Privacy Policy

Free and Victorious takes your privacy seriously. Free and Victorious does not share your information with third parties unless necessary to provide services to you (e.g. Bank, Investment Advisor, and the Platform website or phone application relaying our services to you). We do not sell your information to third parties for marketing purposes. 

Terms not defined in the Privacy Policy are defined in our Terms of Service. 

Below is our policy on your privacy: 

a. Information we collect includes: 

Information you provide us: We collect nonpublic personal information you provide to us when you apply for a Deposit Account or an Investment Account or if you otherwise use Platform or our website or phone application services to send or receive funds. Additionally, when you communicate with Platform, Bank, or Free and Victorious about these services, we may collect this information. While not all of this information is necessary to use our services, if you opt out of sharing some of this information, this may affect your ability to use your Deposit Account or Investment Account or other services offered by Platform, Bank, Investment Advisor, or Free and Victorious. 

The types of information we may collect include: 

Consumer Identity Information: your name or aliases, city, state, phone number, email address, date of birth, gender, photo identification, selfie, or video authorization, or any other information you choose to provide; 

Business Identity Information: entity legal name or aliases / “doing business as” names, physical address, phone number, entity type, industry, organizational documents (e.g. articles of incorporation), employer identification number, or other information relating to your authorized signors or beneficial owners;

Other Information you provide to Customer Support or Platform: If you provide information to customer support, Platform, we may collect this information in order to provide services requested by you.

Information from your digital identity: Your access to Platform services, and Free and Victorious’s services is primarily limited to your internet connected devices. As a result, we may collect some information relating to your digital identity such as: 

Digital Identity Related Information: IP address, your device “fingerprint” (e.g. hardware model, operating system and version, unique device identifiers and mobile network information), browser type, pages visited on our website and pages visited before visiting our website. 

Cookies + Our Website: If you visit our website, we use various technologies to collect information on our services and other websites, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us improve our services and your experience, see which areas and features of our services are popular and count visits. While most web browsers are set to accept cookies by default, if you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our website or other services. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

b. How we use your information 

We may use your information, including nonpublic personal information as follows: 

Provide, maintain and improve account services, and other services we offer you with Platform; 

Provide and deliver the products and services you request, process transactions and send you related information, including confirmations;

Communicate between Platformin order to provide services to you; 

Send you technical notices, updates, security alerts and support and administrative messages;

Respond to your comments, questions and requests and provide customer service;

Monitor and analyze trends, usage and activities in connection with our services;

Personalize and improve the services based on your usage;

Link or combine with information we get from others to help understand your needs and provide you with better service; and

Carry out any other purpose for which the information was collected.

Free and Victorious is based in the United States and the information we collect is governed by U.S. law. By accessing or using the services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries. 

c. How this information is shared 

In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process; 

With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud;

If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Free and Victorious or others;

In connection with, or during negotiations of, any merger, sale of Free and Victorious’s assets, financing or acquisition of all or a portion of our business to another company; and

With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share certain transaction details such as amounts and zip codes in a pseudo-anonymous fashion to promote security and validity of the transaction ledger and Free and Victorious’s services. 

Free and Victorious takes commercially reasonable measures to help protect your User Data and other information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we implement policies designed to protect the confidentiality and security of your nonpublic personal information. Except as detailed herein as it relates to Platform, Free and Victorious limits access to your nonpublic personal information to employees that have a business reason to know such information, and implements security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.