Privacy policy

This Privacy Policy describes how Copilot Money, Inc. (“Copilot”, “we”, “our”, or “us”) collects, uses, and discloses information collected through websites and mobile applications owned and operated by us that link to this Privacy Policy, such as the Copilot mobile app and www.copilot.money, and any other interactions (e.g., customer service and other communications) that you may have with Copilot (collectively, the “Services”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy includes the following sections:

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:

• Create an account to use the Services, we may collect contact and registration information, such as your name and email address. We may also collect payment information, including your payment card number and associated billing information, and other profile information you upload to your account.
• Interact with Services, we may collect the information that you upload or provide, including financial information such as your account balance, descriptions of financial transactions, investment interests, budget names and amounts (“Financial Information”), information about other users, credentials to facilitate integrations with Financial Data Sources, and descriptions regarding the foregoing.
• Contact us with questions, comments, or for customer service, we may collect contact information, such as your name and email address, as well as any information you provide in connection with your outreach. We will also collect any information you provide to publicly-accessible parts of the Services, such as in posts and comments to our Feature Requests forum. Participate in promotions, events, surveys, and sweepstakes, we may collect basic contact information and any other information you provide in connection with these activities.
• Choose to integrate the Services with other apps/functionalities on your mobile device (e.g., your photos or contacts), we will collect information contained in these other apps/functionalities in accordance with your app and device settings.

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.

• Device Information. We collect technical information associated with the device(s) you use to access our Services, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.
• Usage Information. We also collect a variety of information to better understand your use of our Services. This may include the webpages, screens, or features of our Services you use, how much time you spend there, date, time and use, how you engage with the Services, information about your usage preferences, whether you open an email and your interaction with email content, access times, error logs, and other similar information. If you access our Services via a link on a third-party website, we may also receive certain click-through data such as the webpage that you were visiting before accessing our Services.
• Location Information. We also may collect your device’s IP address or your mobile device’s GPS signal (with your permission in accordance with your device settings) when you use certain Services as well as the city, state, county, and ZIP code associated with that 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:

• provide the information and Services you request;
• provide you with effective customer service;
• personalize your experience and our communications with you;
• engage in transactions with you, including contacting you about your account, billing you for the Services, and processing payments;
• contact you with operational information and notices related to your use of the Services;
• contact you with special offers and other promotional content related to our Services that we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• invite you to participate in promotions, sweepstakes, surveys and provide feedback to us;
• analyze use of the Services and improve the content, functionality and usability of the Services;
• secure the Services and investigate and help prevent fraud, security issues, and abuse;
• understand and resolve app crashes and other issues being reported;
• comply with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others;
• establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our Terms of Service, other usage policies, and other legal terms or controls, or to engage in other legal matters; and
• for any other purpose with your consent.

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

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.

3. COOKIES AND SIMILAR TECHNOLOGIES

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.

• A web server log is a file where website activity is stored.
• An SDK is a set of tools and/or code that we embed in our applications and software to allow third parties to collect information about how users interact with the Services.
• A cookie is a small text file that is placed on your computer or mobile device when you use the Services, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
• Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookies.

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

We may use third-party analytics services (such as Google Analytics and Amplitude Analytics) on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. For more information on the privacy practices of Amplitude, please visit the Amplitude Privacy Policy or write to Amplitude at privacy@amplitude.com.

We may also work with a number of companies that assist in marketing our services to you on third party websites, mobile apps, and online services. These third parties may use cookies, web beacons or other tracking technologies to collect information about your use of the Services and your activities across other websites and online services, which they may associate with persistent identifiers. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

Their activities and your choices regarding their use of your information to personalize ads to you are subject to and set out in their own policies. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party providers. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each third-party service provider, not us.

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.

5. HOW WE SHARE YOUR INFORMATION

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.

With Your Consent or At Your Direction. We may share information with third parties when you direct us to do so or if you have consented to additional sharing of your information (including as set out in this Privacy Policy).

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.

8. THIRD PARTY LINKS AND FEATURES

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.

These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. Copilot is not responsible for the practices of such third parties. Any information you provide to third parties on their websites or services is covered under their privacy and data collection collections, and is not covered by this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

9. CHILDREN’S PRIVACY

The Services are intended for a general audience and not for children under the age of 13. We do not knowingly collect, maintain, or use personal information (as defined by the United States Children’s Online Privacy Protection Act) from children under 13 years of age. If you believe that we might have any such information from a child, please contact us as described at the end of this Privacy Policy. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

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 unsubscribe@copilot.money with “OPT-OUT”, “UNSUBSCRIBE”, “STOP”, or “REMOVE” in the subject line.

Removing your name from the email list may take a reasonable amount of time. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Account Information. To keep your information accurate, current, and complete or delete your information, please contact us through the app or at privacy@copilot.money.

Additional Information. If you do not want the Service to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or disable certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you disable or reject cookies, some features may not work properly.

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 nevadarequests@copilot.money. 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.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through use of the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Updated” date included at the beginning of the document. If we make a material change to the Policy, we will provide you with notice in accordance with legal requirements. Your use of the Services following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.

14. CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, our privacy practices, please contact us at privacy@copilot.money or by writing to us at:

Copilot Money, Inc.

45 Tudor City Place, Apt 1118

New York, NY 10017