Privacy Policy

This policy was last updated June 27, 2019

This “Privacy Policy” contains information regarding how Level Technologies, Inc. (“Level,” “We,” “Us,” or “Our”) collects and uses personal information. To make this Privacy Policy easier to read, our website, www.levelgoals.com, our mobile application (the “App”), and our other products and services are collectively called the “Platform.” We don’t share your personally identifiable information (“PII”) with anyone, except as specified in this Privacy Policy. PII generally includes, but is not limited to, a person’s name, address, email address, phone number, and any other information that is able to identify an individual.

 

If you have questions about deleting or correcting your personal data please contact our support team at support@levelgoals.com.

Third Party Service Provider Terms

By using the Platform you are engaging in transfers between your external bank account (the “User Bank Account”) and the “Level Account.” The Level Account consists of funds held by Evolve for your benefit in an FDIC-Insured “FBO” account held at Evolve Bank & Trust, Member FDIC, a subsidiary of Evolve Bancorp, Inc. (the “Bank”). Further, the Platform uses Synapse Financial Technologies, Inc. (“Synapse”), a third-party banking software provider, to carry out all financial transactions between your User Bank Account and the Level Account.


We rely on the Bank and Synapse as third party service providers (the “Providers”) to make the Platform available and each sets forth its own terms of use and privacy policy that governs your use of the Platform and the collection and use of your PII (the “Provider Terms”).

It is essential for you to read and understand the Provider Terms, and by using the Platform you represent that you have read, understood, and agree to the Provider Terms, which may change at any time, here is a non-exhaustive list of terms you agree to when using the Platform:

 

Collection and Use of Information

Your use of the Platform may result in certain PII collected or used by Level or the Providers.

 

We may use the information collected for several purposes, including but not limited to:

 

  • Process applications and transactions;

  • Verify identity;

  • Communicate with you;

  • Ensure legal and contractual compliance;

  • Protect against fraud;

  • Respond to customer service requests;

  • Perform analytics concerning your use of the Platform;

  • Improve the Platform; and

  • Carry out any other lawful purpose as may be disclosed to you at any time.

 

We may share the information collected with:

 

  • Non-financial service providers, such as identity verification and fraud prevention service providers;

  • Financial service providers, including the Providers;

  • Non-affiliated companies for Level’s everyday business purposes; and

  • Others in the form of aggregated and de-identified data, which cannot reasonably be used to identify you.

 

By using the Platform you consent to Level’s collection and use of information as specified below:

 

a) Registration Information.

In order to utilize some of the Platform you will need to set up an “Account” with us, we require certain identifying information that will be linked to your account, including your:

 

  • Name,

  • Mobile Number, and

  • Email Address.

 

We encourage you to exercise caution before voluntarily disclosing other types of PII about yourself, and prohibit you from disclosing any PII about another person, whether another account holder or not.

 

b) Verification and Compliance.

While users generally have the right to limit most information collected and shared via the use of the Platform, federal law requires the collection and verification of certain information as it relates to financial institutions. Specifically, in order to use the Platform, the Providers must verify certain information in order to carry out financial transactions. This information may include:

 

  • Name,

  • Address,

  • Tax Information,

  • Date of Birth, or

  • Social Security Number.

 

Additional documentary evidence, such as photo identification, might also be collected and shared for legal compliance and identity verification purposes. Level or the Providers may also collect public or non-public information about you in order to verify your identity, to prevent fraud, or otherwise provide the Platform to you.

 

c) Linking User Bank Account.

In order to link your User Bank Account to the Platform, the Providers might use and verify certain information in order to carry out financial transactions. This information may include:

 

  • Account and Routing Details,

  • User Bank Account Username and Password, and

  • User Bank Account Security Questions and Answers.

 

Additional documentary evidence might also be collected and shared for legal compliance and identity verification purposes.

 

d) Transaction Information.

By using the Platform, Level or the Providers may collect your Transaction Information. “Transaction Information,” includes but is not limited to User Bank Account and/or Level Account:

 

  • Transaction Types,

  • Transaction Amounts,

  • Transaction Dates and/or Times, and

  • Other details relating to the transaction.

 

Level or the Providers may use Transaction Information, in an anonymized or aggregated format stripped of personally identifiable information, to operate, provide, develop, and improve the Platform.

 

e) Use Analytics

The Platform automatically collects certain types of technical information, such as:

  • Browser or Device Type,

  • Language Preference,

  • Referring Site,

  • Operating System,

  • Page Views, and

  • Date and Time of Visit.

 

We use this information to better understand how our visitors use the Platform, and to maintain and improve Platform.

 

We use Google Analytics to help us understand how our Users use the site. For more information about your PII and Google, please visit www.google.com/intl/en/policies/privacy.

f) Location Information & IP Addresses

Internet Protocol (“IP”) addresses indicate the location of your computer or mobile device on a network connected to the Internet. Using the Platform may result in the logging of IP addresses for systems administration, troubleshooting purposes, and to prevent prohibited account sharing. While this may be used to infer an approximation of your location when using certain features of the Platform, we do not log IP addresses to track your location. If you are an account holder, we may link IP addresses to PII in order to monitor account sharing and prevent prohibited activity.

g) Data Aggregation

In addition to the other uses described in this Policy, you agree that we may extract and use information from the information you disclose for the purposes of aggregating data in a non-identifiable method. This aggregated data may be used to improve Platform or without limitation, to develop, analyze, combine, or publish the aggregated data for commercial purposes.

h) Cookies

Your use of the Platform may result in the assignment and storage of session cookies to recognize your access privileges. A cookie is a text file that is placed on the hard disk of your computer or mobile device by a server. Session cookies expire when you end your session and close your browser interface. Cookies cannot be used to run programs or deliver viruses to your computer or mobile device. Cookies are uniquely assigned to you, and can only be read by a server in the domain that issued the cookie to you. We use cookies to help us identify and track visitors, their usage of and preferences on our website. Visitors who do not wish to have cookies placed on their computers or mobile devices should set their browsers to “Refuse Cookies” before using our Platform, with the drawback that certain features of our Platform may not function properly without the aid of cookies.

