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© 2019 by intrX Inc, a Delaware Corporation. All rights reserved 

intrX Privacy Policy

This Privacy Policy describes how intrX Inc. (“​intrX​”), a Delaware corporation, collects, uses, and discloses information about you in connection with your use of the intrX online cash management service web and mobile application, the website at ​www.intrXcorp.com​ and any other properties that reference this Privacy Policy (collectively, the “​Service​”).1 By using the Service, you consent to the use of your information as set forth in this Privacy Policy. “You” means “you” as defined in the intrX Terms of Service and Client Agreement, and you should read this Privacy Policy in conjunction with that agreement.

 

Summary

intrX respects your privacy. The following summarizes the intrX Privacy Policy, and please read the entire policy for details:

  • intrX collects information that you provide explicitly when you create an account or use the Service, including non-public personal and financial information such as your name and bank account number;

  • intrX automatically collects additional information about you, including via your use of the Service, and may store information about you by using cookies and similar technologies;

  • intrX may collect information about you from third-parties that may have referred you to the Service;

  • intrX never shares your directly identifiable personal information (e.g., name, contact details) with third parties for their own marketing purposes;

  • intrX uses the information it collects to manage your Service account, provide the Service, charge you for the Service, deliver marketing communications, generate and analyze Service usage statistics, prevent fraud and improve the Service;

  • intrX may share your information with third parties (a) as necessary to enable the foregoing uses, (b) at your express direction or with your express consent, e.g. to your service providers such as financial information aggregator services and financial advisors, (c) as required or requested by regulatory or other governmental authorities, (d) in special circumstances such as to protect your rights or the rights of intrX or others and (e) in connection with a sale or restructuring of intrX;​

  • intrX uses commercially reasonable administrative, technical, and physical safeguards, including encryption and other security measures, to protect your information; and

  • intrX may update this Privacy Policy at any time.

What Information Does intrX Collect?

Information You Explicitly Provide​ — intrX may work with one or more affiliated or unaffiliated intermediaries and/or third parties to operate the Service (collectively, “​Other Parties”​ ). intrX and the Other Parties collect the information that you explicitly provide to intrX, including when you apply for a Service account at www.intrXcorp.com and when you use the Service.

If you are an entity client, intrX collects your business name, entity registration number, tax identification number, state of formation or incorporation, and the names of any owners of 25% or more of your entity. If you are a natural person, intrX collects your full legal name, date of birth and social security number or other tax identifier.

For all clients, intrX also collects your postal address, email address, telephone number, password for accessing the Service and your response to additional security questions that help verify your identity. You can log into your Service account to view and update your personal information. intrX may also ask you to provide optional demographic information, such as your age, income, profession, and information about your financial assets. To fund your Service account and withdraw funds from the Service, you must also provide information about at least one financial account that you maintain with a third-party financial institution. intrX refers to your sensitive personal financial information such as account numbers, account balances and responses to security challenge questions as “​Financial Account Information​.” intrX may also collect information that you provide to intrX by email, telephone, or other means.

Information Automatically Collected From Your Internet Access Device​ — intrX and the Other Parties may automatically collect information from the Internet access device you use with the Service, such as your Internet Protocol address, your browser type, your operating system, mobile device identifiers such as make and model, mobile advertising ID, mobile carrier, the components of the Service you access, the pages you view immediately before and after you access the intrX website, and the information you search for within the Service. This information allows intrX to recognize you and personalize your experience, and to improve the Service.

intrX and the Other Parties may collect this information using “cookies,” which are small text files that websites and mobile applications save on your Internet access device, and similar technologies. intrX uses cookies and information gathered through them to enhance your Service experience, including maintaining continuity during an online session, gathering data about the use of intrxcorp.com and an implementing anti-fraud and information security measures.

