Privacy Policy

Last Updated: May 15, 2024

This Privacy Policy describes how Too Express Technology Inc and its affiliates and related parties (“Too Express”) collect, use, and share any information that can be used to directly or indirectly personally identifies you (“Personal Data”) that we receive from you when you visit our website or app or which we otherwise receive or collect from you in the course of, or in connection with, the provision of our products and services and our business operations.

It answers the following questions:

• How do we collect Personal Data about you?
• What Personal Data do we collect?
• How do we use your Personal Data, and on what legal basis do we collect your Personal Data?
• How do we keep your Personal Data safe?
• How do we share your Personal Data?
• What are your legal data privacy rights?
• How long do we retain your Personal Data?
• How do we protect children’s privacy?
• How do we use your Personal Data to inform you and market to you?
• How do we make changes to this Privacy Policy?
• Where does this Privacy Policy apply?
• Who can you contact if you have further questions or requests about your privacy?

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

How do we collect Personal Data about you?

We collect information from and about you when you register with us or use our products, services or apps (our “Services”) or use our website or software applications, or access or use third-party services that use our Application Programming Interface (“API”).

• When registering with us as a customer, we ask you for detailed information, which we will use to verify your identity and protect against fraud, among other reasons discussed below.
• We gather Personal Data at other times when managing your Too Express account, such as from surveys, during support or customer care or during investigations.
• We automatically collect information sent to us by your computer, mobile phone or other device to improve your experience.
• When you use a location-enabled device with our Service, we may collect geographical location data or use various means to determine your location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots.

As you interact with our website or software applications, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, and other similar technologies. Cookies are small data files stored on your hard drive by a website. Cookies help us make our website and Service and your use of them better by allowing us to recognize your browser and capture and remember certain information. Please see our Cookie Policy for additional information. You can also adjust your browser settings to disable cookies, but it may affect your ability to use the Service and our website.

Do Not Track (“DNT”) is a privacy preference that Individuals can set in certain web browsers. DNT is a privacy preference that Individuals can set in certain browsers to inform websites that they do not want certain information about their webpage visits collected over time and across websites. We do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.

We may receive data from third parties about you. This may include technical data from analytics and advertising partners like Google, from identity verification providers, as well as from other institutions.

What Personal Data do we collect?

Too Express only collects the Personal Data we need in order to offer and support our Service and meet our legal and regulatory obligations, which may vary depending on our relationship with you.

Here is an overview of the Personal Data we collect from or about you:

• Identity verification data: To verify your identity, we may collect your name, address, ID numbers, date of birth, and other similar information. We may also require you to provide additional Personal Data for verification purposes, including a copy of your government-issued identification and a selfie photo. We may obtain information from affiliated and non-affiliated third parties, such as credit bureaus, identity verification services, and other screening services to verify that you are eligible to use our Services, and will associate that information with the information we collected from you. As part of our identity verification process, Too Express uses Acuant to verify your identity by determining whether a selfie you take matches the photo in your government-issued identification.
• Financial data: In addition to identity verification, Too Express may collect various information regarding your finances and other financial information (including the bank information you provide us) in order to be able to perform, and better perform, the transactions you request on the platform. We also may collect this information to ensure compliance with regulatory requirements (e.g., anti-money laundering laws) and our own internal policies. In order for this to function, we must share certain elements of your Personal Data with these third parties. The information we receive, including information from third parties, may include accounts you hold, balances, transactions, and a risk score. When linking your existing bank account to the Too Express platform, users in certain jurisdictions may use third-party services including Plaid and Stripe to seamlessly link accounts, and in order to do so, information about your bank account is shared by such third-party providers with Too Express. The collection and transfer of this information is also subject to privacy policies of our third party service providers.
• Account activity data: We collect information about your transactions, payments from or to you, and your other activities on our site or Service and other details of products and services you have purchased from us.
• Application use data: We may collect data on your interaction and use of our Service. This includes visits to our website or app, sign-up activity, your bank account, credit card, other payment details to enable you to enter into transactions on the Service, along with any additional information you may disclose to our user support team in order to resolve problems you report.
• Your device data: We collect and process your internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or any of our software applications.
• Marketing data: We collect and process your preferences in receiving marketing from us, your email address, including hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising, and where you may have seen Too Express advertisements.

How do we use your Personal Data, and on what legal basis do we collect your Personal Data?

Listed below are the ways in which we may use and process your Personal Data and the legal grounds we rely on to do so.