The Providers may also place a cookie or similar file on your computer: (i) to customize your experience; (ii) to collect technical and navigational information; or (iii) for security purposes.

i) Behavioral Advertising; Marketing

We may use your PII to provide you with targeted advertisements or marketing communications. Our marketing communications contain information about unsubscribing from such communications.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s website at www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by visiting:

Facebook at www.facebook.com/settings/?tab=ads,

Google at www.gogle.com/settings/ads/anonymous, or

Digital Advertising Alliance’s online portal at www.optout.aboutads.info.

Protection of Certain Personally Identifiable Information
We take all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially PII. We disclose potential PII only on an as needed (or required) basis as follows:

  • To Our employees that: (a) need to know that information in order to process it on our behalf or to provide the Platform; and (b) that have expressly agreed not to disclose it to others. Note* Some of those employees, and contractors may be located outside of your home country; by using the Platform you consent to the transfer of such information to them.

  • As required by law such to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process.

  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request

  • If we become involved in a merger, acquisition, or any form of sale of some or all of its assets. In the event of a merger, acquisition, or any form of sale of some or all of our assets, we will ensure that the acquiring organization agrees to protect personal information in accordance with the commitments we have made in this Privacy Policy, and that the acquiring organization will provide notice before personal information, customer information, or business information becomes subject to a different privacy notice.

  • To any other third party with your prior consent to do so.

 

Feedback & Support

If you send us a request (via a support email or one of our feedback channels), we reserve the right to publish it (stripped of all PII) in order to help us clarify or respond to your request or to help us support other users (i.e. create a FAQ database).

 

We may provide technical support to service your Account with us. In order to do so, we may use certain PII, with your consent, to access your Account for the purpose of troubleshooting, running tests, and/or otherwise providing support. In providing technical support to you, we may potentially see other PII viewable on your Account pages. As with all other information, we will hold any information we encounter in the process of providing support to the highest possible security and protection standards.

Accessing and Updating your Personal Information

To review, access, or update your personal information to review its accuracy, or request deletion please contact us.

 

We will make commercially reasonable efforts to provide you with reasonable access to any of your personal or other account information held by Level within 45 days of your request. We provide this access so you can review, make corrections, or request deletion of your information. If we cannot honor your request within the 45-day period, we will tell you when we will be able to provide access. In the unlikely event that we cannot provide you access to your information, we will explain why we cannot do so.

Please note that any changes you make will be reflected in our active user database within a reasonable time, however we may retain information you submit for backups, archiving, prevention of fraud, to satisfy legal obligations, or otherwise we reasonably believe there is a legitimate reason to do so.
 

You can opt out of receiving marketing communication we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the emails we send you or by contacting support@levelgoals.com


Additional information for International Users

If you are visiting this website and/or accessing the Platform from outside the United States, please be aware that you are sending information (including PII) to the United States where our servers are located. This information may be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how we store it. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence, however, our collection, storage and use of your PII will at all times be governed by this Privacy Policy.

 

EU Users

If you are a resident of an EU nation and use our Platform from within the EU, you acknowledge that any information that we collect and store, for the limited purposes outlined above in this Privacy Policy, will be collected and stored outside of the EU. For avoidance of confusion, references to “personal information” in this policy are equivalent to what is commonly referred to as “personal data” in the EU.

 

By clicking “I Accept,” you consent to the collection, use, disclosure, and processing of your personal information in the manner described in this Privacy Policy, including our procedures related to cookies and IP addresses. We store data about or from you in the US. You understand that the US does not have the same level of protection for personal information that exists in other countries. Your consent is voluntary, and you may revoke your consent by opting out at any time. If you choose to opt-out, we can no longer provide you with the Platform. If you have enabled cookies on your web browser, you consent to our use of cookies as described in this Privacy Policy.

 

Security

To prevent unauthorized access, safeguard data accuracy, and maintain the appropriate use of information, we have put in place appropriate physical, technical, and administrative procedures to protect the PII you submit. We make every effort to ensure the integrity and security of our network and systems. However, since the Internet is not 100% secure and as new technology evolves and emerges, we cannot guarantee that our security measures will prevent third-party interferences from illegally obtaining or tampering with your personal information.

Online Banking Security: The Bank employs bank grade processes and technologies to protect the privacy and security of your information when you bank online, including firewalls, encryption techniques, and authentication procedures.

We encourage you to help us by also taking precautions to protect your personal data when you use the Platform. Change your Account password often, using a combination of letters, numbers, and characters, and make sure you use a secure connection.

 

Privacy of Minors

The Bank, Synapse, and Level does not promote or offer the Platform for use by anyone under the age of 13 (“minors”), knowingly solicit or collect PII from minors, and will not knowingly link to any third-party website or platform that solicits or collects PII from minors. If you believe that a minor has disclosed PII to us or that we have linked to such a third-party or user website or platform, please contact us.

 

Business Transfers

If our ownership substantially changes, such that all of its assets were acquired, or merged into another entity, or in the unlikely event that we enter bankruptcy, you understand that any stored personally identifying, and non-personally identifying information and data will likely be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer or our merging entity may continue to use your personal information as set forth in this policy.

 

Privacy Policy Changes

We may change or modify this Privacy Policy from time to time, in our sole discretion. We encourage you to frequently check this page for any changes to our Privacy Policy.