Last updated: 10/25/2022

If you are reading this Privacy Policy (the “Policy”), that means you have created an account through the website (the “Site”) and/or the mobile app (the “App”, and collectively with the Site, the “Platform”) that Higo Inc. (“Higo”) makes available to power your banking needs or you are otherwise using Higo’s Mobile App and services under the Terms of Service. By using these services, signing an electronic signature card or opening a deposit account (“Account”) with us, you agree to this Policy.

We may update this Policy from time to time and we will provide updates as required by law. We may update this Policy from time to time and the continued use of our services means acceptance of this Policy. If you do not agree to the Policy as last revised, do not use (or continue to use) the Services (as defined below).

Synctera is our backend software provider, and partners with financial institutions to provide FDIC insurance. Synctera’s API, and their relationship with financial institutions, enables us to offer banking services and products. By agreeing to this Policy, you also agree to Synctera’s privacy policy found at: www.synctera.com/privacy-policy, as well as the privacy policy of our bank partner, Lineage Financial Network, Inc., (“Bank Partner”), found at: www.lineagebank.com/privacy/.

At Higo, we take our customers’ privacy and security very seriously as provided herein. To demonstrate our commitment to privacy and security, we have developed this Policy to explain how we may collect, retain, process, share, and transfer your information.
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1. Policy Overview
This Policy describes the types of personal information we collect, how we use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.

In this Policy, “Services” refers to any products, services, content, features, technologies, or functions made available to you by Higo as a technology service provider working with Synctera and its Bank Partner via the Mobile App.

The terms “Higo,” we”, “us” or “our” shall refer to Higo, Inc. The terms “you” or “your” shall refer to any individual or entity who accepts this Policy.
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‍2. Information We Obtain
‍‍We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with our member services representatives.  In addition, we may obtain information about you when you send or receive payments to or from one of our members.

The types of personal information we may obtain about you include:
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- Identifiers such as name, date of birth, postal and email address, and phone number;
- Government-issued photo ID, such as a driver’s license or passport;
- Login credentials for your Higo account;
- Financial information, including your account number from our Bank Partners, Higo account transaction history, information about your linked non-Higo accounts (such as transaction information and balances, payroll account information, etc.), and payment card information;
- Direct deposit status (whether you electronically deposit a portion of your regular paycheck or benefit payment above a minimum threshold);
- Information included on a tax return you provide;
- Employment information, including occupation, information about your employer, and income details (such as source of income, approximate annual income and how frequently you are paid);
- Physical characteristics, demographic information and similar details (such as sex, gender, race, color, marital or family status, citizenship status, signature, language preference and national origin) present in documents (e.g., IDs, tax returns) you provide;
- Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or services;
- Voice recordings (such as when you call Higo’s member services);
- Biometric information (such as a facial image collected for identity verification, if you use certain features of our App);
- Social media handles;
- Information you provide through member services interactions and that you provide about your experience with Higo, including via questionnaires, surveys, participation in user research or other feedback;
- Geolocation data;
- Information provided by marketers and other websites on which Higo advertises;
- Information you provide through contacts integration, including a list of contacts from your phone’s operating system; and
- Other information you choose to provide, such as through our “Contact Us” feature, emails or other communications (such as with member services), referrals, on social media pages, or in registrations and sign-up forms.

When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.

When you use our App, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, battery and signal strength, usage statistics, referring emails and web addresses, dates and times of usage, actions taken on the App, and other information regarding use of the App. In addition, as indicated above, we may collect your device’s geolocation information. Your device’s operating platform may provide you with a notification when the App attempts to collect your precise geolocation. Please note that if you decline to allow the App to collect your precise geolocation, you may not be able to use all of the App’s features or the offers available through the App.