• Providing our Service to you: It may sound obvious, but we need your data to make Too Express work in the first place. Without your name, banking information and other details, we simply could not offer you our products and services. In addition, we may store and use your data to make our product work better and quicker. For example, we may store your bank account information to make it easier for you to conduct future transactions with us without requiring you to re-enter your bank account information.
• Fraud Prevention: We use the Personal Data we collect in connection with providing you our services to detect and prevent fraudulent activity. We share this information with Acuant, a third party service provider, to assist us with this effort. Acuant uses various technologies to capture various device identifiers, such as canvas fingerprinting and may use automated decision making in order to detect and prevent fraudulent activity. To learn more about Acuant, please see their Service Privacy Notice.
• Account Security: We use your phone number for our account two-factor authentication process. This includes sending SMS or text messages (including by an automatic telephone dialing system) to any of the phone numbers provided by you or on your behalf in connection with your Too Express account.
• Keeping you informed: It is important for security and financial transparency that we keep you aware of your transactions and related activity at Too Express. We will send you emails with confirmations, invoices, technical notices, updates, security alerts, legal and support and administrative messages.
• Investigations: Occasionally, we need to look at your account activity in order to check and protect against fraudulent, unauthorized or illegal behavior.
• Customer care: We strive to make sure you can easily use our products with no headaches, but sometimes you need help. Our customer care team will occasionally need access to your account data in order to fix any issues or answer your questions.
• Managing and improving our Service: We like to understand how our users engage and use Too Express in order to make sure Too Express is the best it can be. This process includes combining different account, transactional, marketing and other data to analyze the effectiveness and performance of our Service.
• Behavioral Advertising and Analytics: This process includes combining different account, transactional, marketing, and cross-device tracking. When we apply these techniques we may use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We may also use information from your mobile device, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier for advanced attribution and analytical purposes including personalized or lookalike advertising.

You can opt-out of targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Google Analytics: http://myactivity.google.com/

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. Or by visiting any of the links below: http://optout.networkadvertising.org/.

• Communicating with you: We want you to be aware of product updates, news, events, and promotions and, if you consent, we will send you information, including regular personalized emails, to keep you up to date with all things Too Express is offering.
• Business operations: We may need to use your Personal Data for our business operations, including internal training and administration, legal compliance, to enforce our legal rights, to protect third party rights, and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
• Website and software applications: We use data analytics to improve our website and software applications, activities and operations, products/services, events, etc.
• Third parties: If you (i) use our Service and/or platform by (a) using an application (whether directly or by authorizing an application to use our Service and/or platform), (b) using a link provided by a third-party, or (c) any third party integrations or (ii) if you partner with us in a program or other business arrangement where a third-party intermediary is involved all such third parties may receive detailed information about your account, your use of the Service, transaction history or even the ability to take actions on your behalf. When you authorize an application or third party integration via the Too Express platform, you will be notified of what Personal Data will be shared with these third parties. Information collected by these applications or third-party integrations are subject to their terms and policies and are required by contract by Too Express to maintain the confidentiality and security of your Personal Data.

The primary legal grounds upon which we collect and process your Personal Data are:

• through obtaining your consent at the time of collection,
• due to the necessity of doing so to perform the services as requested,
• in order to comply with our legal obligations, and
• to pursue our legitimate interests (e.g., to improve our services).

Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using that data.

How do we keep your Personal Data safe?

We have implemented security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We protect your Personal Data by maintaining physical, electronic, and procedural safeguards, incorporating tested security technologies, in compliance with applicable laws. We may use network safeguards such as firewalls and data encryption, enforce physical access controls, and authorize access to Personal Data only for those people who require access to fulfill their job responsibilities.

In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Those with access to your Personal Data are carefully screened, periodically reevaluated, and are required to keep all your Personal Data confidential.

How do we share your Personal Data?

We sometimes share your information internally between employees and contractors of the Too Express, in particular in connection with activities undertaken jointly or in common with such group members and/or provide IT and system administration services and undertake management reporting.

We do not sell, trade or otherwise transfer your Personal Data to third parties other than third parties who assist us in operating our Service, third parties who assist us in facilitating certain programs and other business arrangements for which you have expressly agreed to participate, management and reporting, maintaining compliance with relevant laws (including compliance with relevant anti-corruption, anti‐bribery, anti‐terrorism, and anti‐money laundering laws), conducting our business or supporting our users, or providing you with applications or services integrated via our API. We require that those third parties agree to keep this information confidential and secure on the same conditions and protection levels we provide to you as a user, in accordance with relevant privacy laws.

We may also release your information to certified and authorized law enforcement officials when we believe release is appropriate to comply with the law, enforce our terms or policies, or protect the rights, property, or safety of Too Express, our users, or others. We have a set of guidelines for how we engage with law enforcement officials that are available to the public here.

