Date of Last Revision: May 5, 2023
1. Personal Information We Collect
A. Personal Information we collect from you
We may collect the following categories of Personal Information directly from you:
- Identification Information, such as name, email, phone number and postal address;
- Commercial Information, such as transaction activity, order activity, deposits, withdrawals and account balances;
- Financial Information, such as bank account and credit card information, routing number and IRA account information;
- Sensitive Personal Information, such as government-issued identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number)
- Correspondence, such as information that you provide to us in correspondence, including account opening and customer support; and
- Sensory Information, such as images collected for identity verification and audio recordings left on answering machines or when you call customer support.
B. Personal Information we collect automatically
We may collect the following categories of Personal Information automatically through your use of our services:
- Online Identifiers, such as IP address and domain name;
- Device Information, such as hardware, operating system, browser;
- Usage Data, such as system activity, internal and external information related to iTrust Capital pages that you visit and clickstream information; and
- Approximate geolocation data, such as latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation or other techniques.
2. How We Use Your Personal Information
The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve iTrustCapital. We may use your Personal Information to:
- Provide you with our services. We use your Personal Information to provide our services to you, to communicate with you about your use of our services, to respond to your inquiries and for other customer service purposes.
- Provide you with customer support. We process your Personal Information anytime that you reach out to our customer care team when there are issues arising from your account or to respond to your inquiries, comments, feedback or questions.
- Comply with legal and regulatory requirements. We process your Personal Information to comply with legal obligations and to protect our rights, privacy, safety or property.
- Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account.
- Protect the security and integrity of our services. To protect our own rights and interests, such as to resolve any disputes, enforce our Terms of Service, or to respond to legal obligations.
- Optimize and enhance our services. We use your Personal Information to better understand how users access and use our Site, both on an aggregated and individualized basis, to improve our Site and respond to user requests and preferences, and for other research and analytical purposes.
- Market our products to you. For example, to send you news, special offers, and promotions, or to otherwise contact you about products or information we think may interest you.
- With your consent. We may use your Personal Information for additional purposes with your consent.
- Other business purposes. We may use your Personal Information for additional purposes in the operation of our business, that would be reasonably expected based on context, and as permitted by law or required to comply with our legal obligations.
3. How We Share Your Personal Information
We will not share your Personal Information with third parties, except as described below:
- Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.
- Affiliates. We may share your Personal Information with our affiliates, for the purposes outlined above, and as necessary to provide you with our services.
- Legal Obligations. We may be required to share your Personal Information with law enforcement, government agencies, regulators or third parties to comply with legal or regulatory requirements.
- Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
- Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
- Consent. We may share or disclose your information with your consent.
- Other business purposes. We may share or disclose your Personal Information for other business purposes as permitted by law or required to comply with legal obligations.
We may make use of third-party Cookies or analytics services, including but not limited to Google Analytics. Google Analytics tracks visitor sessions to help the website analyze how users use the Site. This data is primarily used to optimize our website and mobile app for our visitors but we will use this data for marketing purposes. This data DOES NOT include any Personal Information. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google analytics, here: https://tools.google.com/dlpage/gaoptout (this requires you to install a browser add-on).
Third-party tracking technologies are not controlled by us, and statements regarding our practices do not apply to these third-parties or their use of information. We make no representations regarding the policies or practices of such third parties. You may be able to opt out of the practices of some of these third parties if they are members of the Network Advertising Initiative (“NAI”) by visiting http://www.networkadvertising.org or if they participate in the Digital Advertising Alliance (“DAA”) by visiting http://www.aboutads.info/choices. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.
Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. We currently do not respond to browser “Do Not Track” signals (this requires you to install a browser add-on).
You also can learn more about Cookies by visiting https://www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies on different types of browsers and mobile devices.
Please note that if you reject Cookies, you will not be able to use some of our Site. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use our Site. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
5. Direct Marketing
We may send periodic promotional emails to you. You may opt-out of such promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you necessary information about transactions or our business relationship.
6. Children’s Personal Information
iTrustCapital is not intended for children under the age of 18 and we do not knowingly collect Personal Information of children under the age of 18. If we learn that we have collected any Personal Information from a child under the age of 18, we will promptly delete it from our systems.
7. Information Security
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Personal Information from loss, theft, or misuse, and from unauthorized access, disclosure, alteration, and destruction. Nevertheless, no security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect iTrustCapital and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store.
We retain your Personal Information (including geo-location data) for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account with us, we will continue to retain your Personal Information as necessary to comply with our policies, legal obligations, resolve disputes and enforce our agreements.