Last Updated: 1/1/2022
This privacy policy (“Policy”) describes how Anchor US LLC and its affiliates (“Company,” “our,” “we,” or
“us”) collect, store, use and share your personal information whenever you access or use our products,
website, services, features and technologies, including our mobile application (collectively, the
“Services”). This Policy also applies to any of our other websites that post this Policy. This Policy does not
apply to websites that post different statements. Please read this Policy carefully.
Your use of our Services is at all times subject to our Terms of Service, which incorporates this Policy.
If you have a consumer financial product or service with us, we will use and share any nonpublic personal
information that we collect from or about you in accordance with our consumer privacy notice (see below),
which offers you certain choices with respect to the collection, use, sharing, and processing of your
nonpublic personal information by financial institutions.
This Policy covers how we treat “personal information” that we receive or gather when you access or use
our Services. “Personal information” means any information that identifies or relates to you or your use of
the services, unless such information is publicly known (excluding personal information that identifies or
relates to a natural person). We may create aggregated, de-identified or anonymized data from the
personal information we collect, including by removing information that makes the data personally
identifiable to a particular person. We may use such aggregated, de-identified or anonymized data and
share it with third parties for our lawful business purposes, including to analyze, build and improve the
Services and promote our business, provided that we will not share such data in a manner that could
identify you. Such aggregated, de-identified or anonymized data is not considered personal information.
PERSONAL INFORMATION WE COLLECT
From the first moment you interact with us, we are collecting personal information about you. Sometimes
we collect personal information automatically when you interact with our services and sometimes we
collect the personal information directly from you. At times, we may collect personal information about you
from other sources and third parties, even before our first direct interaction. We get information about you
in a range of ways. We may collect, receive, and develop several categories of personal information:
• account registration information, such as your name, email, postal address, username and
password, telephone number and preferences when using our Services. !
• Information about your personal characteristics, such as your full name, age, phone and/or
cell number, date of birth, nationality, gender, signature, utility bills, citizenship, disability, military
status, and photographs. !
• government-issued identification, such as your social security number or equivalent, driver’s
license number, taxpayer identification number, and passport number. !
• transaction information, such as securities and crypto-currency trading activity, account
withdrawals and account balances. !
• institutional information, if you are a business, information such as your company’s legal name,
employer identification number (or comparable number issued by a government), information on
beneficial owners and proof of legal formation (e.g., articles of incorporation). !
• financial information, such as your bank account information, including account and routing
numbers, tax information; credit and debit card information, credit history, and credit scores. !
• employment-related information, such as your job title and salary information. !
• other information you may provide, such as information you provide when you contact us with
questions, feedback, survey responses, participation in contests, promotions or other prospective
seller marketing forms or devices, suggestions for improvements of our services or products,
referrals, or otherwise communicate with us. !
• internet activity information, such as your IP address, geolocation data, unique device ID,
browser type and language, operating system, information about how you interact with our
Services, including your access time, “log-in” and “log-out” information, browser type and
language, and information collected via cookies and similar technologies (described below),
including pages visited on our website, referring and exit pages, and the dates and times of the
visits. !
• personal information you affirmatively disclose to us in connection with your interactions with
us, including through your use of our Services. !
Some of the categories of data listed above, such as financial data, may be regulated by other federal
and state laws and regulations, such as the Gramm-Leach-Bliley Act (the “GLBA Act”). To the extent such
data is subject to the GLBA Act, please refer to our consumer privacy notice below. !
HOW WE COLLECT PERSONAL INFORMATION !
We collect and obtain the personal information set forth in this Policy from the following categories of
sources: !
• From you. We collect information that you provide to us. Such information includes, but is not
limited to, the categories identified above, as well as any other information you provide to us.!
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• From other sources. We also obtain personal information from other sources, which we often
combine with personal information we collect either automatically or directly from you. In addition
to the personal information described above, we also collect the following personal information
from third party sources: !
