Privacy Policy

Updated: January 1, 2023

Privacy Policy

Welcome to Treasure

Treasure Technologies, Inc. respects your privacy and we have communicated in our Privacy Policy our methods to safely protect customer information.  

1. WHEN THIS PRIVACY STATEMENT APPLIES.

If a Service you're using links to this Privacy Statement, this Statement applies to you.

This Privacy Statement (“Statement”) applies to our sites, products, and services (collectively, "Services") that link to this Statement. Treasure Technologies Inc. is the responsible entity for all Personal Information subject to this Statement for our Services targeted to US customers.

2. WHAT WE DO WITH YOUR INFORMATION.

We want to be clear about what information we collect and how we use it to deliver our Services to you, operate our business, and help make our Services useful, more intelligent, and work better for you. We do not sell or share your Personal Information with third parties for their own commercial uses without your consent.

a) Types of Information We Collect. In connection with accessing our Services, we may collect information from you which can be used to identify you ("Personal Information"), such as your name, shipping/billing address, email address, phone, username and password.

We collect information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us feedback.  We may also get information from other companies or third parties, such as when you sync a third party account or service with your Treasure Technologies Service, or when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. Finally, we also collect content or other information that you may provide or create when you interact with our Services.

We may also automatically collect certain usage information when you access our Services ("Usage Data"), such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. For example, we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services.  We also collect IP addresses from users when they log into the Services as part of our log-in and security features.  We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data.  Our Services may change over time and we may introduce new features that may collect new or different types of information.

b) How We Use Your Information. We may use your information, including your Personal Information, for the following purposes:

Account Registration. We may use your name, address, phone number, and email address to register your Treasure Technologies Account for certain services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current.  If you set up an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information.

Communicate with You and Tell You About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that we think may be of use to you.

To Improve Services and Develop New Services. We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of Treasure Technologies' Services.

To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information.

Customer Service and Technical Support.  We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience. We also offer various Internet chat services, for example, to speak with a Treasure Technologies support representative or tax advisor.  Internet Chat transmissions are encrypted but you should not supply more Personal Information, including tax data, that is required to address your specific issue.  A transcript of the session is retained to resolve questions or issues related to our Services.

Feedback. We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them.  Answering any survey is optional.

Research, Including Publishing or Sharing Combined Information from Many Users, But Only in a Way that Would Not Allow You or Any Other Person to beIdentified. Only in a way that would not allow you or any other person to be identified, we may prepare and share information about our customers with third parties, such as advertisers or partners, for research, academic, marketing and/or promotional purposes.  For example, we may share demographic data that describes the percentage of our customers who use mobile services or who use a particular operating system. We or our third-party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.  (Do these third parties/partners/etc. have controls/policies in place?

c) How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others.

Third Party Service Providers. We may share your information, including Personal Information and Usage Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they're providing to us or on our behalf.

Response to Subpoenas and Other Legal Requests.  We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

Protection of Treasure Technologies and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products' Terms of Service and other agreements; or protect the rights, property, or safety of Treasure Technologies, our Services, our users, or others.  This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.  This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Statement.  

Reporting to Information.  We may share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

Information Sharing Between Treasure Technologies Entities. We share your information, including your Personal Information, with and among our affiliates and subsidiaries, except where prohibited by law.  The protections provided in this Privacy Statement apply across all Treasure Technologies entities. Affiliates and subsidiaries means companies related by common ownership or control. The reasons why we share your information include for our everyday business purposes, such as to: process your transactions, maintain your accounts, operate our business, etc. We will also share your information in order for us to be able to offer our products and services to you. We may also share information about your creditworthiness, your transactions and experience so that we can operate our business effectively, detect and prevent fraud, and improve our Services.  Do these affiliates, subs have controls/policies in place?

Sale of Our Business.  If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.

With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.

d) Syncing, Linking, Connecting Your Bank Account or Other Third Party Services with Your Treasure Technologies Service.

