If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information. Additionally, please refer to your applicable user account agreement for terms and conditions governing your use of the Services.
Synapse Brokerage LLC is a registered broker-dealer and member of FINRA and SIPC. Synapse Brokerage provides cash management account and related services to account owners made available through Platforms and the Platform Mobile App.
Synapse Brokerage’s offices are located at 2012 Northwest Military Highway, San Antonio, TX 78213. Synapse Brokerage operates as a data controller of personal data collected from residents of the European Economic Area or the United Kingdom.
Personal Data We Collect
If you interact with a Platform or Platform Mobile App that offers our Services, we will receive from the Platform (via Synapse Financial Technologies, Inc.) certain of your Personal Data and process that Personal Data to provide our Services:
- Create an Account. When you create an account with a Platform, we may collect information such as your name, email address, Social Security Number or other tax identification number, address, telephone number, date of birth, gender, videos, and photographs that may contain images of your face such as your driver’s license or government-issued identification card.
- Financial Information. We may collect information regarding an external financial account such as the financial institution name, account name, account type, branch number, account number, routing number, international bank account number (“IBAN”), information, data, passwords, authentication questions, materials or other content, transaction, and available balance information. If you establish an account through our Services, we may collect information regarding transactions and transaction history, including but not limited to ACH, wire and card transactions, available account balance, card data, loan and debit amounts, loan types, payment plans, loan balances, linked bank accounts, salary and other income, sources of wealth, and other assets.
- Background Check Data. We may collect information such as credit and criminal checks, supporting research, and screenings, to the extent required or permitted by local law.
- Recipients’ or Senders’ Data. When you send or request money through a Platform, we may receive your name, address, telephone number, IP address, date of birth, and financial account information about the recipient or sender of the funds. The extent of data required about a recipient or sender may vary depending on the Platform product you are using to send or request money.
- Contact Information. We may collect contact information such as your name, email address, and telephone number.
In some cases, we may receive certain Personal Data about you from merchants, recipients and senders of funds, data providers, identity verification providers, and credit bureaus as permitted by law.
How We Use Your Personal Data
We use the Personal Data we collect to provide the Services, to improve our Services, and to protect our legal rights. In addition, we may use the Personal Data we collect to:
- Open cash management accounts on your behalf;
- Provide the Services, perform obligations under our agreements, and carry out related business functions, including performing data and transaction processing, analyzing transaction history to combat regulatory and other security concerns, assisting with the investigation of a dispute, facilitating credit checks, handling user inquiries, and managing the relationship;
- Improve, enhance, modify, add to, and further develop our Services;
- Comply with legal obligations, audit requirements, and regulations applicable to the Services, including but not limited to “know your customer” obligations based on applicable anti-money laundering and anti-terrorism requirements, economic and trade sanctions, customer due diligence, suspicious activity reporting, foreign exchange and international trade, tax reporting and other applicable laws, regulations, ordinances, and obligations or requirements;
- Confirm a person’s authority as a representative or agent of an account holder;
- Conduct record keeping and otherwise manage the business;
- Verify you, your identity, that the data provided is credible, and prevent fraud;
- Protect you, Platforms, Synapse Brokerage, and our related entities and take measures to prevent fraud, malicious activity and other privacy and security-related concerns from impacting you, Platforms, Synapse Brokerage and our related entities;
- Provide customer support to you or to Platforms, including to help respond to your inquiries related to our Services or Platforms’ applications or websites;
- Send you technical notices, statements, updates, security alerts, and support and administrative messages;
- Investigate any potential misuse of our Services or Platforms’ applications or websites, including criminal activity or other unauthorized access to our Services;
- Communicate with you about our Services or to inform you of any changes to our Services;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business;
- Comply with applicable law and regulation, including but not limited to those relating to Synapse Brokerage’s licensing requirements; and
- For any other purpose with your consent.
We may share the information that we collect about you in the following ways:
- To third parties to whom you authorize to access your account information or to place transactions in your account;
- With a joint account holder as applicable;
- For our everyday business purposes, such as processing your transactions, maintaining your account(s), or reporting to credit bureaus;
- With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, financial service providers, credit bureaus, or collection agencies;
- With other parties to transactions when you use the Services, such as other users, merchants, and their service providers. We may share your information with other parties involved in processing your transactions. This includes other users that you are sending or receiving funds from, and merchants and their service providers. This information might include: (i) information necessary to facilitate the transaction and (ii) information to help other participant(s) resolve disputes and (iii) detect and prevent fraud;
- To information technology providers or other service providers around the world that act under our instructions regarding the processing of certain data. These entities will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the information, and to process information only as instructed;
- To independent external auditors or other service providers around the world. Such service providers will be subject to any necessary contractual obligations regarding the protection and processing of such Personal Data;
- To support our audit, compliance, and corporate governance functions;
- To service providers to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law or regulation;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
- To any other person or entity where you consent to the disclosure.
