Privacy Policy

This Privacy Policy (“Policy”) describes how Ivella, Inc. (“Ivella,” “we,” “us,” or “our”) may collect, use, and disclose information from you and the choices you have regarding information that you supply to Ivella.

Please read this Policy carefully and contact us with questions at support@ivella.com.

Applicability of This Policy

This Policy applies to our services, which include the services we provide on www.ivella.com, our mobile application, or any other websites, pages, features, or content we own or operate that link to this Privacy Policy (collectively, the “Services”).

What We Collect

Information you provide to us:

• Account Information, such as your first and last name, email address, phone number, primary address, shipping address, social security number, profile picture, and birthday.
• Financial Information, such as your bank account number and credit or debit card information. For additional information relating to your choices about financial information specifically, see our GLBA Privacy Notice.
• Transaction Information, such as information about the transactions you make on our Services, including the transaction type, transaction subtype, transaction amount, transaction description, and timestamp.
• Partner Account Information, such as your partner’s account information, balance(s), or information about the transactions and transfers your partner makes on our Services.
• Demographic Information, such as income information, income source, income frequency, gender, sexual orientation, living status, and relationship status.
• Identity Verification Information, such as a government-issued ID, lease agreement, utility bill, and biometric information such as FaceID and TouchID.
• Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams, including via our help chat.

Information we get from other sources, such as:

• Public Databases. We may combine the information collected from these sources with the information we get through our Services in order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities.

Information we collect automatically, such as:

• Online Identifiers and Activity Data, such as, operating system, device manufacturer, carrier, Wi-Fi information, and session length.
• Information from Cookies and Other Tracking Technologies.  We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of our website and mobile apps,  collect information about the use of the Services and about our interactions with you, and for interest-based advertising purposes. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, and information about your interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. You may choose to set your web browser to refuse cookies or to alert you when cookies are being sent. If you do so, please note that some parts of our Services may not function properly.

How We Use Information

We use your information in accordance with your instructions, including any applicable terms in the Terms of Service, and as required by applicable law.  We may also use the information we collect for:

• Providing Services and Features. We may use the information we collect to provide, personalize, maintain, and improve our products and Services, including as we described in the Terms of Service. This includes using information to:
  
  - operate, maintain, customize, measure, and improve our Services and manage our business;
  ‍
  - create and update user accounts;
  ‍
  - process transactions;
  ‍
  - send information, including confirmations, notices, updates, security alerts, and support and administrative messages; and
  ‍
  - create de-identified or aggregated data.
• ‍Safety and Security.  We may use your information to help maintain the safety, security, and integrity of you and our Services, including to:
  
  - protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
  
  - monitor and verify identity or service access to combat spam, malware, or security risks;
  
  - perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems;
  
  - enforce our agreements with third parties, and address violations of our Terms of Service or agreements for other Services; and
  
  - comply with applicable security laws and regulations.‍
• Customer Support.  We may use information we collect to provide customer support, including to:
  
  - direct questions to the appropriate customer support person;
  
  - investigate and address user concerns; and
  
  - monitor and improve our customer support responses and processes.‍
• Research and Development.  We may use the information we collect for testing, research, analysis, and product development to improve your experience.  This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes, and develop new features and products relating to our Services.‍
• Legal and Regulatory Compliance.  We may verify your identity by comparing the personal information you provide against third-party databases and public records.  We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, or official inquiries.‍
• Marketing and Advertising
  
  - Direct Marketing. We may use the information we collect to market our Services to you. This may include sending you communications about our Services, features, promotions, surveys, news, updates, and events and managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by selecting “unsubscribe” to any marketing email sent by us or by contacting us at support@ivella.com.
  
  - Interest-Based Advertising. We may engage third-party advertising companies to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for our services to them or similar users on other online platforms. For more information, or to understand your choices, please visit the Online tracking Opt-Out Guide below.

How You Share Information Through Ivella

When connecting to a partner, you agree to share certain information with them.  This information includes your account information, transaction information, balance information, bank account information, and some card information.  When disconnecting from your partner, we are still required to show your partner some information regarding transactions that have occurred in the past.  This information includes historical account information and transaction information.

How We Share and Disclose Information

We may share your information in the following circumstances:

• With Partners, such as our banking partners, payment processors, payment networks, and other similar third parties.
• With Your Consent.  For example, you may opt-in to allow us to share personal information with companies for their own marketing uses.
• To Comply with Our Legal Obligations.  We may share your information: (A) to cooperate with government investigations; (B) when we are compelled to do so by a subpoena, court order, or similar legal procedure; (C) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person; (D) to report suspected illegal activity; or (E) to investigate violations of our Terms of Service or any other applicable policies.
• With Advertising Partners. We may share personal information that we collect on our website with third party advertising companies (including for the interest-based advertising purposes described above), lead generation partners, and channel partners, resellers, and distributors that allow us to explore and pursue growth opportunities.
• With Service Providers.  We may share your information with service providers who help facilitate business and compliance operations such as marketing, payment processing, data enrichment, card printing and fulfillment, security and fraud prevention tools, identity services, credit reporting and scoring agencies, external bank account information providers, and technology services.  Our contracts require these service providers to only use your information in connection with the services they perform for us, or for improving their own services.
• During a Change To Our Business.  If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-Identified Data. We may share aggregated and/or anonymized data with others for their own uses.

Security

We maintain administrative, technical, and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure.  However, no system can be completely secure. and we encourage all users to play an important role in information security, including by keeping log-in credentials private and secure.  If you have any questions about our security measures, please contact us at support@ivella.com.

Age Limitations

Our Services are not intended for use by any individual under 18 years of age.

Online Tracking Opt-Out Guide

Like many companies online, we use services provided by Google and other companies that use tracking technology.  These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet.  There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

• Blocking Cookies in Your Browser.  Most browsers let you remove or reject cookies, including cookies used for interest-based advertising.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit: www.allaboutcookies.org.
• Blocking Advertising ID Use in Your Mobile Settings.  Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using Privacy Plug-Ins or Browsers.  You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features and configuring them to block third-party cookies/trackers.
• Platform Opt-Outs.  The following advertising partner offers opt-out features that let you opt-out of use of your information for interest-based advertising:
  
  - Google: www.adsettings.google.com
  
  - Twitter: www.twitter.com/settings/personalization
  
  - Facebook: www.facebook.com/about/ads
• Advertising Industry Opt-Out Tools.  You can also use the opt-out options set forth below to limit use of your information for interest-based advertising by participating companies.  Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
  
  - Digital Advertising Alliance: http://optout.aboutads.info
  
  - Network Advertising Initiative: http://optout.networkadvertising.org

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not honor “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Changes to This Policy

If we make any changes, we will change the Last Updated date above.  We encourage you to review this Policy to stay informed.  If you continue to use the Services after the updated Privacy Policy is posted on the Services, you will be deemed to have consent to the new Privacy Policy.

Contact Us

Please contact us if you have any questions about this Policy or about how we use your data.  We will respond within a reasonable timeframe.  You may contact us at support@ivella.com or at our mailing address below:

1334 3rd Street Promenade
Unit 306
Santa Monica, CA 90401