1. INFORMATION WE COLLECT
Information You Provide Directly. We collect information that you provide when you use the Services or otherwise communicate with us. For example, when you:
Information You Provide via Integration with Financial Data Sources. We collect information about you when you connect your registered account with us to financial institutions and other third-party data sources (“Financial Data Sources”) or you otherwise provide us with access to information from those Financial Data Sources. For example, you may choose to connect your bank or other financial accounts with your Copilot account. To sync information from these Financial Data Sources, we will collect your Financial Information including your account balance, transactions, and holdings. We may also collect certain credential information necessary to facilitate an integration with a Financial Data Source that you have chosen to make, including API keys required to connect your registered account with us to cryptocurrency exchanges or wallets. We may use third-party data sources to assist in collecting and syncing your information, including Financial Information, from Financial Data Sources, and by connecting your Copilot account to a Financial Data Source, you agree to all applicable third-party sources’ terms and conditions and privacy policies.
Information from Other Sources. We also obtain information from other sources, like other users of the Services, payment service providers who provide us with payment or balance information, analytics service providers, and security service providers, who provide us with information to secure our systems, prevent fraud and help us protect the security of the Services.
If you access the Services through a third-party connection or log-in (e.g., through Sign in with Apple), you may allow us to have access to and store certain information from such third-party services, depending on your settings on that service. If you do not wish to have this information shared, you may be able to adjust your account settings on those Services, or choose not to use these connections to access our Services. Please see the privacy policies and terms for these third parties for more information.
Automatically Collected Information. We may automatically receive and store certain information about the computer or device you use to access the Services. As discussed further below, we and our service providers may use a variety of technologies, including cookies, to assist in this information.
2. HOW WE USE YOUR INFORMATION
We use your information in a variety of ways to provide the Services and to operate our business. In particular, we may use your information to:
Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties in our discretion.
To collect the information in the “Automatically Collected Information” section above, we and our service providers may use web server logs, cookies, tags, SDKs, tracking pixels, and similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future.
As we adopt additional technologies, we may also gather information through other methods.
We may also collect, access, or store session cookies to facilitate integrations with Financial Data Sources.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
4. ONLINE ANALYTICS AND ADVERTISING
If you are interested in more information about interest-based advertising and how you can generally control cookies other tracking technologies from being put on your computer to deliver such advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link, or TrustArc’s Advertising Choices Page. To opt out of the display of interest-based advertising from Google, please visit the Google Ads Settings page. For more information and to exercise your choices regarding Facebook and/or Instagram ads, please visit the Facebook Ads Settings page and/or the Instagram Ads Settings page.
Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals. Learn more about Do Not Track.
We do not share Financial Information (whether provided by you manually or via a Financial Data Source integration) with (1) other companies for joint marketing purposes; or (2) any third parties so they can market to you. We may share, transfer, or disclose information collected from and about you in the following circumstances:
Service Providers. We may share information with select third parties who provide services to us, such as customer service, interfacing with Financial Data Sources, analytics, website management, information technology, and other similar services.
Financial Data Sources. We may share information with the Financial Data Sources to help establish or maintain an integration you have chosen to make.
Other Users of this Service or the Public. To the extent that you post content in publicly-accessible parts of the Services (e.g., Features Request forum), or choose to make certain content or account information viewable by other users or the public, such content and information can be read, collected, and used by others with permission to view it.
Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information as we believe to be necessary or appropriate to: comply with applicable law and legal processes; respond to requests from public and government authorities, including public and government authorities outside your country of residence; enforce our Terms of Service; protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and allow us to pursue available remedies or limit the damages that we may sustain.
Corporate Transactions. We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
6. HOW WE PROTECT YOUR INFORMATION
We implement a variety of security safeguards designed to protect your information. However, no method or transmission over the internet or electronic system is completely secure, so there is no guarantee that such data may not be accessed, disclosed, altered, or destroyed in connection with a breach of our physical, technical, organizational, or managerial safeguards.
When you create an account, you may be prompted to create a username and password. If you create an account with us, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. We urge you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure browser. If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Contact Information” section below.
For additional details about the steps we take to protect your information, please review our Security Policy.
7. RETENTION OF INFORMATION
We will retain your information for as long as your account is active or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect Copilot and our users, and enforce our agreements.
The Services may contain links, banners, or widgets to third-party sites, apps, services, and plug-ins, including Financial Data Sources. We may also incorporate third-party software (including open source software) in the Services.
9. CHILDREN’S PRIVACY
10. YOUR CHOICES
Marketing Communications. You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. You can opt-out of receiving further promotional emails from us by following the unsubscribe instructions provided in the promotional email you receive or by emailing us directly at firstname.lastname@example.org with “OPT-OUT”, “UNSUBSCRIBE”, “STOP”, or “REMOVE” in the subject line.
Account Information. To keep your information accurate, current, and complete or delete your information, please contact us through the app or at email@example.com.
11. NOTICE TO CALIFORNIA RESIDENTS
California’s “Shine the Light” law gives California residents the right under certain circumstances to request information from us regarding the manner in which we share certain categories of “personal information” (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your “personal information” with third parties for their own direct marketing purposes.
12. NOTICE TO NEVADA RESIDENTS
Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at firstname.lastname@example.org. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
14. CONTACT INFORMATION
Copilot Money, Inc.
45 Tudor City Place, Apt 1118
New York, NY 10017