intrX may also use cookies and information gathered through their use to make your experience on other sites more personalized based on the products, services, or other interaction you have with at the intrX website and other sites. Information gathered through the use of cookies may be used to make offers to you via online ads, email, U.S. mail, or telephone. We also use cookies, sometimes in conjunction with third parties, in online advertising either on the intrX website or on third party sites to help determine which of intrX advertisements are most likely to appeal to you. intrX respects consumers’ ability to exercise choice in receiving these types of ads on third party sites as follows: For this type of advertising placed on third party sites, intrX works with advertising networks that participate in the Digital Advertising Alliance AdChoices program. If you receive an ad delivered on a third party site in part based on information gathered through the use of cookies, you may opt out of receiving such ads by clicking the displayed icon and following the instructions or by visiting http://www.aboutads.info/choices/. This opt-out works via cookies, so if you delete cookies, use a different device, or change web browsers, you will need to opt out again. Information that intrX collects about you from one particular browser or device may be used to provide advertising or collect information on another browser or device. It may also be transferred to a third party for advertising or information collection on behalf of intrX. Please note that your choice to opt out on a particular browser or device will apply only to the collection and use of information from that particular browser or device. Opting out on a particular device will not opt you out of information collection on other devices, nor will it limit cross device sharing on those other devices.

Other Parties collecting information about your behavior when you use the Service are generally limited to service providers that only use the information to provide services for intrX and not to provide services or advertising for any other party. Note, however, that intrX also provides certain widgets or tools on our sites, such as tools that allow web surfers to easily share information on another platform, such as a social media platform. At other times, information from a third party may be embedded on our site, such as a map or information streaming from another site, including communications streaming from a third party social media platform. These widgets, tools, and informational items often function through the use of third party cookies utilized by the third party site, such as the social media platform. As a result, these third parties may have access to information about your web browsing on the pages of intrxcorp.com where these widgets, tools, or information are placed. You may wish to review information at third party sites, such as social media platforms where you have an account, to determine how these third parties treat data that they obtain through the use of cookies.

The latest versions of internet browsers provide cookie management tools, such as the ability to delete or reject cookies, and doing so may affect Service functionality. The latest mobile device operating systems allow you to change your advertising identifier tracking setting, Refer to information supplied by browser and device providers, as applicable, for more specific information, including how to use these tools.

Information intrX Collects from Third Parties​ — intrX may collect information about you from third-parties. For example, if someone refers you to create a Service account, intrX may store the identity of that person in your account profile. intrX similarly records the names of anyone you refer to create a Service account.

 

How Does intrX Use Your Information?

intrX may use the information it collects for lawful purposes, including, but not limited to: ▪ providing the Service to you and charging you for the Service;

  • providing you with products, services, information and notices related to the Service;

  • providing you with marketing communications, promotional materials, and advertisements (however, intrX never shares your directly identifiable personal information such as name or contact details with third parties for their own marketing purposes);

  • customizing your Service experience, including personalizing components and content based on your interests;

  • enhancing the Service and developing new service offerings;

  • generating and analyzing for internal use individual statistics about you and your Service usage, including statistics derived from Financial Account Information such as account balances;

  • aggregating individual statistics with statistics about other Service users; and

  • detecting, preventing, and responding to fraud, intellectual property infringement, violations of our Terms of Service and Client Agreement, violations of law, and other misuses of the Service.

    Under What Circumstances Does intrX Disclose Your Information?

    intrX never discloses your Financial Account Information or directly identifiable personal information such as your name or contact details to third parties so they can market to you, and intrX may otherwise disclose the information it obtains about you:

  • as necessary to enable the use of your information as detailed above under “How Does intrX Use Your Information?” including, for example, by providing it to third parties that help to verify your identity, to establish that you control the bank accounts you connect to the Service, and to store the Financial Account Information you provide to intrX;

  • to service providers working on behalf of intrX that are bound by confidentiality and privacy obligations;

  • at your express direction or with your express consent, e.g. to your service providers such as financial information aggregator services or financial advisors;

  • as required by law, such as to comply with a subpoena or other legal process, or as required or requested by governmental and regulatory authorities, such as to comply with government reporting obligations or to assist in governmental investigations;

  • when intrX believes in good faith that disclosure is necessary to (a) protect its rights, your rights, or the rights of other Service users or (b) maintain the integrity of the Service or protect human safety; and/or

  • to affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to procure, negotiate and complete a merger with another entity, a corporate reorganization, an acquisition of capital stock, or a sale of all or a portion of intrX’s assets.

