Privacy Policy

Effective Date: July 21, 2021

1. About Us

We are Lambda Financial Technologies, Inc. (referred to as "Klutch" or “we” or “us”) and we are committed to protecting your personal information and your right to privacy. This document ("Privacy Policy") explains what information we collect, how we use it, and your rights if you want to change how we use your personal information.

If you have any questions about our Privacy Policy or how it applies to specific data, please reach out to our privacy team at privacy@klutchcard.com

2. How We Collect Information

We collect information when you interact with us in the following ways:
- Register to use Klutch’s Services, including mobile applications, websites, software, hardware, and other products and services (“Services”) as defined in our Terms of Service;
- Process transactions through your Klutch account;
- Connect your social media account(s);
- Use of the Services;
- Communicate with us.

3. Types of Information We Collect

The types of information we may collect include, but are not limited to:

3.1 Personal information you provide to us.
When you create an account with us, we are required to collect your personal information including your first and last name, email, birth date, phone number, postal address, and social security number. To help the government fight the funding of terrorism and money laundering activities, we share the information we collect with our Bank partner and service providers to verify your identity for the Services. We may also ask to see other identifying documents such as a driver’s license, passport or verification of an address. If for any reason, you are unable to provide the information necessary to verify your identity, you will not be permitted to access or use the Services. Additionally, we may collect information from you through communications, including interactions with customer support, joining our waitlist, and survey responses.

3.2 Automatically-collected data.
We collect certain information automatically from you when you access or use the Services, read our emails, or otherwise engage with us. This includes when you initiate a transaction, send payments, what you click on, time you spend on our mobile application or website, or otherwise engage with or use the Services.  We collect information about the computer or mobile device you use to access the Services which may include your IP address, zip code associated with your server, browser type, device type, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device or your account. We collect browsing information, such as where you click on our website or Uniform Resource Locator ("URL") that may have directed you to our website or that you just came from, or the URL that you go to after visiting our website. We do not control third-parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. If you prefer not to accept cookies, most browsers will allow you to configure your preferences or options to determine if and how a cookie will be accepted, disabled, or rejected.  You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain actions with it. 

3.3 Information from third parties.
Your information collected through our Services may be combined with other information we collect about you from third-party sources, as permitted by law. This may include information from publicly available sources to verify your identity, verify your account, prevent fraud, enable a collection procedure, or as may be otherwise required by law.

4. How We Use Information

We will use the information we collect for any the following legitimate business purposes: 
- To create an account and deliver the Services to you. We may provide it to our service providers and Banking Partner to allow us to provide you the Services (i.e. identity verification, fraud prevention, ability to fund to your account, process payments, process applications, ensure quality control, operate and monitor the Services, and other functionality or features of the Services);
- To respond to your requests, comments or questions;
- To send you transactional information, product and services information, updates, security alerts, and support and administrative messages;
- To improve the quality of the Services and product design, such as store your preferences, monitor and analyze trends and usage, provide you with tailored content and offers, and customize the Services; 
- To improve marketing or promotional efforts from better understanding your journey to finding the Services and your interests and needs;
- We may anonymize and aggregate data collected through the Services. We may use this anonymized data and share it with third parties in any matter permitted by law to analyze, build and improve the Services and promote the Services. When any non-personally identifiable information is combined with other information that identifies you, it will be treat as personal information in accordance with this Privacy Policy;
- To facilitate contests, promotions, and rewards and provide you news about Services offered by us and our selected partners;
- To comply with applicable laws and regulatory requirements; 
-To protect the safety of any person, to address fraud, security or technical issues, or to protect our rights or property; or
- For any other purpose for which you provide consent. 

5. Who We Share Information With

We may share information that we collect with our service providers and business partners. We will share information that we collect to protect you, us, or third parties. We may share personal information:

- To comply with applicable law or regulation;
- To enforce our contractual rights;
- To protect the rights, privacy, safety and property of Klutch, you, our business partners, or others; and
- To respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. When complying with court orders and other similar legal processes, Klutch strives for transparency. We will make reasonable efforts to notify the relevant party of any disclosure of their personal information, unless we are prohibited by law, court order, or exigent circumstances prevent us from doing so.

5. Who We Share Information With

We may share information that we collect with our service providers and business partners required in order to provide you the Services. We will share information that we collect to protect you, us, or third parties. We may share personal information:

- To comply with applicable law or regulation;
- To enforce our contractual rights;
- To protect the rights, privacy, safety and property of Klutch, you, our business partners, or others; and
- To respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. When complying with court orders and other similar legal processes, Klutch strives for transparency. We will make reasonable efforts to notify the relevant party of any disclosure of their personal information, unless we are prohibited by law, court order, or exigent circumstances prevent us from doing so.

