Astra’s Privacy Policy

Last updated: May 8, 2018

Privacy Policy

Astra, Inc. is committed to protecting and respecting your privacy. We understand that keeping your financial and personal information secure and confidential is critical to earning and keeping your trust. It is important that you know that your trust is paramount to us.

This Privacy Policy describes the specific policies and procedures we use to collect, use, disclose, and share with others information we collect from you and about you through our website located at www.astra.finance or through our web-based or mobile applications (collectively, the “Site”) and any related services. We take these policies and procedures seriously.

By accessing or using the Site, you agree to be bound by the terms and conditions of this Privacy Policy and Astra’s Terms of Service (into which this Privacy Policy is incorporated by reference), as they may be amended from time to time in the future.

Information We Collect

To offer these services, we use information you provide to us, information that we collect automatically when you use or access the Site, or that we collect from you and your financial accounts as you use our Site.

Information you provide to us

To access our services through the Site, you are required to sign up for an account. When you sign up for an account, we may ask you to provide us with personal information about you, like your name, e-mail address, mobile phone number, or an avatar for your account.

During the account setup, you will be asked to provide certain information about you from third-party financial institutions or third-party payments providers with which you have a legally binding customer relationship (each, a “Third-Party Financial Institution”). To enable us to access your financial data with Third-Party Financial Institutions, you will need to provide (as applicable): the name of the Third-Party Financial Institution, the username or email associated with that institution, the password for your financial account, and other similar information. We collect this information to establish a connection with your financial accounts and gain access to information and data we need to provide you with the services you request, including your bank account and routing number with that institution. We do not store your bank account and routing number in our systems.

We may also be required to verify your identity to comply with certain obligations and laws. In such an event, we will ask you to provide us with information like your name, date of birth, your social security number, images of your government-issued identification, and mailing address. With the exception of your name and mailing address (which we will use and store in accordance with this Privacy Policy), we will not store the other information you provide in such an event after it has been used for these purposes.

Information we collect from your use of our Site or App

In addition to the information you provided when creating your account, we may collect information from you during your use of the Site a. For instance, we may collect information from you about the device you use to access the Site, what operating system or internet browsing software you use for that access, and your IP address. We also may collect information about how you use our Site, including what links you may click on or whether you have visited our Site in the past and when.

When you authorize us to access information from your financial accounts with Third-Party Financial Institutions, we may also collect information about those accounts, including the balance of those accounts, what type of institution is holding the account, and what type of account is involved (i.e., checking or savings and credit or depository). We also collect information about the transactions that have taken place with that financial account, including, but not limited to, the amount of the transaction, where the transaction took place, and the time of the transaction.

Cookies and Google Analytics

We and our partners may use various technologies to collect and store information when you visit our Site. This technology may include the use of cookies or similar technology. We use these cookies and similar technology through Google Analytics to better your experience with our Site. Google Analytics is a web analysis service provided by Google. Google utilizes the data collected from our Site, through cookies and similar technology, to track and examine the use of the Site, to prepare reports on these activities and share them with us. We use these cookies and the Google Analytics information to improve the delivery and performance of our Site by:

  • better understanding how you use our Site;
  • detecting and defending against fraud and other security risks; and
  • better presenting advertisements, products, and/or services of interest to you.

To learn more about how Google Analytics collects and processes data, please visit “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/.

How We Use the Information We Collect

We use the information we collect for a variety of purposes, including:

  • Providing the Site and all related services to you
  • Improving the Site and all related services, as well as to research and develop new services, determine customer demand for new or improved services, and specifically tailoring or customizing our services for you and other customers
  • Communicating with you regarding your account, changes to the Site or services we provide, and promotional material about new services or products we may be offering
  • Responding to requests or inquiries from you
  • Providing customer support or technical assistance
  • Creating or administering your account, including identifying you with your account
  • Billing you, as applicable
  • Maintaining the Site, including by ensuring compatibility with software and hardware you or our customers typically use.
  • Securing the Site and our systems and networks, and protecting your information and data
  • Sharing or disclosing to others in accordance with this Privacy Policy

In addition to the above, we may use information about your transactions (including their amount, where they take place, and when they occurred) (“Transaction Information”) to provide you with summaries, reports, or trends regarding your spending, including information on the categories or frequency of purchases. We may use your Transaction Information to help show you trends in your spending, to predict future spending, or to highlight opportunities for savings. We may use Transaction Information to highlight unusual spending trends – like spending associated with a business trips/vacation or major purchases – to improve your record keeping and budgeting. And we may use your Transaction Information to show you the way such transactions may have affected your financial goals.

