Privacy Policy

Last updated: Feb 6, 2024

Introduction

This Privacy Policy sets out the basis on which any personal data and other information we collect from you or other sources or that you provide to us (“Information”) will be processed by us in connection with your access and use of Dapi (“Site”), services made available to you on our Site (collectively, the “Services”). This Site is not intended for children and we do not knowingly collect data relating to children. We understand the importance you, as a user of our Site, place on the Information provided to us, and we are committed to protecting and respecting your privacy. Please read the following
carefully to understand our practices regarding your Information. By using our Services, you agree to the handling of your Information in accordance with this Privacy Policy. DAPI Inc, a corporation registered in Delaware, USA. The office of DAPI Inc is located at 2261 Market Street #4838, San Francisco, CA 94114, USA. References to “user” or “you” (or similar) are references to you as an individual or legal entity, based on the service you are utilizing from DAPI Inc.

INFORMATION WE MAY COLLECT FROM YOU AS PART OF OPEN BANKING SERVICES

We may collect, use, store, transfer and process the following Information about you:

  1. Information that you provide by filling in forms on our Site, including information
    provided at the time of registering to use our Site and other core registrations,
    subscribing to our Services, posting material or requesting further services;
  2. Information we receive from the financial product and service providers that maintain your financial accounts, as well as the information made available by those providers, e.g.:
    ‍
    i. account information, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, and account and routing number;
    ii. information about an account balance, including current and available balance;iii. information about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
    iv. information about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
    v. information about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
    vi. identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address
    information;
    vii. information about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction;
    viii. insurance information; and
    ix. professional information, including salary amounts, information about your employer, in limited cases where you have connected
    your payroll accounts.
  3. If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.
  4. A record of correspondence if you contact us;
  5. General, aggregated, demographic and non-personal Information;
  6. Details about your computer, including (where available) your IP address, operating system and browser plug-in types, operating system and platform as well as information about your general internet usage (e.g. by using technology that stores information on or gains access to your device, such as cookies, tracking pixels, web beacons etc. (together, “Cookies”));
  7. Preferences in receiving marketing from us and our third parties and your communication preferences;
  8. Information we may receive from other sources, e.g. we also receive identifiers and commercial information about you directly from the relevant developer or other third parties, including our service providers, bank partners, and identity
    verification services; and
  9. any other Information we consider necessary to enhance your experience on theSite.

INFORMATION WE MAY COLLECT FROM YOU AS PART OF PAYMENT SERVICES & DIGITAL BANKING ACCESS

WHAT DOES DAPI 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:
‍
• Name
• Address
• Transaction data
• Date of Birth
• Account balances
• Social Security Number
‍
When you are no longer our customer, we continue to share your
information as described in this notice.

How?

All financial companies need to share customers' 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 Dapi chooses to share; and whether you can limit this sharing.

What?

The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
‍
• Name
• Address
• Transaction data
• Date of Birth
• Account balances
• Social Security Number
‍
When you are no longer our customer, we continue to share your
information as described in this notice.

What?

The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
‍
• Name
• Address
• Transaction data
• Date of Birth
• Account balances
• Social Security Number
‍
When you are no longer our customer, we continue to share your
information as described in this notice.

Reasons we can share your personal information
Does Dapi 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

For our marketing purposes
to offer our products and services to you

We don’t share

For joint marketing with other financial companies

We don’t share

For our affiliates everyday business purposes
information about your transactions and
experiences

We don’t share

For our affiliates everyday business purposes
information about your creditworthiness

We don’t share

For non affiliates to market to you

We don’t share

Questions? Contact us at www.dapi.com/contact

How does Dapi 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.We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.

How does Sutton Bank collect my personal information?

We collect your personal information, for example, when you open an account  Use your credit or debit cardPay your bills  Make deposits or withdrawals from Apply for a loan your account 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 non affiliates 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.

Affiliate Definitions

Affiliates Companies related by common ownership or control. They can be financial and non-financial companies. Sutton Bank does not share with our affiliates. Non Affiliates Companies not related by common ownership or control. They can be financial and non-financial companies. Sutton Bank does not share with non affiliates 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 insurance companies and investment companies.

Other Important Information & State specific privacy rights

For Alaska, Illinois, Maryland and North Dakota Customers: We will not share personal information with non affiliates either for them to market to you or for joint marketing - without your authorization.
‍
‍For California Customers: We will not share personal information with non affiliates either for them to market to you or for joint marketing - without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.
‍
For Massachusetts, Mississippi and New Jersey Customers: We will not share personal information from deposit or share relationships with non affiliates either for them to market to you or for joint marketing - without your authorization.

OUR USE OF YOUR INFORMATION

We may use Information held about you in the following ways:

  1. to provide you with information, products or services that you request from us or which we feel may interest you;
  2. to provide you with location-based services, such as advertising, search results and other personalized content;
  3. to carry out our obligations arising from any contracts entered into between you and another entity using our Site or between you and us;
  4. to improve, operate and maintain our Services and to deliver a better and more personalized service;
  5. to ensure that content from our Site is presented in the most effective manner for you and the device you use to access our Site;
  6. to comply with a legal obligation;
  7. to notify you about changes to our Services;
  8. to protect you, developers and our partners from fraud, malicious activity, and other privacy and security-related concerns;
  9. to investigate any misuse of our service or developers’ applications, including criminal activity, or other unauthorized access to our services;
  10. to develop new services;
  11. to verify your identity and the identities of other members of your company or organization;
  12. to bill developers for our Services and to transmit payment;
  13. to respond to your comments, questions, inquiries, and customer service requests;
  14. to communicate with you about products, services, offers, and events offered or sponsored by us, and to provide news and other information we think may be of interest to you;
  15. to monitor and analyze trends, usage, and activities in connection with our Services; and
  16. for any other reason which we deem necessary to enhance your experience of the Site.