You may choose to sync certain Treasure Technologies Services with information from other financial accounts.  To sync your financial account information, we must access your online account with your financial institution.  We will request your user name, password, and any other login bank data that you have set up with your financial institution to enable access.  We use this information to update and maintain the account information you download, to assist with the download process, and to enhance the Services we may provide in the future.

We work with other companies or developers to offer you products and services and you may choose to sync, link or connect other third party services with your Treasure Technologies Service.  Sometimes Treasure Technologies may let you know about the service or product, or another company may let you know about a Treasure Technologies service or product.  It will be clear who is referring the service or product, and who is providing the service or product.  If you choose to accept these services, providing your consent to either the third party or to us, we may exchange your information, including your Personal Information, as well as information about how you interact with each company's service or product.  This exchange of information is necessary to maintain business operations and to provide the ongoing service you've requested.  By requesting or accepting these products or services, you are permitting us to provide your information, including your Personal Information, to the other party.

3. WHAT YOU CAN DO TO MANAGE YOUR PRIVACY.

You can view and edit information that identifies you online through your Treasure Technologies Service. How you can access and control information that identifies you will depend on which Services you use. You have a choice about the use of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies.

a) Managing Marketing Communications from Us. We will honor your choices when it comes to receiving marketing communications from us.

You have the following choices if you have been receiving marketing communications from us that you no longer wish to receive:

  • Click the "unsubscribe" link in the email or newsletter you received.
  • Adjust your preferences in your Treasure Technologies account settings.
  • For SMS messages, reply "STOP" or follow the instructions in the message or settings to discontinue the Service.
  • Subject to your control, our mobile applications may send push notifications to your mobile device.  If you are receiving push notifications and no longer wish to receive these types of communications, you may turn them off at the device level.
  • Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.

b) Updating Your Personal Information. In connection with your right to manage your Personal Information you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the "Contact Us" section of this statement.

c) Cookies and Similar Tracking Technologies. The following is a high-level summary of our practices and your controls for cookies and other tracking technologies.  For more information, please see our Cookies Policy.

In accordance with applicable law, Treasure Technologies and our service providers may use commonly-used tools to recognize your visit and track your interactions with our Services such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, "Cookies").  Sometimes this tracking is necessary in order for us to provide you the Service you requested. Other times, we combine Usage Data collected from Cookies with that of other customers to improve your and other customers' experience.  You have control over some of the Usage Data we collect from Cookies and how we use it.  Information on changing your browser settings to opt out of Cookies can be found in your browser settings.

In accordance with the Digital Advertising Alliance Principles (Who is this entity?) , Treasure Technologies also uses advertising networks and other third parties to display advertising on our website or to manage our advertising on other sites.  Our third-party partners may place Cookies on our Services and unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests, and to determine the effectiveness of such advertisements.  If you wish to opt out of interest-based advertising, click here.

You also have the following additional choices to opt-out of certain tracking through Cookies for such purposes:

  • Clicking here to opt out of targeted ads on Facebook.
  • Clicking here to opt out of Google Analytics for display advertising or to customize Google Display Network ads.

Please note that even if you opt-out of such Cookies or otherwise opt-out of interest based advertising, you will still receive advertisements, they just won't be tailored to your interests.  Also, if you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.

d) Do Not Track. Like most other companies, our Services are not currently configured to respond to browsers' "Do Not Track" signals because at this time no formal "Do Not Track" standard has been adopted.

e) Social Media Features. Our Services may use social media features, such as Facebook sharing ("Social Media Features").  These features may collect your IP address and which page you are visiting within our Service, and may set a cookie to enable the feature to function properly.  Social Media Features are either hosted by a third party or hosted directly on our Services.  Your interactions with these features are governed by the privacy statement of the company providing the relevant Social Media Features.

4. DATA RETENTION AND YOUR ACCESS RIGHTS

a) Data Retention. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business.  When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications.  We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones.  We will retain and use your information as required by applicable regulations and Treasure Technologies' records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

b) Your Access Rights. If you have created an online account with us and would like to update the Personal Information you have provided to us, you can access your account to view and make changes or corrections to your Personal Information.