We may use third parties to send advertisements on our behalf. We may only share a very limited set of personal information required to deliver our advertisements to you (such as an email address to deliver the message to you), and we do not permit third parties to use or share your personal information to advertise unaffiliated products or services to you. These third parties may also use cookies or similar tracking tools to identify you through your browser usage. While you may disable these tools in your browser settings, you may still receive non-targeted advertisements we sent as part of a general marketing campaign.

In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal information and data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Klutch may continue to process personal information consistent with this Privacy Policy. 

We do not rent, sell, or share personal information about you with other people or non affiliated companies for their direct marketing purposes, unless we have your permission. We also do not provide any personal information to any third-party ad networks. We disclose your information to the categories of service providers or other partners listed below. These parties help us provide you the Services or perform business functions on our behalf. 
- Payment processors, payment networks, and program managers. Klutch uses Productfy in order to provide the Services to you. Please see Productfy’s Privacy Policy here;
-Banking Partner. Klutch has partnered with Stearns Bank, N.A. in order to provide the Services to you. Please see Stearns Bank Privacy Policy here
- External bank account information provider. Klutch is using third party services from Yodlee to allow you to connect an external banking account. Please see their privacy policy here;
- Card fulfillment vendors;
- Identity services;
- Risk investigation and migration tools, transaction dispute processing services;
- Hosting, technology and communication providers;
- Security and fraud prevention consultants and detection;
- Analytics providers, such as Google Analytics; and
- Customer support vendors.

6. Where We Store Personal Information

Your information collected through our Services may be stored per this Privacy Policy in the United States. We will store this information while we continue to develop our products and services to you, to operate our business, comply with contractual obligations, and for as long as required by law. Information may be stored using cloud-based services and may be maintained by third-party networks in locations in which such third-party networks operate or maintain data storage or processing facilities. The security of your information is a priority to us. We use organizational, technical, and administrative practices, protocols, and procedures to preserve the security your information. We also inquire and understand our partners security systems to ensure maximal security. We take measures to limit access to your information only to those with a need to know in order to provide you the Services. However, no security system is impenetrable, and we cannot guarantee that our data security program is entirely secure. We do not accept liability for unintentional disclosure. Please contact us immediately if you believe that your personal information is no longer secure or has been lost or stolen. If we confirm that there has been a breach of personal information or confidential data related to you, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. 

‍If you ask us to delete specific personal information, we will honor your request unless deleting the information prevents us from conducting required audits, or carrying out other legitimate business functions, or we are required by law or contractual obligation to keep that information.

7. Other Important Information About Your Personal Information

You must be at least the age of majority in the United States to have our permission to use this website. We do not knowingly process any information from or direct any of our products or services to children. Our Services are intended for adults. 

In some circumstances, we require you to provide us with personal information relating to another person. Do not provide us with any personal information unless you have obtained consent of these persons or you are sure the disclosure of the personal information is otherwise permitted by law. You must inform all other persons whose information you share with us how we process personal information and all other terms of this Privacy Policy.

Our website does not respond to "do not track" signals sent by internet browsers. However, our website may provide links to other websites. Please be aware that when you click on one of these links, you are going to another website. Information you enter on these other websites is being collected by those websites, not Klutch. Their privacy policies may allow disclosures and uses of personal information that are not allowed by Klutch. We encourage you to read the privacy policies of these linked websites as they may differ from ours.

8. Your Choices About Your Personal Information

You may choose not to receive promotional emails from us by following the unsubscribe/opt-out instructions in those emails, but we may still send you non-promotional messages relating to information about our future products and operations such as updates to agreements and privacy notices.

If you are a California resident, you have certain rights over the information that we have about you. Starting January 1, 2020, you can: Access a copy of any personal information we have about you; Delete any personal information we have about you when we do not have legal or contractual obligations to keep the information; and Correct any personal information we have about you by contacting us as provided below.

To exercise your choices about your personal information, please contact us at privacy@Klutchcard.com or through the chat on our website. We will not discriminate against you for exercising any of your rights. 

You can delete your Klutch account by contacting us. When you delete your account, you will no longer be able to view your account or profile information, but we may continue to have access to your information for a period of time in order to comply with applicable legal or service obligations. 

9. Changes to This Privacy Policy

We may make updates to this Privacy Policy, and we encourage you to visit this site from time to time to be aware of and review any updates. We will notify you of material changes, changes that limit any of the rights you have related to how we process your personal information under this Privacy Policy, or that we are required to disclose by law via a prominent notice on our website or via email at least 30 days before the changes take effect.