DISCLOSURE OF YOUR INFORMATION

Information about our customers is an important part of our business. We share customer information only as described below and with group companies that follow practices at least as protective as those described in this Privacy Policy:

  1. Affiliated and Partner Businesses, and other Third Parties: To offer you our Services, we may engage with an affiliated or other business, or other third party, that we may or may not control (e.g. marketing companies, developers, payments processers to process online transactions etc.). We will inform you when an affiliated or partner business, or other third party, is involved in your transactions and when we will need to share your Information related to those transactions with them.
  2. You understand that it is important that such affiliated and partner businesses, and other third parties, have access to the relevant Information to perform their functions. We will ensure that these affiliated and partner businesses, and other third parties, do not use your Information for other purposes. We may also receive Information from these affiliated and partner businesses, and other third parties (e.g. updated address information), which we may use (e.g. to correct our records).
  3. Marketing and Promotional Offers: We may also use your Information to provide you with information about goods and services which may be of interest to you and enhance your Site experience, service messages, new features, enhancements, special offers and events of interest. We may contact you via the following channels: emails, push notifications, web notifications, post, telephone or in-app messages.
  4. Business Transfers: In the event that we or substantially all of our assets are acquired (by merger or acquisition), or transferred by way of a reorganization, customer information will be one of the transferred assets.
  5. Protection of Our Site and Others: We release accounts and other personal information when we believe such a release is appropriate, necessary or required to comply with the law and law enforcement investigations and to protect the rights, property or safety of our users, developers or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. However, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information provided by you for commercial purposes in violation of the commitments set forth in this Privacy Policy.
  6. With Your Consent: Other than as set out above, you will receive notice when information about you might be sent to third parties, and you will have an opportunity to choose not to share the information.

We may collect, use, and share Information in an aggregated, de-identified, or anonymized manner for any purpose permitted under law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

Note that 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 these policies. Please check these policies before you submit any personal data or other information to these websites.

STORAGE OF YOUR INFORMATION

Some of the information we collect from you may be transferred to, and stored at, a destination outside of your country of residence, specifically in the United States. It may also be processed by staff operating in the United States who work for us or for an affiliated or partner business. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details, and the provision of support services.

SECURITY

We take reasonable steps to ensure that your Information is treated securely and in accordance with this Privacy Policy.

We may, for example, use encryption technology to secure your Information during transmission to our Site as well as external firewall and on-host firewall technology to prevent network level attacks.

It is important for you to protect against unauthorized access to your password and to your devices used to access our Services. You are responsible for keeping your password confidential. For example, ensure that you sign off when you have finished using a shared device.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Information, we cannot guarantee the security of your Information transmitted to our Site; any transmission is at your own risk.

AMENDING YOUR INFORMATION

You may be able to access a broad range of Information about your account and your interactions with the Site for the purpose of viewing and, in certain cases, updating that Information.Examples of information you may be able to access at the Site include:

  1. up-to-date information regarding recent orders;
  2. personally identifiable information (including name, e-mail, password, communications and personalized advertising preferences);
  3. payment settings (including credit card information); and
  4. e-mail notification settings.

You can opt-out of receiving future marketing communications from us at any time by adjusting your customer communication preferences, or the unsubscribe link within the email communication.

Also our system will place cookies when you log on to our Site and this is to ensure you have an enjoyable user experience and are able to utilize all aspects of the Site. You may disable Cookies by changing the settings on your browser. If you disable Cookies, it will affect how our Site works and you may not be able to access or use certain areas of our Site or full functionality. For example, performance cookies collect information about how you use the Site, for instance, which pages you visit most often, which allows us to provide you with targeted and relevant choices that enhance your Site experience.

We may retain a copy of your Information for compliance reasons. When you update Information, we may retain a copy of the prior version for our records. It is important that your Information we hold about you is accurate and current. Please keep us informed if your Information changes during your relationship with us.

DATA RETENTION

We will only retain your Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

CHANGES TO OUR PRIVACY POLICY

Our business changes constantly, and our Privacy Policy may therefore also need to change. We will post the current version of this Privacy Policy on the Site and each such change will be effective upon posting on the Site or upon the date designated by us as the “effective date”.

We may e-mail periodic reminders of our notices and conditions, but you should check our Site frequently to see recent changes.

It is your obligation to regularly check the Privacy Policy. Your continued use of the Site following any such change constitutes your agreement to this Privacy Policy as so modified.

CONTACT

If you have any concerns about your Information on the Site, please contact us with a thorough description, and we will try to resolve it. Our customer service contact details are:

1- Address: 2261 Market Street #4838 San Francisco, CA 94114
2- Email: hello@dapi.com

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