In addition, intrX may publish or share with any third party aggregate reports on Service user demographics and Service usage, and any other information that does not personally identify you. This may include aggregate, non-personally identifiable information derived from Financial Account Information (e.g., the average or total balances of our users’ Service accounts).

 

Third-party Financial Institutions

When intrX accesses a third party financial institution on your behalf (e.g., to make ACH transfers), it acts as your agent and not as the agent of the third party financial institution. Your information that intrX transmits on your behalf to such third party financial institutions, such as your name and account number, is subject to the third party financial institution’s privacy policy and terms of use. You should review and be aware of each third party financial institution’s terms before linking your account at such institution to the Service.

Third-Party Data Providers

To provide the Service to you, intrX may use third party data services to access your Financial Account Information from financial institutions (e.g., to verify that you control the accounts that you link to the Service). These Other Parties are bound by privacy obligations that prohibit them from disclosing your Financial Account Information and personally identifiable information except to provide the Service and they are allowed to use anonymized user data in their discretion. By using our Service, you grant such Other Parties the right, power, and authority to act on your behalf to access and transmit your personal and financial information to and from the relevant financial institution.

Third-Party Websites

The Service and communications from intrX may contain links to websites operated by third parties. intrX is not responsible for the collection and use of your information by any websites that intrX does not control. Review the privacy policies of the applicable websites to learn more.

Where is Your Information Stored?

intrX processes and stores the information collected through the Service in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country, and such information may be available to the United States government or its agencies under a lawful order made in the United States. By using the Service, you consent to such transfer to, and processing in, the United States.

How is Your Information Secured?

intrX is committed to protecting your information from unauthorized access, use, and disclosure. intrX maintains commercially reasonable administrative, technical, and physical safeguards designed to protect the information collected through the Service. For example, intrX uses Transport Layer Security encryption technology to protect the transfer of your information, encrypts your information stored on its servers, and does not permit its employees to access

your Financial Account Information. However, no information or communications system can be 100% secure, and intrX cannot guarantee the security of your information. In addition, intrX is not responsible for the security of information that you transmit to the Service over networks that it does not control, including the Internet and wireless networks.

Children’s Information

The Service is for persons 18 and over and is not directed to, nor does intrX knowingly collect, information from children under the age of 13. intrX requests that children under the age of 18 do not provide personal information through Service. If you become aware that a child has provided intrX with information, please contact intrX at the contact information listed below. For more information about children’s privacy, see the information provided by the FTC about the Children’s Online Privacy Protection Act (COPPA) (e.g., at https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children%27s-privacy​).

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. intrX does not share your directly identifiable personal information with third parties for the third parties’ direct marketing purposes.

Do Not Track

intrX does not support Do Not Track. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit ​www.eff.org/issues/do-not-track​.

Changes to This Privacy Policy

intrX reserves the right to modify this Privacy Policy from time to time by posting the modified Privacy Policy at [www.intrXcorp.com/privacy][confirm].​ ​Using the Service following any modification means that you accept the modified Privacy Policy, provided that if intrX determines in good faith that any modifications are material, it will notify you via email at least 30 days prior to implementing them, unless a longer notice period is required by applicable law.

Contact intrX

If you have any questions about this Privacy Policy or the use of your information collected through the Service, please write to intrX legal@intrxcorp.com or at intrX Inc., Attn: Legal Affairs, 142 West 57th Street, New York, NY 10019.