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o Public databases and ID verification partners. We obtain information about you from
public databases and ID verification partners to verify your identity in accordance with
applicable law (e.g., anti-money laundering laws). !
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o Credit, compliance, and fraud information. We also obtain information about you from
third party sources, such as credit report information, identity verification information,
fraud detection processes, where relevant collection procedures, and information about
any person or corporation with whom you have had, currently have, or may have a
financial relationship. !
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o Blockchain data. We may analyze public blockchain data and obtain information about
your transactions from blockchain analysis providers to ensure parties utilizing our
Services are not engaged in illegal or prohibited activity under our Terms of Service, and
to analyze transaction trends for research and development purposes. !
!
o Data append services and joint marketing partners. We receive personal information from
these sources so that we can better understand which of our Services may be of interest
to you. !
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o Electronic, visual, or similar information. We will also collect data in connection with your
interactions with our customer service team, as well as any photo IDs and profile pictures
you provide, i.e., on a driver’s license or passport. External bank account information
providers. When you use certain Services, we may collect from you, e.g., usernames,
passwords, account numbers, and other account information for third-party websites and
Internet banking services. This information is used to obtain your account, transaction,
and other banking information from the relevant financial institution on your behalf in
order to display the information to you or to fulfill your requests for certain products,
services, or transactions through a Service. By using our Service, you agree to abide by
the terms of service of Plaid Inc. (“Plaid”), available here [https://plaid.com/legal/], and
agrees to the privacy policy of Plaid, available here [https://plaid.com/legal/]. You
represent and warrant that you are the owner of any linked account and are authorized to
disclose any information related to such account to us for our use. !
!
• From your device. We, and our third-party partners, may use various technologies that
automatically record certain technical information from your browser or device when you visit our
website, read our e-mails, access or use our Services, or otherwise engage with us. We typically
collect this information through a variety of tracking technologies, including cookies, web
beacons, embedded scripts, location-identifying technologies, file information, and similar
technology (collectively, “tracking technologies”). !
We, and our third-party partners, use tracking technologies to automatically collect usage and
device information, such as: !
o Information about your device and its software, such as your IP address, browser type,
Internet service provider, device type/model/manufacturer, operating system, date and
time stamp, and a unique ID that allows us to uniquely identify your browser or your
account (including, for example, a persistent device identifier or an Ad ID), and other
such information. We may also work with third-party partners to employ technologies,
including the application of statistical modeling tools, which permit us to recognize and
contact you across multiple devices. !
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o When you access our Services from a mobile device, we may collect unique identification
numbers associated with your device or our mobile application (including, for example, a
UDID, Unique ID for Advertisers (“IDFA”), or Google AdID), mobile carrier, device type,
model and manufacturer, mobile device operating system brand and model, phone
number, and depending on your mobile device settings, your geographical location data,
including GPS coordinates (e.g., latitude and/or longitude) or similar information
regarding the location of your mobile device, or we may be able to approximate a
device’s location by analyzing other information, like an IP address. !
o Information about the way you access and use our services, for example, the website
from which you came and the website to which you are going when you leave our
services, the pages you visit, the links you click, whether you open emails or click the
links contained in emails, whether you access the services from multiple devices, and
other actions you take on the Services. !
o We may collect analytics data or use third-party analytics tools such as Google Analytics
to help us measure traffic and usage trends for the services and to understand more
about the demographics of our users. You can learn more about Google’s practices at
https://policies.google.com/technologies/partner-Websites and view its opt-out options at
https://tools.google.com/dlpage/gaoptout. !
We use the data collected through tracking technologies to: (a) remember information so that
you will not have to re-enter it during your visit or the next time you visit or use the Services;
(b) provide custom, personalized content and information, including targeted content and
advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness
of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage,
and demographic patterns on our Services; (f) diagnose or fix technology problems; and (g)
otherwise to plan for and enhance our services. !
USE OF PERSONAL INFORMATION
We may use your personal information in the following ways:
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• To provide you with our Services. We use your personal information to provide you with our
Services. !
