Stash Financial, Inc.

Privacy Policy

Effective November 9, 2018

Stash Financial, Inc. and its affiliates, Stash Investments LLC (our registered investment adviser), Stash Capital LLC (our registered broker dealer), Stash Cash Management LLC (our banking and related services provider), and Stash Insurance Services LLC (our insurance services affiliate), welcome you. We refer to Stash Financial, Inc. and its current and any future affiliates as “Stash” in this privacy policy (“Privacy Policy”). This Privacy Policy is written to apply to Stash Financial, Inc. and all of its affiliates.

We respect your privacy. This Privacy Policy relates to the information collection and use practices of Stash in connection with our online services, including, for the avoidance of doubt, banking services provided by Green Dot Bank and offered through Stash (collectively, the “Services”). Our Services are available to you through a variety of platforms, including, but not limited to, www.stashinvest.com and learn.stashinvest.com (the “Sites”), and our mobile application, which is accessible through a variety of connected devices (the “App”). The Sites and the App are collectively referred to as the “Platform.”

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Platform, who view only publicly-available content (the “Visitors”) and customers who have signed up to access and use the Services offered by Stash through the Platform (the “Customers”).

By visiting or browsing the publicly accessible areas of the Sites or the App, Visitors are acknowledging that they have read, understood, and agree to be legally bound by this Privacy Policy and our Terms of Use. If you do not agree to any of the terms in this Privacy Policy or the Terms of Use, you may not access or use the Sites or the App

By signing up, accessing, or using our Services, each Customer is agreeing to the terms of this Privacy Policy, the Terms of Use, and any applicable customer agreements.

Information We Collect or Receive

In the course of operating the Platform and providing the Services, we collect or receive the following types of information:

1. Personal Information

When you register to become a Customer, you will be asked to provide us with certain information about you, such as, your name, date of birth, Tax ID number, citizenship, visa information, home address, telephone number, email address, bank account number, bank routing number, bank account login credentials, bank name, employer name, employment status, job position, whether you are a “politically exposed person,” whether you are a “control person” (pursuant to FINRA Rule 3210), annual income range, total net worth range, and other information as appropriate for our legitimate business needs (collectively and together with information referenced in Sections 2-6 below, the “Personal Information”). We may also collect Personal Information when you voluntarily provide us with Personal Information as a Visitor, such as when you use our “Contact” form.

2. Nonpublic Personal Information

When you register to become a Customer and at certain times following initial registration during the provision of our Services to you, we will also collect your nonpublic personal information which means (i) any information you provide to us to obtain a financial product or service from us, (ii) any information about you resulting from any transaction involving a financial product or service between us and you, or (iii) any information we otherwise obtain about you in connection with providing a financial product or service to you (collectively, the “Nonpublic Personal Information”). Nonpublic Personal Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy. We may also collect Nonpublic Personal Information from Visitors, who are consumers of our Platform.

3. Investment Style Information

When you register as a Customer, you will be asked to provide information about your investment preferences and investment style such as, your risk tolerance, time horizon, liquidity needs, investment objectives and investment experiences (collectively, the “Investment Style Information”). Investment Style Information may be updated or modified following initial registration during the provision of our Services to you. Investment Style Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy.

4. Card and Bank Information

Certain features of the Services will allow you to link your credit card, debit card, and bank accounts to your Stash account(s) by providing your account number, billing address and similar information (collectively, the “Card and Bank Information”). If you have a Stash Debit account, such account will automatically be linked to your Stash investment advisory accounts. Card and Bank Information may be collected and processed by one or more third parties pursuant to the terms and conditions of their respective privacy policies and terms of use. Card and Bank Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy. Stash stores your Card and Bank Information and uses it as set forth in this Privacy Policy.

5. Transaction Information

When Customers wish to make a purchase, sale or any other transaction through the Platform, they must provide us with certain information about the transaction they are seeking to execute. Such information is collectively called the “Transaction Information.” Transaction Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy.

6. Geolocational Information

Certain features and functionalities (such as the location service within the Stash Cash Back Program) of the Services are based on your location. In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocational information from your mobile device, wireless carrier, or certain third-party service providers. Such information is collectively called the “Geolocational Information.” Collection of such Geolocational Information occurs only when the App is running on your mobile device. You may decline to allow us to collect such Geolocational Information, in which case Stash will not be able to provide certain features or functionalities to you.

