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Privacy Policy: Contents and Summary

A list summarizing the contents of this privacy policy ("Privacy Policy") appears below, followed by the policy in full. Should there be any discrepancy between the summary and the full Privacy Policy, the language of the full Privacy Policy shall govern.

Scope and Consent

By using the application, you expressly consent to our collection, use, disclosure, and retention of your personal information and other information as described in this Privacy Policy and the privacy policy of your financial institution. Your use of the application is also governed by the Terms of Use.

Information Collection

We collect the following information when you use the Application.
(a) Registration and Profile Information: When you activate the Application, you voluntarily provide personal information including your email address.
(b) Information About Payees: If you initiate a payment, you may give us their personal information including email address, financial institution routing number, and financial institution account number.

Use and Retention

Information collected from the Application in the normal course of use is retained in accordance with legal and regulatory requirements. Use of any information collected from or retained by the Application is governed by this Privacy Policy and the privacy policy of your financial institution.

Disclosure

In general information collected by the Application will be disclosed solely with your financial institution. Certain other disclosures to law enforcement or for purposes of support may be required.

Access and Review Options

You can review your personal information by accessing your profile on the Application. You can edit your personal information by contacting your financial institution.

Security

We protect your personal information using security measures built in to your mobile device as well as into the Application. Payment information is exchanged between the Application and your financial institution via secure channels.

Notification Regarding Updates

You agree that we may notify you about material changes to this Privacy Policy by posting notices through the Application or via communication with your financial institution.

Contact Us

For more information about our privacy practices, please continue to our full Privacy Policy below or send an email to support@excheq.com

Full Policy

1. Scope and Consent

When you use the Application, you are contracting with Excheq, LLC, located at 1901 Oakcrest Avenue, Ste 9A, Roseville, MN 55113. By using the Application, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

2. Information We Collect

a.   Registration and Account Information: We collect personal information, such as your name, email address, name of the financial institution where you hold accounts, and financial account numbers at the time of Application activation. Additionally, if you have activated the Application, your financial institution’s privacy policy applies to the information that we collect through the Application and to any information that your financial institution provides to us.

b.   Information About Payees: In the normal course of Application use, you will submit personal information about other people in order to initiate a payment to pay them. This information includes their name, email address, the name and routing number of the financial institution where they hold an account, and financial account numbers. You should receive your consent to your sharing of their personal information before submitting it to us.

3. Use, Retention and Disclosure

a.   Application Operations: We use the information collected to (i) respond to your requests; (ii) enable your financial institution to initiate payments between you and a payee; (iii) send you an email to notify you of an initiated payment; (iv) facilitate your activation of the Application and resolve issues relating to that activation; (v) resolve a problem related to a payment with your financial institution; (vi) provide customer service and obtain your feedback regarding the Application (e.g., to resolve disputes, problems with your instance of the Application); (vii) improve the Application; (viii) provide you with a safe, efficient, and customized experience.

b.   Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze Application and user behavior and for general business purposes, including but not limited to data analysis, audits, developing new products, enhancing our Application, identifying usage trends, and improving services.

c.   Prevent Fraud: We use information from the Application to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Use.

d.   Communicate With You: We use your information to contact you to maintain the Application, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, or contact you for other purposes (e.g. customer service purposes), or otherwise authorized by law.

e.   We retain information (i) for that time period necessary to complete payment initiation; (ii) in accordance with legal and regulatory requirements; (iii) in accordance with your financial institution’s Privacy Policy.

4. Disclosure

a.   In general, Excheq, LLC discloses information provided to us by you solely to your financial institution. Please see your financial institution’s Privacy Policy for further information regarding disclosure.

b.   With Your Consent, Excheq, LLC will disclose information to other third-parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

c.   We will disclose requested information to Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, your financial institution, or any other User to legal liability. In this regard, we may share your information with third parties in response to a subpoena, other legal process and/or as permitted by law. In such events, we will only disclose information relevant and necessary to the investigation or inquiry.

d.   Change of Control - New Owners: We may share your information with other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice.

5. Accessing, Reviewing, and Changing Your Personal Information

Registered Application users can review personal information at any time by accessing their settings on the Application. You should promptly update your personal information with your financial institution if it changes or becomes inaccurate who will initiate a change process with you for the Application. We may retain some information from closed accounts/profiles so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account/profile is terminated or suspended, we may maintain some information to prevent re-registration.

6. Security

Your information is stored in obscured form on servers provided by Amazon Web Services. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account/profile registration information are secure and not shared with third-parties.

7. Notification Regarding Updates

From time to time, we may update this Privacy Policy. You agree that we may notify you about material changes in the way we treat personal information by notifying you through the Application or via communication via your financial institution.

8. Contact Us

If your questions are not answered online, you may email us at support@excheq.com, or using the contact us form at https://excheq.com/ or write to us at Excheq, LLC, 1901 Oakcrest Avenue, Ste 9A, Roseville, MN 55113.