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• To improve our Services and run our Services. We may use personal information to research,
analyze, and understand how users access and use our Services, both on an aggregated and
individualized basis, in order to help us improve our Services and develop new products. We also
use personal information to operate, maintain, test, improve (including developing new products
and services), enhance, update, monitor, diagnose, fix, and improve our Services.!
• To correspond with you. We use personal information to provide you with customer support
anytime you reach out to us with questions or issues arising from your account. We also use
personal information to send customers technical alerts, updates, security notifications, and
administrative communications. !
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• Personalize your experience. When you use our services and sites, as well other third-party sites
and services. In this case, we might use tracking technologies like cookies. !
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• For marketing purposes. We may use your personal information to communicate with you
regarding certain products, services or promotions offered by us or certain third-party products
and services we believe you may be interested in, provided that you have not already opted out
of receiving such communications. !
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• Send you locally relevant options. We can only do this if you agree to let us track your location. If
you do, this can help us enhance the security of our sites and services, and customize our
services by sending your relevant coupons and otherwise personalizing content for you (e.g.,
through appropriate ads and search results). !
• Make it easy for you to find and connect with others. For example, if you let us access your
contacts, we can suggest connections with people you may know. !
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• To detect, investigate, and prevent fraud and security issues. We use your personal information
as necessary to protect our company, our customers, and our business partners, including by
investigating and preventing fraudulent activities, unauthorized access to the Services, and other
illegal activities. !
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• Comply with laws and regulations. We use your personal information as we believe necessary or
appropriate to comply with applicable laws, lawful requests, and legal processes, such as to
comply with anti-money laundering laws, to report to credit bureaus, and to respond to subpoenas
or requests from government authorities. !
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• Prevent, investigate, or provide notice of fraud or unlawful or criminal activity, and enforce and
carry out contracts and agreements between us and you. !
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• We may also use personal information for any other purposes disclosed to you at the time your
information is collected or pursuant to your consent. !
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SHARING OF PERSONAL INFORMATION !
We do not “sell” personal information as most people would typically understand that term. However, we
may share your personal information across our services We share your personal information with: !
• Service providers. We share your personal information with service providers that we have
engaged to perform services on our behalf. This includes service providers that: conduct research
and analytics; create content; provide customer, technical or operational support; conduct or
support marketing (such as email or advertising platforms); host the Services; maintain
databases; send or support online or mobile advertising; allow you to conduct transactions in
connection with the Services; and otherwise support or help us provide the Services. Service
providers also include payment processors, payment networks, securities exchanges, external
bank account information provider, broker-dealers, providers of identity services, risk investigation
and mitigation service providers, hosting, technology and communication providers, security and
fraud prevention consultants, risk investigation and mitigation service providers, support and
customer service vendors and product fulfillment and delivery providers. !
!
• Affiliates, investors, and business partners. We share your personal information with our affiliates,
investors, and business partners, subject to the terms of this Policy or otherwise as we disclose to
you at the time the data is collected. !
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• Law enforcement agencies, governmental authorities, or regulators. We will share your personal
information when we believe it is appropriate to comply with the law, enforce or apply our
conditions of use and other agreements, or protect the rights, property, or safety of the Services,
our users, or others. !
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• Mergers, acquisitions, and business transfers. We will share your personal information if we are
acquired by or enter into a merger with another company, or otherwise reorganize our business. !
!
• Credit bureaus and collection agencies. Depending on circumstances, we may share your
personal information with credit bureaus and collection agencies, as permitted by law. !
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• Third parties. We may also share your personal information with third parties with your consent or
at your direction or for any legitimate business purpose not otherwise prohibited by law. !