7. Other Information.

We may automatically collect or receive additional information about you, your use of our Platform, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our Platform (collectively, the “Other Information”). Such Other Information may include, but is not limited to, the following:

  1. From Your Activity
    • IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
    • Browser type and language;
    • Referring and exit pages and URLs;
    • Date and time; and
    • Details regarding your activity on the Platform, such as search queries and other performance and usage data.
  2. About Your Device
    • Type of device;
    • Universally Unique Identifier (“UUID”);
    • Advertising Identifier (“IDFA” or “AdID”);
    • Operating system and version (e.g., iOS, Android or Windows);
    • Wireless carrier; and
    • Network type (WiFi, 3G, 4G, or LTE).
  3. From Cookies, Web Beacons, and Other Similar Tracking Techniques

    In operating the Platform, we may also use data collection and tracking tools such as web beacons, pixel tags, embedded links, cookies, and other similar tracking techniques. A cookie is a piece of information that the computer that hosts our Platform gives to your browser when you access the Platform. Our cookies help provide additional functionality to the Platform and help us analyze the Platform usage more accurately. For example, our Platform may set a cookie on your browser that allows you to access the Platform without needing to remember and then enter a password more than once during a visit to the Platform. In all cases in which we use cookies, we will not collect Personal Information unless we obtain your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. If you do not want Stash to place cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still use the Platform, although your ability to use some of the features may be affected.

  4. Third-Party Analytics

    We may use third-party analytics services (for example, we use Google Analytics, Mixpanel, Braze, and others) to evaluate your use of the Platform, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit https://www.google.com/analytics, https://mixpanel.com/privacy/, or https://www.braze.com/privacy/. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.

Information Collected by or Received from Third-Party Sources

We may also collect Personal Information and information about your transactions with us and those you engage in with our affiliates, unaffiliated third parties, banking verification services and information from consumer reporting agencies. We may further collect information about you from third-party data sources, such as brokers, banks and government databases. We may combine data we collect about you from third-party data sources with data we collect from you and may use and share such data as described in this Privacy Policy. All information we collect and/or receive from such third-party sources is collectively referred to as “Third-Party Information.”

For example, we use Plaid Technologies, Inc. (“Plaid”) and Quovo, Inc. (“Quovo”) to gather your data from financial institutions. This data may include information from all your sub-accounts (e.g., checking, savings, and credit card) accessible through a single set of account credentials, even if only a single sub-account is designated by you. By using our Services, you grant us, Plaid, and Quovo the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal) and by Quovo in accordance with the Quovo Privacy Policy (https://www.quovo.com/legal/privacy-policy/). If you have a Stash Debit account, you agree to your personal and financial information being transferred by Green Dot Bank to us in accordance with the Green Dot Bank Privacy Policy.

We also have partnered with a third-party service provider, Empyr, Inc. (“Empyr”), which enables us to provide offers linked to your debit or credit card in connection with your use of the Service (the “Stash Cash Back Program”), as further described in the terms and conditions governing the card-linked offer element of our Services (the “Terms and Conditions of the Stash Cash Back Program”). You must opt in to access and use the Stash Cash Back Program by registering your eligible credit or debit card, sharing your payment information with us, and allowing us to share your payment information with our third-party service providers (including Empyr) and the payment card networks (e.g., Visa, Mastercard, American Express). Any such third party service provider enables us to provide the Stash Cash Back Program to you. In connection with your participation in the Stash Cash Back Program, we and such third-party service providers (including Empyr) will receive and collect card transaction data from the relevant payment card network (such transaction data, “Cash Back Data”) in connection with providing the services under the Stash Cash Back Program.

Information Collected by or Through Third-Party Advertising

We may share Other Information about you with third parties that Stash has selected and approved for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data. You may choose to opt-out of this type of tracking and sharing of information at any time by selecting the specific partners you wish to exclude from these websites: http://www.aboutads.info/choices and http://optout.networkadvertising.org/.

How the Information is Used and Shared

You authorize us to use the Personal Information, the Third-Party Information, and the Other Information (collectively, the “Information”) to provide and improve our Platform and Services; to help us improve the content and functionality of our Platform and Services; to provide trade recommendations; to advise you about your portfolio; to solicit your feedback; and to inform you about our products and services and those of third parties.

You also authorize us to use and/or share Information as described below.

