Privacy Policy
THIS IS A WEBSITE PRIVACY DRAFTED UNDER U.S. LAW. THIS POLICY IS NOT INTENDED TO SATISFY ANY ‘FAIR PROCESSING NOTICE’ OBLIGATIONS THAT YOU MAY HAVE UNDER GDPR OR OTHER APPLICABLE NON-US LAW.
EFFECTIVE DATE: January 3, 2025
In this Privacy Policy (“Policy”), we describe how corridorX and its affiliated entities (“[corridorX],” “we,” “us,” or “our”) collects, uses, and discloses information that we obtain about visitors to our website (the “Site”), users of our mobile application (the “App”) and the services available through our Site and App (collectively, the “Services”).
By visiting the Site, using or downloading the App, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms and Conditions, including its applicable limitations on damages and the resolution of disputes. The applicable corridorx Terms and Conditions are incorporated by reference into this Policy.
The Information We Collect About You
We collect information about you directly from you, from third parties, and automatically through your use of our Site, App, or Services.
Information We Collect Directly from You.
The information we collect from you depends on how you use our Services.
Employees. If your employer makes the corridorx Services available to you, we will collect the following information from you.
To create an account, you must provide your employer-provided activation code and create a password for your account.
You may provide us with information about your finances, such as your assets, liabilities, budgets, and other information about your financial goals.
Employers.
If you are an employer or human resources administrator accessing the Services, we will collect your name and email address.
All Users:
If you subscribe to our mailing list or newsletters, we will collect your name and email address.
If you contact us or request information from us through the Services, we will collect your name, contact information, and your communications with us.
Information We Collect from Other Sources.
We collect information about our employee users from other sources.
When you create your account with us, we will collect certain payroll information from your employer, such as your net income (e.g., the amount you take home after taxes and deductions), date of birth, address, your name, phone number and email address.
When you link your financial accounts to the Services, we will collect information from your financial institutions, such as your account balances, interest rates, pay off dates and account activity (including historical account activity information).
Information We Collect Automatically.
We automatically collect information about your use of our Site, Apps, and Services through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we may combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Information We Automatically Collect Through the Site:
your browser type and operating system;
web pages you view or content you access on the Site or Services; links you click on the Site or Services; your device’s IP address;
the referring URL, or the webpage that led you to our Site.
the length of time you visit our Site and/or use our Services;
Information We Automatically Collect Through the App:
Mobile device ID; device name and model; operating system type, name, and version;
device language settings;
activities within the App, including content you view and features you use; and the length of time that you are logged into our App.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
Service Provisioning/Transactional Purposes:
To provide our Services to you, including providing you with financial wellness advice and facilitating transactions that you direct.
To communicate with you about your use of our Services; to fulfill your orders or instructions, to respond to your inquiries, and for other customer service purposes.
To tailor the content and information that we may send or display to you, to provide personalized help and instructions, and to otherwise personalize your experiences while visiting or using the Services.
Marketing Communications: In accordance with applicable laws, we may use your information:
To send you marketing communications about our Services and other offerings.
To send you news, newsletters, and event information.
To send you marketing communications about products and services of our affiliated entities.
To send you marketing communications about products and services of other entities that we think may be of interest to you. If you are interested in these entities’ products and services, you may provide your information directly to the appropriate entity.
Sites, Apps, and Services Improvement/Research:
To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Services are more (or least) used by users, and we will use this information to update or add new features to our Services. We may also use feedback provided by users to update our Services or develop new offerings.
To administer surveys and questionnaires, such as for customer engagement, market research or user satisfaction purposes.
To create aggregated, anonymized, pseudonymized or de-identified data sets. We may use such data sets for product improvement and development, marketing, advertising, trend analysis and other purposes.
Legal Purposes:
To comply with legal obligations and act in accordance with legal authorizations, as part of our general business operations, and for other business administration purposes, including to comply with our legal and regulatory requirements, authenticating your identity, maintaining our records, to monitor your compliance with your agreements with us, to collect debts owed to us, to safeguard our business interests, and to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or merger, as described below.
Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or property, or violations of this Policy, your customer agreement, and any applicable terms and conditions.
For other purposes we may inform you about from time to time. Where required by applicable laws and regulations, we will obtain your consent if we wish to use your personal information for purposes requiring such consent.
How We Share Your Information
We may share your information, including personal information, as follows:
Your Financial Institutions. When you direct us to facilitate transactions or payments to your financial or loan accounts, we will share information necessary to complete the transaction, such as your name, account number, and transaction payment information with your financial institution.
Your Employer. To help our employee users meet their financial goals, we work with your employer to make transfers or payments to your accounts directly from your paycheck. When you authorize transactions through the Services, we will share information necessary to facilitate the transaction with your employer. This includes transaction amounts and the routing and account numbers at the respective financial institution.
Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include our hosting provider for the Services, providers to help us integrate with your employer’s payroll system, and fintech companies to help us complete your transactions.
Financial Account Transaction Information. To provide us with access to your financial account transaction information, we use the services of Plaid. When you agree to provide us with access to your financial account transaction information, you agree that Plaid will have access to your information, and its access to such information is covered by Plaid’s privacy policy , not this one.
Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries for the purposes described in this Policy.
We also disclose information in the following circumstances:
Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, law enforcement request, or other legal process, such as in response to a subpoena.
To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or your customer agreement or this Policy, or as evidence in litigation in which we are involved.
Aggregate and De-Identified Information. We share aggregate, anonymized, pseudonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Our Use of Cookies and Other Tracking Mechanisms
We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site, App, or Services. We may combine this information with other personal information we collect about you (and our service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
