Privacy policy
About Aeldra
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Aeldra is a digital bank serving students, professionals, and investors from Asia in meeting their banking needs in the US. Aeldra will assist individuals with US banking needs for employment, educational or investment purposes to establish a bank account prior to obtaining US taxpayer identification. Aeldra will operate through its US bank partner and will be compliant with regulatory obligations, supervisory expectations, and industry practices. Aeldra cares about your privacy and wants you to be familiar with how we collect, use and disclose data. This Privacy Statement covers the collection, use and disclosure on this Site where the statement is linked.

What general data is collected?
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Personal Information. Generally, “Personal Information” refers to any piece or combination of information that identifies, relates to, describes, or can reasonably be linked or associated with you or your household. Personal Information includes, but is not limited to any means of identification, whether traditional, digital, or other documentary information.

Traditional identifiers include:
• Name
• Date of birth
• Personal identification number
• Physical address
• Telephone number

Digital identifiers include:
• Device ID
• Internet Protocol (IP) address
• Cookies
• Platform or website that sent you to Aeldra
• Voice recordings when you contact Aeldra

Other information includes:
• Government-issued photo ID
• Photographs of you
• Proof of address documentation, such as a lease or rental agreement
• Proof of external bank account
• Occupational information

Personal Information also includes any information associated with your identity. This might include any information about how you use a Aeldra website; where you’re located when you login; what operating system you use; what Aeldra products and services you use; your credit score; and your financial habits. Anything about you is your Personal Information.

Data you give us.  Aeldra collects data you provide us in a variety of ways, such as when you submit questions, request information, or give us feedback, we may ask you for Personal Information. We may also ask you to provide other data relevant to your question, request, or feedback, such as your geographical location, professional and demographic information, industry, and preferred contact method.

In the course of your use of the Services, you may correct or update your information collected at enrollment.

Why we collect this information?
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• Aeldra collects your identifiers in order to provide the Services and the following:
• Analyze individual and aggregated behavior to improve and customize the Services
• Verify your identity and comply with our bank partners’ compliance with applicable law, including anti-money laundering (AML) and sanctions screening rules designed to prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services
• Send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you
• Collect fees and other amounts owed in connection with the Services
• Comply with obligations to tax authorities
• Diagnose and debug our technical systems

How we use the data?
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Coordinating With Business Partners. In order to accomplish the business purposes described above, Aeldra may disclose your traditional and digital identifiers to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.

Aeldra may use certain transaction information as applicable to determine your eligibility for certain features or elements of the Services. If you are referred to Aeldra by certain marketing partners, Aeldra may use your this information to determine what information it must collect from you and whether the partner must be compensated for referring you. Additionally, Aeldra collects this information for the purposes applicable to financial information generally.

History of Aeldra partner bank account transactions. Aeldra collects your Aeldra account transaction history from its processor and bank partner. It collects this information in order to provide you with the Services, in particular preparing your statement, resolving errors and unauthorized transfers, and verifying your identity in certain circumstances.

Credit reporting and scoring information. If you enroll in certain features of the Services, Aeldra may collect credit score and other credit history data from a credit bureau. Aeldra collects this information in order to provide you with the Services, in particular to surface your credit score in the app.

Direct deposit information. If you enroll in Aeldra direct deposit, Aeldra will collect identifying information about your employer from you or a third-party service provider, including your employer’s name and address. Aeldra may use this information to analyze trends in its user base. Aeldra will not share information about your employer unless it is de-identified and aggregated. Additionally, Aeldra collects this information for the purposes applicable to employment information generally (see below).

Commercial Information. Commercial information consists of information about your interest in a particular product or service, your purchasing or consuming tendencies, and/or receipts or records for products or services.

Aeldra collects this information from you whenever:
• You begin the enrollment flow or click on an email ad for a new Aeldra product;
• You make a purchase with your Aeldra debit or credit card; or
• You produce a receipt in response to a fraud prevention, anti-money laundering, or security inquiry from Aeldra.

