May 31, 2022
Please Read Carefully
Under Technologies Inc., dba Rho Technologies, together with its affiliates (collectively "Rho", "we", "us", “our”) places a high priority on the privacy of individuals who visit our website, rho.co (“Site”) and/or who cause the businesses they represent to use our cloud-based hosted services (“you” or “User”) including our banking platform or any of our other websites, networks, applications, mobile applications, or other services provided by us (collectively, the "Rho Service").
When any of these activities occur, your Personal Information may be collected and processed by Rho. Rho takes steps to ensure that how we handle Personal Information is ethical and fair. This Policy is designed to explain how we collect, use, store, retain, disclosure by transmission, disseminate or otherwise make available (collectively “Process”) your Personal Information. Please be aware that the Rho Service is integrated with certain third parties (“Third Party Servicers”) including, but not limited to Webster Bank, N.A., Member FDIC (“Webster”). The privacy policies of these Third Party Servicers will govern their collection, use, disclosure and processing of your Personal Information.
Information We Collect.
You are not required by law to provide us with any Personal Information. However, our ability to provide all features on the Site and Rho Service to you may be conditioned on you voluntarily providing us with your Personal Information. This Personal Information may be sensitive in nature.
Personal Information may include your legal name, social security number, home and/or business address, other identifying information about who you are. In addition to collecting information about your own identity, we also collect certain information about transactions which you may be involved. We collect information about the Company. Such information includes but is not limited to the State where the Company is incorporated; documents related to the organization of the Company; financial information about the Company, including real-time financial accounting information provided to and by third parties and linked accounts; credit information about the Company; and any information related to the compliance and/or enforcement with respect to federal and state anti-money laundering and banking laws and regulations.
We use Third Party Servicers to access, process, and collect information about the Company’s financial and purchase activity. Any time you link an account, we may receive real-time data and information associated with the linked accounts including account names, transactions (and transaction history), account balances, bank routing numbers, and unique identifiers.
What Is Personal Information?
“Personal Information” is any information that can be used to identify you. It includes, but is not limited to, name, date of birth, home address, billing and shipping address, email address, photograph, government-issued identification information (such as driver’s license number, social security number or passport number), financial information (such as bank account details, payment card numbers, credit reports), authentication details, and IP address or other device information. Personal Information does not include information that does not identify a specific person.
Why We Collect Information.
The information we collect from you is reasonably necessary to provide you with the Services and products we offer. These Services or products may include but is not limited to banking services, credit services, investment advice and transaction opportunities.
We also collect information to customize offers to you, tailor our services or products for you, conduct marketing functions, maintain complete and accurate contact information and fulfill our legal obligations with respect to the Bank Secrecy Act, anti-money laundering and counterterrorism.
How We Collect Information.
One of the ways we collect information is directly from you. At the time of account opening, you are required to provide certain information about yourself and the business you are opening the Rho Account for.
We collect this information either (1) in person; (2) through documentation you provide to us; (3) telephone calls with you or Third Party Servicers; (4) e-mails with you or Third Party Servicers; (5) the access provided to you on our websites and/or applications; (6) research using Third Party Servicers and (6) ongoing communications with you or your business’ employees or associated persons. We may also collect your personal information from individuals who are listed as associated with the Rho Account which you are associated, public sources, yours or our advisor(s), introducers, referrers, brokers, credit reporting agencies, and other reporting organizations or exchanges that serve the financial services industries.
In other cases, it may be provided to Rho indirectly, such as the IP address of the computer or device you use to connect with us online or by a Third Party Servicer from whom you seek to obtain services or are obtaining services.
How We Use Your Information.
We use your information in a variety of ways. We use your information to: process applications and onboard you; manage our own products and services, including product and service testing and modeling; conduct a comprehensive risk analysis and risk report; communicate information about your Rho Account to Third Party Servicers and vendors; prevent or mitigate financial crimes such as fraud or anti-money-laundering; communicate information about any of your transactions; assess creditworthiness and evaluate whether you have the ability to make payments owed to us on time; and investigate inquiries or complaints.
We may also anonymize your data as part of and for our own processes and procedures for market research and new product development. To the extent permitted by law and without your express permission, we may also permit our Third Party Servicers or affiliates to use your Personal Information. We do not sell your personal data.
Disclosure Of Your Information.
At times, we may be required to disclose information about you to law enforcement authorities who are non-employees of Rho. We may share Personal Information and other information about you to law enforcement when reasonably necessary and when our Third Party Servicers who provide services in connection with our Services and products request the information to be share it and when it is required to comply with any legal, regulatory or compliance obligations.
