privacy policy

Frello and Rizing Tides, Inc (“Company,” “we,” or “us”) respect your privacy and is committed to protecting it through this Privacy Policy.

Please read the Privacy Policy carefully before you start to use the Website or App. By using the Website, App, or by clicking to accept or agree to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy Policy, you must not access or use the Website or App.

APPLICABILITY OF PRIVACY STATEMENT

This Privacy Statement applies to all information we collect through our Services from current and former Frello users. “Services” means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Rizing Tides, Inc. in connection with a Frello account. When you are no longer our customer, we continue to disclose your information as described in this Statement. This Statement only applies to the Services and does not apply to the practices of any other Rizing Tides service.

Frello is always improving. As the Services evolve we may occasionally update this Privacy Statement to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by posting notice of the change on the “Privacy Policy” page of our website and mobile apps, otherwise the revised Privacy Statement will be effective as of the published effective date.

Throughout this Privacy Statement, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific person.

THE INFORMATION WE COLLECT

When you visit the website or use one of our mobile applications or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service.

If you open a Frello account, we collect the following information from you:

  • Account Information – text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
  • Identification Information – your name, street address, email address, date of birth, and Social Security number (“SSN”) (or other governmental issued verification numbers).
  • Device Information – information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. 
  • Geolocation Information – information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to disclose your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
  • Social Web Information – with your consent, we may also collect information from social networks, such as your Facebook Connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your email address, Facebook friends list, and public profile (including profile picture). We also allow you to import data from other social web services, including but not limited to Twitter, FourSquare, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation (as well as helping us improve the Services and fight fraud). 
  • Financial Information – bank account online login information and bank account and routing numbers linked to your Frello account. Frello does not disclose financial information with third party social networking services such as those listed in the prior bullet.
  • Biometric Information – when you consent in the user experience, we collect face scans to authenticate your account and manage fraud and risk.
  • Audio, electronic, visual or similar information – Call recordings when you talk to customer service or sales.
  • Professional or employment information – including business information, contact emails, phone numbers and taxpayer ID numbers.
  • Information you provide when you contact us – your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, information about others if you choose to share it with us.

We may also collect the above data from other third parties, including service providers, internet service providers, partners and merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks, card networks and financial institutions.

We are committed to providing a safe, secure and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information in order to comply with law or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or your operating systems or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team, store results when you respond to a survey, or when you use another Rizing Tides service.

INFORMATION FROM CHILDREN

The Services are not directed to children under the age of 18. If we obtain actual knowledge that we have collected personal information from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

HOW WE USE COOKIES

When you visit or use our Services, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies to recognize you as a customer; customize Services, other content and advertising, measure the effectiveness of promotions, perform a wide range of analytics, mitigate risk and prevent potential fraud, and to promote trust and safety across our Services.

Certain Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of certain Services may be limited or not possible.

Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

HOW WE PROTECT & STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state laws and regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal information as well, including never sharing your Frello password with anyone.

If Frello learns of a systems security breach, we may attempt to notify you electronically so you can take appropriate protective steps. By using the Services, you agree that Frello may communicate with you electronically. Frello may post a notice on the website or mobile applications if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at [email protected]

HOW LONG WE STORE YOUR PERSONAL INFORMATION

We retain your Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law.

The criteria used to determine our retention period is as follows:

  • Personal Information used for the ongoing relationship between you and Frello is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:
    • a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under Anti-Money Laundering obligations
    • litigation, investigations, audit, and compliance practices, or to protect against legal claims.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary business purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

  • provide the Services and customer support you request;
  • process transactions and match payments, including payments performed by you through when paying Frello users and matching of such payments to participating digital wallets, and to send notices about your transactions or your network activity;
  • resolve disputes, collect fees, and troubleshoot problems;
  • prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
  • create an account connection between your Frello account and a third-party account or platform;
  • customize, personalize, measure, and improve our services and the content and layout of our website, including showing you location-based promotions and business profiles;  
  • send you updates about new products and services that we are offering to customers;
  • compare information for accuracy and verify it with third parties;
  • perform other duties as required by law;
  • if you elect to disclose your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-based options, functionality, offers, advertising, search results, or other location-based content.

HOW WE DISCLOSE PERSONAL INFORMATION WITHIN THE FRELLO NETWORK

To make or accept payments or loans on Frello, we need to disclose some of your personal information with the person or company that you are paying or is paying you. Your date of sign-up, the number of payments you have received and other verification metrics may be provided to users or companies when you transact with, on, or through Frello.

We work with vendors, such as Plaid, to enable you to make or accept payments to/from others using Frello. In doing so, we may share information about you with them, such as but not limited to your mobile phone number, date of birth, email, or Frello username, . We use this information to confirm things like your identity. 

Regardless, we will not disclose your bank account number or information to anyone on the platform you have paid or who has paid you through Frello, except with your express permission or if we are required to do so in order to comply with a subpoena or other legal process.

HOW WE DISCLOSE PERSONAL INFORMATION WITH OTHER PARTIES

Frello does not disclose your personal information with third parties for their promotional or marketing purposes.

Some personal information is public information and may be seen by anyone on the internet, whether or not they have a Frello account. Public information may also be seen, accessed, reshared or downloaded through Frello’s APIs or third-party services that integrate with our products.

We may disclose your personal information with:

  • Our parent company, Rizing Tides, Inc. and affiliates and subsidiaries it controls, but only for purposes allowed by this document.
  • Companies that Rizing Tides, Inc. plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this Privacy Statement with respect to your personal information. If your personal information could be used contrary to this Statement, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
  • Law enforcement, government officials, or other third parties if Rizing Tides is compelled to do so by a subpoena, court order or similar legal procedure; when it is necessary to do so to comply with law; or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Frello User Agreement, or as otherwise required by law.
  • Third party service providers who assist us in providing Services to you or who provide fraud detection or similar services on our or any vendor’s behalf.
  • The other Frello user participating in the transaction and, depending on the privacy setting of each Frello user, the public, through the Frello feed on our website and mobile application and elsewhere on the internet. 
  • Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit. 
  • Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
    • For the purposes of this Privacy Statement, an “account connection” with such a third party is a connection you authorize or enable between your Frello account and a non-Frello account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Frello and the third-party will exchange your personal information and other information directly; for example, connecting your Frello account to a third-party financial services company like your bank.
    • If you connect your Frello account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.
    • Information that we disclose with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection.

DATE EFFECTIVE

This policy is effective as of March 14, 2024.