Who we share this information with?
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In connection with one or more of the purposes outlined above, we may disclose your information to:
• Complete a transaction  you request or authorize, or provide you with a product or service;
• Third parties that provide services to us, such as system hosting, management, and support; data analysis; data backup; and security and storage services;
• As otherwise outlined in this Statement. For example, to advertise to you on social media platforms pseudonymous data is provided to the social media platform;
• Relevant third parties as part of a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding);
• Competent governmental and public authorities, in each case to comply with legal or regulatory obligations or requests; and
• Other third parties as we believe necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce our terms and conditions; (d) to protect our operations and those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or those of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit damages that we may sustain.  

In general, Aeldra discloses each category of Personal Information for the same purpose it is collected. In addition, Aeldra may disclose certain categories of your Personal Information in the circumstances described below:
Legal disclosures. Aeldra may transfer and disclose information as applicable, including your Personal Information, information about how the Services are accessed and used, to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our User Agreement or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety or security of third parties, users of the Services, or the public.
Business transfers. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, Personal Information collected through the Services may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
With your permission. At your direction or request, we may share your Personal Information with specified third parties.

Third-party sites
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This Privacy Statement does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate sites to which this site links. Including a link on our site does not imply that we or our affiliates endorse the practices of the linked site.

When you access or use the Services, you may be directed to other websites or applications that are beyond our control. We may also allow third-party websites or applications to link to the Services or use Session Trackers with the Services. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications. We encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Privacy Policy only applies to the Services.

Use of site by children
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Aeldra understands the importance of protecting the privacy of minors, especially in the online environment. This Site is not designed for or intentionally targeted at minors under the age of 18. It is our policy to never knowingly collect or maintain personal information about anyone under the age of 18. If we become aware that we have collected personal information relating to a minor, we will take reasonable steps to delete it.

Security
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We have in place reasonable organizational, technical, and administrative measures that are designed to protect data from loss, misuse, and unauthorized access, disclosure, alteration, destruction, and other forms of unlawful processing while it is under our control. However, please be aware that the storage and transfer of data cannot always be one-hundred percent secure. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account log-in information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.

Retention period
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We will retain data about you as long as necessary for the fulfillment of the purposes set out in this Privacy Statement, unless applicable law or professional obligations requires a longer retention period.

Special notice to California residents
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If you are a resident of the state of California, you are entitled to request information regarding the disclosure of personal information about you to third parties for direct marketing purposes. Please note that we do not share personal information about you with non-affiliated third parties for such purposes.

Cookies and other similar technologies
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Overview: Our Site uses cookies and other similar technology. Cookies are text files that web servers send to your computer for record keeping and other purposes. The Site may use session cookies (which expire when you close your browser) and persistent cookies (that remain on your computer after you close your browser until you delete them or they expire. We use cookies for security purposes, to help you navigate the Site, to display information more effectively, and to better serve you with tailored information on the Site. We also use cookies to gather statistical information about how visitors use the Site in order to continually improve its design and function.

Pixel tags, web beacons, clear GIFs, and other similar technologies are used in connection with some Site pages to, among other things, track the actions of Site users, compile statistics about Site usage, associate non-identifiable demographic and preference data with device-related data (e.g., cookie IDs), and in some cases matching that with similar data supplied by other companies or estimate the age ranges of the audience that viewed the videos on this Site. We use, and permit third parties to use, this technology that recognize a unique identifier from a cookie placed on your device, and to provide content and ads that are more relevant to you. We also use this technology to compile information about your interaction with email or other communications and determine whether our communications have been opened.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more how to manage cookies, please visit http://www.allaboutcookies.org/manage-cookies/. Some features of the Site may not work properly if you decline the use of cookies.

Third-Parties: The Site contains cookies or similar technologies from third-party providers that help us understand how visitors access our Site, use our Site, and how the site is performing. This information is used to improve our Site and to make our Site more intuitive. These technologies enable the third-party providers to set or read their own cookies or other identifiers on your device.

Honoring do-not-track browser signals
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“Do Not Track” (“DNT”) is a preference you can set in your web browser to let the websites you visit know that you do not want them collecting information about you. At this time, this Site does not respond to DNT or similar signals.

Updates to this privacy statement
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We may update and make changes to this Privacy Statement from time to time in light of, for example, changing business or information handling practices, technology, or legal requirements. When we make changes to this Privacy Statement, we will amend the “Last Revised” date at the top of this page, and such modified or amended version of this Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to review this Privacy Statement periodically to be informed about how we are protecting your information.

Aeldra’s Product Agreement can be found on our website at this link.

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