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We may also share personal information for other reasons we may describe to you from time to time
as permitted by law. We may also share your personal information: (i) in an emergency, to protect the
health and safety of users of our Services or the general public; (ii) to respond to claims that any
posting or other content violates the rights of third parties; and (iii) in order to investigate, prevent,
defend against, or take other action regarding violations of our terms of service governing the
Services, illegal activities, suspected fraud, or situations involving potential threats to the legal rights
or physical safety of any person or the security of our network or Services. !
SERVICES NOT FOR CHILDREN !
Children’s safety is important to us, and we encourage parents and guardians to take an active
interest in the online activities of their children. Our Services are not directed to, and we do not intend
to, or knowingly, collect or solicit personal information from children under the age of 18. If you are
under the age of 18, please do not use our Services or otherwise provide us with any personal
information either directly or by other means. If a child under the age of 18 has provided personal
information to us, we encourage the child’s parent or guardian to contact us to request that we
remove the personal information from our systems. If we learn that any personal information, we
collect has been provided by a child under the age of 18, we will promptly delete that personal
information !
INTERNATIONAL VISITORS !
Our Services are hosted in the United States and is generally intended for United States visitors. If
you visit from the European Union or other regions with laws governing data collection and use that
may differ from U.S. law, please be aware that you are transferring personal information to the United
States. The United States does not have the same data protection laws as the European Union and
some other regions. By providing personal information to us, you consent to the transfer of it to the
United States and the use of it in accordance with this policy. !
SECURITY !
We care about the security of your information and employ certain safeguards designed to preserve
the integrity and security of personal information collected through our Services. However, no security
system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that
any information under our control is compromised as a result of a breach of security, we will take
reasonable steps to investigate the situation and, where appropriate and required by law, notify those
individuals whose information may have been compromised and take other steps, in accordance with
any applicable laws and regulations. !
INFORMATION CHOICES
You have certain choices about how we use your personal information, including with respect to. !
• Marketing communications. We may send you emails regarding the Services. If you do not want
to receive promotional emails, you can click the unsubscribe link in any marketing email from us
or contact us at support@tryanchor.com and let us know. However, there may be certain
administrative emails that you will have to continue to receive in order to use the Services. !
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• Cookies. You also have choices with respect to the following types of cookies that we use on our
website: !
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o Strictly necessary cookies. These are cookies that are required for the operation of our
website. They include, for example, cookies that enable you to log into secure areas of
our website. This category of cookies cannot be disabled. !
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o Analytical cookies. These cookies allow us to recognize and count the number of visitors
and to see how visitors move around our website when they are using it. This helps us to
improve the way our website works, for example, by ensuring that users are finding what
they are looking for easily. !
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In the U.S., you can opt out of tracking on our website by visiting the Digital Advertising Alliance’s
Consumer Choice page at http://www.aboutads.info/choices/ or the Network Advertising Initiative’s page
at http://www.networkadvertising.org/choices/.
You may also disable cookies by activating the setting on your browser that allows you to refuse the
setting of all or some cookies. However, if you use your browser settings to disable all cookies (including
strictly necessary cookies) you may not be able to access all or parts of our website.
Disabling a cookie or category of cookie does not delete the cookie from your browser. You will need to
do this separately within your browser. If you have disabled one or more analytical cookies, we may still
use information collected from cookies prior to your disabled preference being set.
When we collect tracking information on our website, we do not respond to users’ Do Not Track settings
in browsers. However, you may choose to decline cookies in your browser settings on a desktop
computer, or by declining tracking in your settings on a mobile device.
THIRD PARTY SERVICES
Our Services may include links to third-party services, websites, plug-ins and applications. Except where
we post, link to or expressly adopt or refer to this Policy, this Policy does not apply to, and we are not
responsible for, any personal information practices of third-party websites and online services or the
practices of other third parties. To learn about the personal information practices of third parties, please
visit their respective policies.
CONTACT INFORMATION
We welcome your comments or questions about this privacy policy. You may contact us at
legal@tryanchor.com.