5. SECURITY OF YOUR INFORMATION.

Keeping your Information safe is important to us.

We provide reasonable and appropriate security measures in connection with securing Personal Information we collect.

For example, we:

  • Constantly work to update our security practices to implement accepted best methods to protect your Personal Information and review our security procedures carefully.
  • Comply with applicable laws and security standards.
  • Securely transmit your sensitive Personal Information.
  • Train our staff and require them to safeguard your data.
  • Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry's Data Security Standards.
  • All traffic runs over SSL to prevent third parties from eaves dropping on user’s connection
  • All data is stored using bank level AES-256 encryption.
  • Two Factor Authentication method to confirm customer’s identity
  • Treasure uses Plaid Technologies, Inc., to serve as a Third-Party Admin. To view their data protection practices click on the attached link: Plaid's Privacy Policy [SS1].
  • Identity Verification.
  • During registration of a new customer’s account, customer agrees to provide us with the information we request for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime and permit us to keep a record of such information.
  • Customer will need to complete certain verification procedures before permitted to use the Treasure Services. Access to one or more Treasure Services and the limits that apply to use of Treasure Services, may be altered as a result of information collected about customer on an ongoing basis.
  • The information we request may include certain personal & business information, including, but not limited to, customer’s name, address, telephone number, e-mail address, date of birth, employer or taxpayer identification number, a valid government identification, and information regarding customer’s bank account (such as the name of the bank, the account type, routing number, and account number). In providing us with this or any other information that may be required, customer confirms that the information is accurate and authentic.
  • Customer agrees to keep Treasure updated on any of the information that changes. Customer in addition authorizes Treasure to make inquiries, whether directly or through third parties that we consider necessary to verify customer identity [SS2] [GE3] [GE4] against fraud or other financial crime and to take action we reasonably deem necessary based on the results of such inquiries.
  • When we carry out these inquiries, customer acknowledges and agrees that their personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full.
  • This is an identity check only and should have no adverse effect on your credit rating.

6. INTERNATIONAL DATA TRANSFERS.

In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to wherever we or our third-party service providers operate.  

7. CHANGES TO OUR PRIVACY STATEMENTS.

From time to time we may change or update our Privacy Statements.  We reserve the right to make changes or updates at any time.  More information about how we will notify you is below.

If we make material changes to the way we process your Personal Information, we will provide you notice via our Service or by other communication channels, such as by email or community post. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you may close your account(s). All changes are effective immediately upon posting and your use of our Service after a notice of material change or posting of an updated Privacy Statement shall constitute your consent to all changes.

8. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION.

We do not knowingly collect information from minors.

Treasure Technologies Services are intended for and directed to adults.  Our Services are not directed to minors and we do not knowingly collect Personal Information from minors.

9. YOUR CALIFORNIA PRIVACY RIGHTS.

We do not share your Personal Information with third parties for their marketing purposes without your consent.

10.  CONTACT US

If you have questions or complaints regarding our Privacy Statement or practices, please contact us at info@treasure.tech, we want your feedback and comments and look forward to connecting with you.

Treasure Technologies Inc.
447 Sutter St
STE 405 PMB 25
San Francisco, CA 94108
* Returns are projected based on current performance and are gross of fees. Treasure's fee is 35 basis points on Assets Under Management. There is no fee for Treasure Cash. Returns are subject to change daily.

** Treasure Cash accounts are held at Grasshopper Bank, N.A., our FDIC partner bank. Return differentials based on national average checking account rates as of 5/24/2023. Source: FDIC

Website is operated by Treasure Investment Management, LLC ("Treasure"), a wholly-owned subsidiary of Treasure Technologies, Inc., and an investment adviser registered with the U.S. Securities and Exchange Commission ("SEC"). Brokerage services are provided to clients of Treasure by Apex Clearing Corporation ("Apex"), an SEC-registered broker-dealer and member FINRA.

Investing involves risk, including loss of principal. The contents of this website are provided for information purposes only and do not constitute an offer to sell or a solicitation to buy securities. Past performance is no guarantee of future returns.