In addition, depending upon the jurisdiction in which you reside we may rely upon other bases such as consent or contract. To the extent that you agree to our terms of service and enter into a contract with us, you acknowledge that the transfer is necessary for performance of that contract.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Services do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
We maintain commercially reasonable security measures to protect the Personal Data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee absolute security.
The Services are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal information from children under 16.
If you are in a country in the European Economic Area (EEA) or in the United Kingdom, you are entitled to the following explanation of the legal bases we rely on to process your Personal Data and a description of your privacy rights.
Legal Bases for Processing Your Personal Data
The legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
We may process your Personal Data based on your consent such as when you create an account or use a Platform to request a service. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
Our Legitimate Interests
We may process your Personal Data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your Personal Data to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities and to improve our services and the content and functionality of our Services.
To Perform a Contract
We may process your Personal Data to administer and fulfill contractual obligations to you.
To Enable Us to Comply with a Legal Obligation
We may process your Personal Data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.
Necessary for the Exercise or Defense of Legal Claims
If you bring a claim against us or we bring a claim against you, we may process your Personal Data in relation to that claim.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data for any specific processing activity, please contact us using the “How to Contact Us” section below.
Access Your Personal Data
Rectify Your Personal Data
You have the right to ask us to rectify any inaccurate Personal Data about you and to have incomplete Personal Data completed.
Restrict Our Use of Your Personal Data
You have the right to ask us to place a restriction on our use of your Personal Data if one of the following applies to you:
- You contest the accuracy of the information that we hold about you, while we verify its accuracy;
- We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
- We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
- You have objected to us using your information, while we check whether our legitimate grounds override your right to object.
You have the right to object to our use of your Personal Data where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).
Delete Your Personal Data
You can ask us to delete your Personal Data if:
- We no longer need it for the purposes for which we collected it;
- We have been using it with no valid legal basis;
- We are obligated to erase it to comply with a legal obligation to which we are subject;
- We need your consent to use the information and you withdraw consent;
- You object to us processing your Personal Data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.
If you do exercise a valid right to have your Personal Data deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
Transfer Your Personal Data to Another Service Provider
You may request that we transfer some of the Personal Data you have provided to you or another service provider in electronic copy. This applies to Personal Data we are processing to service a contract with you and to Personal Data we are processing based on your consent.
To exercise any of these rights, please contact us as described in the “How to Contact Us” section below.
Make a Complaint
If you have any concerns or complaints regarding our processing of your Personal Data, please contact us as described in the “How to Contact Us” section below and we will do our best to answer any question and resolve any complaint to your satisfaction.
If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority:
EU Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
Information Commissioner’s Office (United Kingdom)
Notice to California Residents
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA’s privacy rights described below do not apply to Personal Information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. The CCPA’s privacy-related rights also do not apply to certain types of Personal Information that is subject to the Federal Credit Reporting Act (FCRA).
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
Collection of Personal Information
For a list of the purposes for which we have collected this Personal Information, please see the “Collecting and Using Information – How We Use Your Personal Data” section above.
Disclosure of Personal Information
We do not knowingly collect or sell the Personal Information of minors under 16 years of age.
Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know and/or Delete
You may submit a request to know or delete by emailing us at firstname.lastname@example.org.
As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
Our Process for Verifying a Request to Know or Delete
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Depending on the jurisdiction in which you are located, you may have certain rights with respect to your Personal Data. For example, you may have the following rights:
- Right to access your Personal Data;
- Right to receive a copy of your Personal Data, including in a machine-readable format;
- Right to delete your Personal Data;
- Right to update your Personal Data;
- Right to correct inaccurate, out-of-date, or irrelevant Personal Data;
- Right to anonymization, blocking or deletion of unnecessary or excessive Personal Data or Personal Data processed in noncompliance with applicable law;
- Right to receive information about public and private entities with which we have shared your Personal Data;
- Right to information about the possibility of denying consent and the consequences of such denial;
- Right to revoke consent;
- Right to data portability;
- Right to confirm that we are processing your Personal Data;
- Right to restrict our processing of your Personal Data;
- Right to not be subject to automated decision-making;
- Right to a verification procedure that provides whether we are in compliance with the applicable law; and
- Right to object to or opt out of direct marketing from us.
For a description of the legal bases for which we collect your Personal Data, please see the section “Your Personal Data and Your Rights –Europe and the United Kingdom Only - Legal Bases for Processing Your Personal Data” above.
For questions or concerns about our privacy policies or practices, please contact us at:
Email Address: email@example.com
Synapse Brokerage LLC
2012 Northwest Military Highway
San Antonio, TX 78213