CHANGES TO THIS PRIVACY POLICY
We may occasionally update this policy. When we do, we will also revise the "last updated" date at the
beginning of the policy. Your continued use of any of the Services after such changes will be subject to
the then-current policy. We encourage you to periodically review this policy to stay informed about how
we collect, use, and disclose personal information.
Consumer Privacy Notice
Last Updated: April 26, 2021
FACTS
WHAT DOES ANCHOR US AND ITS AFFILIATES DO WITH YOUR PERSONAL
INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires us to tell you
how we collect, share, and protect your personal information. Please read this notice
carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or service
you have with us. This information can include:
■ Social Security number and account transactions
■ payment history and transaction history
■ account transactions and income
How?
All financial companies need to share members’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their customers’
personal information; the reasons we choose to share; and whether you can limit this sharing.
Reasons we can share your personal
information
Does Anchor US share?
Can you limit this
sharing?
For our everyday business purposes – such as to
process your transactions, maintain your
account(s), respond to court orders and legal
investigations, or report to credit bureaus
YES
NO
For our marketing purposes – to offer our
products and services to you
YES
NO
For joint marketing with other financial
companies
NO
NO
For our affiliates’ everyday business purposes –
information about your transactions and
experiences
YES
NO
For our affiliates’ everyday business purposes –
information about your creditworthiness
NO
NO
For our affiliates to market to you
YES
YES
For nonaffiliates to market to you
NO
We don’t share
To Limit our
Sharing?
Email us at support@tryanchor.com.
Please note:
If you are a new customer, we can begin sharing your information 30 days from the date
we sent this notice. If you’re an existing customer and have opted out previously, you
don’t need to update your privacy choices again. When you are no longer our customer,
we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.
Questions?
Email us at support@tryanchor.com.
Who we are
Who is providing this notice?
Anchor US LLC and its affiliates
What we do
How does Anchor US protect my
personal information?
To protect your personal information from unauthorized access and use,
we use security measures that comply with federal law. These measures
include computer safeguards and secured files and buildings.
How does Anchor US collect my
personal information?
We collect your personal information, for example, when you:
§ open an account or provide account information
§ apply for services or accounts
§ direct us to buy and/or sell your securities
§ tell us about your investment or retirement portfolio
§ provide account information
§ give us your contact information
§ show us your government-issued ID
We also collect your personal information from others, such as credit
bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
▪ sharing for affiliates’ everyday business purposes –
information about your creditworthiness
▪ affiliates from using your information to market to you
▪ sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights
to limit sharing. See below for more on your rights under state law.
Definitions
Affiliates
Companies related by common ownership or control. They can be
financial and nonfinancial companies.
Nonaffiliates
Companies not related by common ownership or control. They can be
financial and nonfinancial companies.
■ Anchor US does not share with nonaffiliates so they can market to
you.
Joint marketing
A formal agreement between nonaffiliated financial companies that
together market financial products or services to you.
■ Our joint marketing partners include companies such as financial
services companies, banks, non-bank lenders and other financial
institutions.
Other important information
CA Residents: We will not share information we collect about you with nonaffiliated third parties, except
as permitted by California law, such as to process your transactions or to maintain your account. We will
limit sharing among our companies to the extent required by California law. We will limit sharing among
our companies to the extent required by California law.
NV Residents: We are providing this notice to you pursuant to Nevada law. If you prefer not to receive
marketing calls from us, you may be placed on our internal Do Not Call List by writing to us at Dave, Inc
1265 S Cochran Ave, Los Angeles, CA 90019. Nevada law requires that we also provide you with the
following contact information: Bureau of Consumer Protections, Office of the Nevada Attorney General,
555 E. Washington Street, Suite 3900, Las Vegas, NV 89101, phone number (702) 486-3132, email
BCPINFO@ag.state.nv.us.
VT Residents: We will not share information we collect about you with nonaffiliated third parties, except
as permitted by Vermont law, such as to process your transactions or to maintain your account.
State laws may also provide you with specific privacy protections. We will comply with applicable state
laws with respect to our use of your information.