Finally, in the event of the sale or transfer of ownership, your data would be shared with the new owners.

What are your legal data privacy rights?

You have the right to:

• Access the Personal Data we store and process about you or to request a copy of it to transfer to another service provider.
• Request that we correct inaccurate data about you.
• Ask us to delete or object to us processing your data, although for legal reasons (e.g., anti-money laundering rules and regulations) we cannot always do this.
• Withdraw your consent to receive marketing emails.

Your marketing preferences can be updated on the Too Express Platform under your user settings or through any Newsletter via the “Unsubscribe” link. For all other Data Privacy inquiries, please submit your request through our standard customer support process, by contacting us at csg@too.express.

How long do we retain your Personal Data?

Too Express maintains reasonable procedures to help ensure that your Personal Data is reliable for its intended use, accurate, complete, and current.

• We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, as well as other factors required by the laws to which we are subject.
• When it is no longer necessary to retain your Personal Data, we will securely delete it, subject to applicable law and regulations.
• In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
• If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
• Should you make a Data Subject request through our standard customer support channel, we will retain the minimum required amount of data in order to keep a record of your request and the action we took to resolve it.

Please be aware that we may keep your Personal Data for five years or more from the date you cease to be our customer, depending on applicable law or regulations in the jurisdictions we operate.

How do we protect children’s privacy?

We do not knowingly solicit or collect information from individuals under 18. If we become aware that a child under the age of 18 has provided us with Personal Data, we will close the account and restrict their information. If you believe that we might have collected Personal Data from a child under 18, please contact us using the information below.

How do we use your Personal Data to inform you and market to you?

In compliance with applicable laws, we may send you personalized marketing information, including by email, and such information may include product and service updates, industry news, our events, activities and offers, information about our business and personnel, and tips. We may combine your Personal Data such as age, transaction history, account usage to improve the value and specificity of these communications.

You can ask us to stop sending you marketing messages or information at any time by following the “unsubscribe” link on any marketing message sent to you or by updating your contact preferences directly on the Too Express Platform. Please note, it may take up to 10 days for this to take effect. Where you opt-out of receiving these marketing messages or publications, this will not apply to Personal Data collected by or provided to us in connection with a specific purpose, request, order, event or activity or any dealings with you, and you may still receive emails from us relating to the operation of the Too Express service, like transaction confirmations.

How do we make changes to this Privacy Policy?

This version was last updated on the date indicated above and historic versions are archived and can be obtained by contacting us. We may update this Privacy Policy from time to time as we deem necessary or appropriate in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you by email, by means of a notice on the Too Express Platform, or as otherwise required by applicable law. We encourage you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by us. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Where does this Privacy Policy apply?

This Privacy Policy applies to all of the services offered by Too Express and services offered on third-party sites, such as advertising services. This Privacy Policy does not apply to services that have separate privacy notices that do not incorporate this Privacy Policy

This Privacy Policy doesn’t apply to the information practices of other companies and organizations that advertise our services or to services offered by other companies or individuals, including products or sites that may include our Services or be linked from our Services.

This website and app may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

Information for California Residents If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (the “CCPA”) and other applicable laws with respect to your Personal Data, as outlined below.

(i) Right to Know. You may request, twice per calendar year, to know (i) the specific pieces of Personal Data we have collected about you; (ii) the categories of Personal Data we have collected about you; (iii) the categories of sources from which we collected your Personal Data, (iv) our business purpose for collecting your Personal Data; and (v) the categories of third parties with whom we shared your Personal Data.

(ii) Right to Delete. You may request to delete the Personal Data we have collected about you. We may deny your request under certain circumstances, such as if we need to comply with a legal obligation.

(iii) Right to Correct. We would like to maintain accurate Personal Data. If you believe that the Personal Data we have collected about you is inaccurate, you may request to correct the Personal Data.

(iv) Non-Discrimination. We will not discriminate against you for exercising these rights.

(v) “Shine the Light.” You may request, once per calendar year, certain information regarding our disclosure of your Personal Data to third parties for their own direct marketing purposes.

If you wish to make a request pursuant to this section or learn more about our compliance, please contact us using the information provided below.

Who can you contact if you have further questions or requests about your privacy?

You can direct any questions or complaints about the use or disclosure of your Personal Data to us by contacting us as set out below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data as soon as possible.

If you have any questions about this Privacy Policy or need to contact us, please email us at csg@too.express. All Data Subject Requests should be submitted to our Customer Support Team.