We may also share your information in connection with the undertaking of a particular business initiative, including any business transactions between Rho and other companies. Such business initiative may include, but is not limited to a merger, acquisition and the management of our business operations or assets. International considerations: The Rho Service and the purposes for which your Personal Information is processed may cause your Personal Information to be processed and/or stored outside of the United States. Therefore, your Personal Information may be sent to other countries with data protection standards that differ from those of your home country.
By supplying your Personal Information to Rho either directly or indirectly, you consent to your information being transferred across international borders to Rho and its affiliates, Third Party Servicers, and agents. Vendors and other outside contractors we engage are subject to our contractual requirements for safeguarding Personal Information.
Rho strives to ensure that any information collected from you or gathered about you is complete, accurate and up to date. We take reasonable steps to ensure we meet this goal by, among other things, requesting information from you on an ongoing basis, conducting research through Third Party Services, research publicly available information and searching for media associated with you or the business which you are affiliated with.
At Rho, security is a priority. We use certain physical, organizational, and technical safeguards that are designed to protect Personal Information submitted to us, and we employ appropriate measures, including advanced technology, to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. These measures may include, among others, physical access security, administrative security measures, data encryption, firewalls, and other appropriate technologies. Rho reviews and enhances its security systems as necessary.
Notwithstanding Rho’s efforts, no security measure is perfect or impenetrable and no method of transmission over the internet or electronic storage is 100% secure. Therefore, Rho cannot guaranty complete security of the transmission or storage of your Personal Information. It is important that you maintain the security and control of your account credentials, and not share your password with anyone. We offer our Users two-factor authentication which is designed to protect their account. Please make use of this added protection.
Our Website and Online Services.
Cookies are small data files that are stored in your device memory or on your hard drive when you visit a website. Cookies may be used as a mechanism to recognize you, record behavior, and/or customize your experience with the Site. They can also be used to monitor Site activity, mitigate risk, measure the effectiveness of promotions and prevent potential fraud. If you choose to disable cookies, your use of the Site may be limited or otherwise affected. By using this Site, you permit us to collect and use your information related to Site access and device activity. You can learn more about cookies by visiting http://www.allaboutcookies.org.
By using the Site, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, location data, and information about your usage of the Rho Service.
Third Party Servicers.
We may use third party analytics vendors to evaluate and provide us with information about your use of the Site and/or the Rho Service. We may share limited information with these third parties. These analytics service providers may also set and access their own cookies, pixel tags and similar technologies on the Site and they may otherwise collect or have access to information about you which they may collect over time and across different websites. For example, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners.
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described more fully throughout this Policy, we limit our use and collection of your Personal Information.
For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the All About Do Not Track website: http://allaboutdnt.com.
Our Website May Be Linked To Other Websites.
We may use third party analytics vendors to evaluate and provide us with information about your use of the Site and/or the Rho Service. We do not share your information with these third parties, but theses analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Site and they may otherwise collect or have access to information about you which they may collect over time and across different websites. For example, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners.
The Site And Rho Service Are Not Directed At Persons Under The Age Of 13 Years Old.
The Rho Service are intended for business use only and is not directed at persons under the age of 13. If you are a parent or guardian and believe we may have collected information about a person under the age of 13, please contact us at the email address or phone number set out at the beginning of this Policy. If we determine that we have inadvertently collected Personal Information from a person under the age of 13, we will promptly delete such information from our records to the extent permitted by applicable law.
The "Last Updated" date at the top of this page indicates when this Policy was last revised. From time to time, Rho may make changes to this Policy, so we encourage you to check back and review it regularly to ensure you are aware of current practices. Changes will be communicated through the Website or through your Rho Service account. If the amendment or revision is required in order for Rho and the Rho Service to remain in compliance with applicable laws or regulations, then the amendment or revision shall take effect as of when it is posted to the Website or your Rho Service account. If, on the other hand, the amendment or revision is not required under law, and you do not close your Rho Service account within thirty (30) days of notice of the amendment or revision on the Website or in your account, then you shall be deemed to have accepted the amendment or revision. If you disagree with the changes, you must stop your use of the Rho Service and discontinue use of our Website. Your continued use of the Rho Service and/or the Website following the effective date of any change, constitutes your consent to any modification to this Policy.
If you have any questions about this Policy, or you want to make a complaint regarding any breach of your privacy by us, or you want to correct or update your Personal Information in our possession, you may contact us by email at firstname.lastname@example.org or call us at toll free (US) at 1 855-743-8746 or through the support page in the web application.