  • We will access, use, and share the Information as required to fulfill our contractual obligations to you or subsequent requests for support by you.
  • To track your purchases, match your purchases with the other Information we have about you and provide suggestions to you about potential trade recommendations, saving money, and other financial services and offers that we believe may help you.
  • Stash, like many businesses, sometimes hires other companies to perform certain business-related functions on our behalf. Examples of such functions include website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide it with the information that it needs to perform its specific function. These companies are authorized to use your Information only as necessary to provide these services to us.
  • We may share some or all of your Information with any of our parent companies, affiliates, subsidiaries, joint ventures, or other companies that we control, are controlled by, or are under common control with us.
  • If you sign up for a Stash Debit account, we will share Information with Green Dot Bank as needed for Green Dot Bank to deliver its services to you and for us to fulfill our contractual obligations to Green Dot Bank;
  • As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Platform of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
  • In an ongoing effort to better understand our Customers, the Platform, the Services, and the products and services of Stash, we may analyze certain Information to compile information about our Customer demographics, interests and behaviors and to create data analytics on an aggregate basis. This aggregate information does not identify you personally. We may share this aggregate information with our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Platform, the Services and our products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
  • Stash may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Stash, (iii) act in urgent circumstances to protect the financial security of users of the Platform or the public against fraud or other harm, or (iv) protect against legal liability.
  • Stash may from time to time enter into agreements with third parties, such as employers or affiliate membership groups, pursuant to which the third-party may pay a portion or all of the advisory fees of its employees or members, and may on occasion make direct or indirect contributions to the Stash account of its employees or members. This is generally implemented by distributed "promotional codes" that are sponsored by the employer or affiliate membership group. If you use the benefit provided by an employer or affiliate group, you consent to additional anonymized reporting with respect to the participation, contribution rates, engagement, etc., of the employees or members, and consent to personalized reporting (i.e., where you may be specifically identified) solely and exclusively to (x) confirm your use of Stash to your employer or affiliate membership group, and (y) if the employer or affiliate membership group makes a contribution to your Stash account, to confirm receipt of the specific amounts contributed. In addition, if the benefit the employer or affiliate group provides includes embedding the Stash experience in a broader experience hosted by the employer or affiliate, by using such benefit you consent to Stash embedding the Stash experience in the hosted experience, and understand that your Personal Information may be shared in order to implement the hosted experience.
  • We may share your Information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate market research data for us which will not identify you personally. Such third parties will provide us market research data to help us better segment our customer base and understand what products and services would likely work best for our customers.

Notwithstanding anything to the contrary in this Privacy Policy, our Terms of Use, and the Terms and Conditions of the Stash Cash Back Program, we and our third-party service providers that enable us to provide the Stash Cash Back Program to you (including Empyr) will use Cash Back Data solely as described below.

  • We will use Cash Back Data to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a statement credit or a card-linked offer;
  • We will share Cash Back Data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points or other promotions should be awarded -- for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
  • We may provide participating merchants or third-party service providers aggregated and anonymized information relating specifically to linked card activity solely to allow participating merchants and third-party service providers to assess the results of their campaign;
  • We will create a record of the Cash Back Data and thereafter maintain and use such data in connection with operating the Stash Cash Back Program;
  • We may conduct analysis for the improvement and optimization of the Stash Cash Back Program; and
  • We may provide information in order to respond to a request from a government authority or a payment organization involved in a transaction with you or a merchant.

You authorize the sharing, exchange and use of Cash Back Data described above and herein by and among Stash and our third-party service providers (including Empyr), applicable payment card networks and applicable merchants participating in the Stash Cash Back Program.

If you have consented to participate in our Stash Cash Back Program, please visit the Terms and Conditions of the Stash Cash Back Program on our Site (at www.stashinvest.com/disclosurelibrary) to learn more about the card linking and transaction eligibility in connection with the Stash Cash Back Program. If you would like to opt out of the Stash Cash Back Program and unlink your cards, please contact us at [email protected] or follow the steps below:

  1. Go to “My Cards”
  2. Select the card you would like to unlink from the Stash Cash Back Program
  3. Confirm you want to unlink the card
  4. You must repeat this process for every card you wish to unlink.

Unlinking your card from the Stash Cash Back Program will not affect your enrollment in any other services offered by Stash for which you may have separately and independently enrolled your card.

If you would otherwise like to opt-out of Stash’s sharing of your Information with affiliates and third parties, please contact us at [email protected]. We will use your Information for our internal business purposes, including but not limited to, creating user state modeling and comprehensive behavioral profiling.

If Stash intends on using your Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Information is collected.

Sharing of Your Information with Non-affiliated Third Parties

We will not share your Information with non-affiliated third parties that may use your Information to market to you, without obtaining your opt-in consent. For example, we may offer you with a product opportunity that requires us to share your Information with non-affiliated third parties that may use your Information to market to you. We will obtain your opt-in consent to such sharing of your Information when we present you with the terms of such offer.

If you have opted-in for this kind of sharing of your Information, then you may: (i) choose to opt-out of such sharing by contacting us at [email protected]; or (ii) request certain information regarding our disclosure of your Information to such non-affiliated third parties by contacting us at [email protected]. If you have signed up for a Stash Debit account, you will not be able to opt out of us sharing Information with Green Dot Bank, the provider of the Stash Debit account.

Accessing and Modifying Information

If you have provided us any Personal Information, you may access, review, and/or make changes, by making the changes in your registered account settings page, by emailing our Customer Support at [email protected] or by contacting us at the contact information listed below.

