the event of insolvency, bankruptcy, or receivership.

4. YOUR CONTROLS

Account Information: You can update your account information at any time by logging into your account or contacting customer service.

Cookies and Tracking Technologies: You can disable cookies through your browser settings or device settings, but this may affect your ability to use certain features of our Services. For more information about cookies, see our Cookies Policy.

Marketing Communications: You can opt-out of receiving marketing communications from us by following the instructions in those communications or by contacting us directly. Please note that even if you opt-out of receiving marketing communications, we may still send you service-related notifications or other communications required by law.

Location Data: You can stop the collection of precise location information by adjusting your device settings or by following the standard uninstall process and removing the app from your device. Note that this may affect your ability to use certain features of our Services.

Do Not Track: Some web browsers may transmit “Do Not Track” signals. Because there is not yet an industry-standard way to handle these signals, we do not currently respond to these signals.

Request to Access, Delete or Modify your Information: Subject to applicable law, you may have the right to request access to, correction of, or deletion of your personal information. To make such a request, please contact us at support@bluegrowthcapital.org.