Information We Share with Others

We do not share your personal or financial information with companies, organizations, or individuals outside of Astra with the following exceptions.

Plaid – As part of providing you with the Site and related services concerning your financial accounts, we work with a partner, Plaid Technologies, Inc. (“Plaid”), who is also authorized to access financial accounts. We use Plaid to gather your data from financial institutions. By using our service, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal). We give Plaid the following information about your financial accounts that you provided during account setup:

  • name of the financial institution where your account is held
  • your username
  • your email address
  • password for that financial account

Plaid receives this information and establishes a connection to those financial accounts. Once the connection is established, we delete the financial account information from our system.

Dwolla – As indicated in our Terms of Service, we also work with Dwolla to provide an account for your use through the Site. You agree to your personal and financial information being transferred to Dwolla, and being stored and processed by Dwolla in accordance with the Dwolla Terms of Service and the Dwolla Privacy Policy. Please refer to those documents for more complete information about how Dwolla collects, uses, and discloses information about you.

Google Analytics – As indicated above, we also provide information regarding your use of our Site or App, or clicks on links to other sites on our Site, to Google Analytics. Though the information we provide can be used to understand how you use our Site, the information cannot be used to identify you.

We may also share personal or financial information with others if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

  • meet any applicable law, regulation, legal process or enforceable governmental request
  • enforce applicable Terms of Service, including the investigation of potential violations
  • detect, prevent, or otherwise address fraud, security or technical issues
  • protect against harm to the rights, property, or safety of Astra, our users, or the public as required or permitted by law

And, we may provide access to your information to third-party vendors who may be assisting us with the operation, maintenance, or security of our Site.

Essential Service Providers – We also share information with essential third party service providers as necessary to provide the Site and the services to you. For example, we use Google Cloud Platform (GCP) as a cloud server provider, and as such we necessarily share information with GCP. Information shared with such essential service providers is strictly limited to the purposes of providing the Site and the services to you.

As Required By Law – In certain circumstances, we may share information as necessary and appropriate under applicable laws (including outside your country of residence) to comply with legal process or requirements, including notification obligations; respond to requests from public and government authorities or regulators (including those outside your country of residence); enforce our contractual rights and comply with our contractual agreements; and to protect the rights, privacy, safety, or property of you, Astra, and others.

Information You Share with Others

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.  Please check these policies before you submit any personal data to these websites.

Your Options

We attempt to provide you with accurate information about your financial accounts. To do so, we need accurate information from you about yourself and those accounts. If you find that information we have about you is outdated, missing, or incorrect, we would ask that you notify us at help@astra.finance of these errors so that they can be addressed. We may ask you to verify your identity before we act on any request to change your information. We may also reject requests that are unreasonably repetitive, require extraordinary or disproportionate technical effort or cost, risk the privacy or security of others, or would be extremely impractical.

Reviewing and Updating your Personally Identifiable Information

You can view and update your profile and account information by signing into your Astra Account. Once signed in, you can select the “Profile” option under the menu to edit any of your personally identifiable information.

Retention Period

We will retain information we collect about you for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by applicable law.

How to Request the Deletion of Personal Information We Collect

You may request your account be deleted by our support department by emailing help@astra.finance from the email address associated with your account, indicating “CANCEL” in the subject line of the message. After confirming you are the account owner we will remove personal information from our records and will only continue to retain such information as required by law.

California Do Not Track Disclosures

Do Not Track. Astra does not track its users over time and across third-party websites and therefore we do not respond to Do Not Track signals.

Security

We are committed to protecting Astra and our users from unauthorized access to, or unauthorized alteration, disclosure, or destruction of, information we may possess. To provide for the security of information in our possession, we may:

  • encrypt information in our possession
  • offer or require multi-step authentication when you access your account
  • review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access
  • restrict access to personal or financial information to Astra employees, contractors, partners, or agents who need to know that information in order to process it for us and are subject to confidentiality obligations

Updates and Changes

We may revise this Privacy Policy from time to time in our sole discretion. In the event of a material change, we will post the updated Privacy Policy on this page and update the date at the top of this page. Your use of the Site following these changes means that you accept the revised Privacy Policy. If you do not wish to accept the revised Privacy Policy, your sole recourse is to terminate your account.

Questions About Our Privacy Practices

Questions about our Privacy Policy or our privacy practices can be sent to help@astra.finance.

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