Communication Preferences

When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you.

If at any time you wish not to receive any future newsletters or marketing communications or you wish to have your name deleted from our mailing lists, please following the unsubscribe instructions included in these emails or contact us at [email protected]. We will use commercially reasonable efforts to process such requests in a timely manner. Note however that as a user of the Services we and/or our custodian(s) will send you administrative and transactional communications that are reasonably necessary to provide the Services, such as billing, brokerage or service notifications and you cannot opt out of receiving such communications.

We may also deliver notifications to your phone or mobile device. You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

By providing your phone number you expressly consent to Stash and/or its agents calling or texting you using an automated telephone dialing system and / or prerecorded messages, even if you incur charges for receiving such communications. For example, we may send you informational text messages to your mobile device in order to better service your account. You can revoke your consent to receiving informational text messages at any time by replying “STOP” or following any other instructions included in these text messages or you can contact us at [email protected].

Surveys

We may, from time to time, ask you to participate in surveys on our Sites. Participation in these surveys is completely voluntary. These surveys may be conducted by our third-party service providers. Such third-party service providers are authorized to use your information only as necessary to conduct these surveys for us. We will use survey results to continue to improve the Platform and the Services. We will use your Personal Information from our surveys to send you information about our products and services and about third-party products and services. We may combine your survey information with other data we have about you, and if such other data is Personal Information, the combined data shall be considered Personal Information under this Privacy Policy. We may also anonymize and aggregate the survey information and sell it to third parties.

How We Protect Your Information

The security of your information is important to us. When you enter sensitive information (such as bank account information) in our App, we encrypt the transmission of that information using secure socket layer technology (SSL). We and our custodian also use third-party ID verification to ensure our users’ true identities are validated.

We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. If you have any questions about security on our website, you can contact us at [email protected].

Retention of Your Information

We will retain your Information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We will also retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Exclusions

This Privacy Policy does not apply to any Personal Information collected by Stash other than Personal Information collected through the Platform and/or Services. This Privacy Policy shall not apply to any unsolicited information you provide to Stash through the Platform, or through any other means. This includes, but is not limited to, information posted to any public areas of the Platform (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Stash shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

Suspicious Email

We do not email you or send you other electronic communications to request nonpublic information or account information (such as username and password). If you receive an unsolicited email or other electronic communication that appears to be from Stash but you suspect it may be from some other source or fraudulent, please email us at [email protected].

Children

The Platform is not directed to children under 13, and Stash does not knowingly collect or receive Personal Information from children under the age of 13 through the Platform and/or the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide any Personal Information on the Platform, the Services, or any other website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to Stash through the Platform and/or the Services, please contact us at [email protected], and we will endeavor to delete that information from our databases.

If you establish an account with us that is governed by the Uniform Gifts to Minors Act or the Uniform Transfers to Minors Act that is for the benefit of a child under the age of 13, only the individual establishing the account provides Personal Information to us necessary to establish the account for the child under the age of 13. Subsequent to the creation of the account, we will only collect and use Personal Information related to the child for the limited purpose of providing the Services, and except as set forth in this Privacy Policy, such information will not be shared with third parties for any purpose not required or permitted by law, including marketing.

Links to Other Websites and Integration of Third-Party Content

This Privacy Policy applies only to the Platform. The Platform may contain links to other websites or services not operated or controlled by Stash (the “Third-Party Sites”). The policies and procedures we describe here do not apply to the Third-Party Sites. The links from the Platform do not imply that Stash endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

In addition, we may integrate third-party content from other websites, such as YouTube videos, into the Platform. Our use of YouTube’s API services subjects you to Google’s Privacy Policy available at http://www.google.com/policies/privacy when you access YouTube content through our Services and you agree to certain of your information being collected by YouTube as applicable and in accordance with such privacy policy.

Federal Privacy Notice

Stash is required by federal law to provide consumers with information regarding our collection and sharing of nonpublic personal information. Please see our Privacy Notice for more information.

California Residents

Stash does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Former Customers

If your customer relationship with Stash ends, we will not destroy your Information unless required or permitted by law. We will continue to treat your Personal Information in accordance with this Privacy Policy and applicable laws.

Other Important Notices

The Platform and the Services are intended for natural persons who are citizens or other lawful residents of the United States and who are located in the United States. The Platform, the Services and their servers are controlled and operated in the United States. Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Platform and/or the Services, you do so at your own risk.

Changes to Stash’s Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Platform prior to the change becoming effective. By visiting and/or using the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect such information. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Stash

Please feel free to contact us if you have any questions about Stash’s Privacy Policy or our information practices:

Email: [email protected]

Phone: 1 (800) 205-5164