We may use these automated technologies on our Platform to collect information about your equipment, browsing actions and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Platform and the use of the Services, including our online forms, tools or content; (3) tailor the Platform around your preferences; (4) measure the usability of our Services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Platform. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
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3. How We Use the Information We Obtain
‍We may use the personal information we obtain for purposes such as the following:
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- Provide the Services;
- Process and fulfill transactions;
- Establish and manage Higo accounts;
- Personalize your experience on our Platform;
- Facilitate direct deposits (including tax refunds and payroll) to your Higo account;
- Facilitate transfers between your external bank account and Higo accounts;
- Verify your identity and comply with our bank partners’ compliance with applicable law, including anti-money laundering (AML) and sanctions screening rules designed to prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services;
- Respond to inquiries, provide member support and resolve disputes;
- Determine your eligibility for, and administer your participation in, certain features of the Platform, including surveys, contests, sweepstakes, promotions and rewards;
- Facilitate and manage referrals from our business partners;
- Identify recipients for transfers;
- Advertise and market our Services, and send information about third-party products and services we think may interest you;
- Provide you targeted offers and notify you nearby third-party locations where you may use our Services;
- Provide member support and quality assurance, and conduct customer service training;
- Collect fees and other amounts owed in connection with your Higo account;
- Operate, evaluate and improve our business (including researching and developing new products and services; enhancing, improving, debugging and analyzing our products and services; managing our communications; establishing and managing our business relationships; and performing accounting, auditing and other internal functions);
- Maintain and enhance the safety and security of our products and services and prevent misuse;
- Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
- Exercise our rights and remedies and defend against legal claims; and
- Comply with and enforce applicable legal requirements, relevant industry standards and Higo policies.
- We also may use the information in other ways for which we provide specific notice at the time of collection.
- Diagnose and debug our technical systems.
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4. Third-Party Analytics Services
‍‍We may use third-party analytics on our Services. For example, we use Google Analytics to better understand how you interact with our Site. We also Google Maps to better understand how our Services are used. The information we obtain through our Services may be disclosed to or collected directly by these third parties. To learn more about Google Analytics and Google Maps, please visit https://www.google.com/policies/privacy/partners/.


‍5. Interest-Based Advertising
‍‍On our Services, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This section of our Privacy Policy provides details and explains how to exercise certain choices.

You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information ad services may collect includes data about your visits to websites that serve Higo advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Platform and on third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

The Platform is not designed to respond to “do not track” signals from browsers.To learn how to opt out of interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ and http://preferences-mgr.truste.com/.


6. Information We Share
‍We may share the information we obtain about you with our affiliates and subsidiaries; our Bank Partner; other Higo users (including in connection with member referrals); other companies in connection with co-branded products, services or programs; joint marketing partners; and consumer reporting agencies. We also may share the information we obtain about you with third-party vendors and other entities we engage to perform services on our behalf, such as payment and check deposit processors, risk detection  and mitigation tools, and modeling and analytics tools.

We also may disclose personal information (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise or defend our legal rights; (iv) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (v) in connection with an investigation of suspected or actual illegal activity or (vi) otherwise with your consent.

We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).


7. Your Rights & Choices
‍We offer you certain choices in connection with the personal information we collect from you.  To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the How To Contact Us section of this Policy. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you are a Higo member, you may update some of your account details and settings by logging into your account on our Platform or by emailing us at [email protected]
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8. How We Protect Personal Information
‍‍We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.


9. Children’s Privacy
‍Our Platform is designed for a general audience and is not directed to children.  In connection with the Services, we do not knowingly solicit or collect personal information from children under the age of 13 without parental consent.  If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the How To Contact Us section of this Policy.


10. Links to Third-Party Services and Features
‍For your convenience and information, our Platform may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Higo, we are not responsible for these third parties’ information practices. 

If you are a Higo member and elect to use the Plaid Technologies, Inc. (“Plaid”) feature in the Services, Plaid may collect your information from financial institutions.  By using the Plaid service, you acknowledge and agree that Plaid will collect and use your personal information in accordance with Plaid’s privacy policy, which is available at https://plaid.com/legal.


11. Updates to Our Privacy Policy
‍We may update and make changes to this Privacy Statement from time to time in light of, for example, changing business or information handling practices, technology, or legal requirements. When we make changes to this Privacy Statement, we will amend the “Last Revised” date at the top of this page, and such modified or amended version of this Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to review this Privacy Statement periodically to be informed about how we are protecting your information.


12. Security
‍We have in place reasonable organizational, technical, and administrative measures that are designed to protect data from loss, misuse, and unauthorized access, disclosure, alteration, destruction, and other forms of unlawful processing while it is under our control. However, please be aware that the storage and transfer of data cannot always be one-hundred percent secure. You also play a role in protecting your personal information. Please safeguard your username and password for your Platform’s account and do not share them with others. If we receive instructions using your Platform’s account log-in information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Platform’s account  or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Platform’s account , and to remove or edit content.


13. Retention period
We will retain data about you as long as necessary for the fulfillment of the purposes set out in this Privacy Statement, unless applicable law or professional obligations requires a longer retention period.

14. How to Contact Us
‍You can update your preferences, ask us to remove your information from our mailing lists, submit a request or ask us questions about this Privacy Policy by emailing us at [email protected] or contacting us via the in-app chat.   

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