Eco Privacy Policy

Privacy Policy

Effective May 10, 2022

Eco, Inc. (together with its affiliates and subsidiaries, “Eco”, “we”, “us” and “our”) respects and protects the privacy of visitors to our website and our customers. This Privacy Policy describes the type of information that we collect from you - as well as our practices for using, protecting, and disclosing that information. This Privacy Policy covers all of your interactions with Eco, whether through www.eco.com or any other websites, pages, or content we own or operate (collectively, the “Site(s)”, your use of the Eco mobile application, our communications with you, or any other products or services provided to you by Eco (collectively, the “Services”).

Please read this Privacy Policy carefully before using the Site or accessing any of the Services.

We may supplement this Privacy Policy with the following:

• Our Sharing of Information Disclosure. Our Sharing of Information Disclosure describes further how we collect, use, and disclose certain of your information. Our Sharing of Information Disclosure is updated annually.

• Specific Terms Agreed to by You. If you qualify to participate in one or more Eco products or services, we may ask you to enter into one or more supplemental agreements with us. In that event, the terms contained in those agreements will supplement the below provisions relating to the collection, use, sharing, and securing of your information.

• Other Supplemental Notices. Additionally, we may supplement this Privacy Policy with other supplemental notices posted on specific web pages within the Site or within the Eco mobile application. These supplemental notices describe in more detail the information we collect via particular pages or services on the Site.

• Partner Privacy Policies. Some of the Services that Eco provides are offered in partnership with third parties. As part of accessing those Services you may be required to agree to additional terms and conditions directly with such third parties which supplement how Eco and those third parties share information in order to offer such Services.

ACCEPTANCE OF THIS PRIVACY POLICY

By accessing any of our Services, you are agreeing to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should discontinue your use of the Site or any Services.

AMENDMENTS TO THIS PRIVACY POLICY; CHANGES TO YOUR INFORMATION

We may change this Privacy Policy or any supplemental notices or policies at any time to reflect changes in our practices. Such changes will not be effective until the revised Privacy Policy or other materials are posted on the Site. If we make a significant change, we will also notify you via e-mail or other electronic communication.

It is important to keep any information that you provide to us up to date. If any information that you have submitted to us in connection with your use of the Services changes, it is your duty to update such information or notify us of the change.

INFORMATION WE COLLECT

Eco collects information that identifies you as well as other types of information about your activities on the Site and while using the Services. We describe each of these categories of information, and how we collect each of these categories, in more detail below.

• Information You Provide Us. We collect information that you provide us, including things like:

  • Personal Information. This includes things like your name, phone number, email address, physical address.

  • Identity Verification Information. In order to verify your identity we may require you to provide us with certain government issued identification such as a driver’s license or passport.

  • Security Information. To keep your information and account secure, we will require information such as your username and password.

  • Financial Information. To facilitate deposits, withdrawals and other transactions, you may be required to provide us with your bank account information, payment card information and related details.

  • Other: From time to time you may provide us with other information about you as part of customer support correspondence, feedback surveys, and other interactions between you and Eco.

• Information Collected Automatically. Certain other information will be collected automatically while you are using the Site or the Services, including things like:

  • Browser-Based Information. We use “cookies”, “pixel tags,” “web beacons,” and other technologies to collect information about your use of the Site. We use this information to improve the quality of our Services, to keep our Site secure, and to make your experience on the Site more meaningful and intuitive (for example, by remembering your preferences or providing you with a localized experience).

  • Online & Device Identifiers. This includes things like which device, operating system and browser you are using, IP address, location data, and device event information like Site crashes and the date and time of actions taken on the Site.

HOW WE USE YOUR INFORMATION

We collect and process your information for a number of reasons, including:

• To provide you with the Services. We cannot provide the Services to you without collecting certain personal and financial information. For example, in order for you to complete certain transactions between your bank account and your Eco mobile application, we need to gather information related to your bank and that transaction.

• To comply with legal requirements. Eco is subject to various legal and regulatory compliance obligations that require us to verify your identity in connection with providing the Services.

• To keep your account secure. In order to make sure that only you can access your account and to prevent fraudulent transactions, we need to verify your identity and your security credentials during log-in and in connection with completing certain transactions.

• To provide you with customer support. In order to communicate with you and troubleshoot any potential issues or answer any questions you might have, we need to be able to access certain information you provide to us or that we collect through your use of the Site and the Services.

• To improve Eco. In order to improve the Services we provide we need to know what is working (and what isn’t) so that we can combine that feedback and information with that of other customers to make changes.

HOW WE SHARE YOUR INFORMATION

Eco will never sell your personal information to a third party without your permission. We only share your information with third parties where we have a legitimate need to do so in order to provide you with the Services. We will only share your information for the following purposes:

• Identity & Payment Processors. We work with third parties to verify your identity and to process transactions within your Eco account. For example, you may use Plaid, Inc. (“Plaid”) to connect your Eco account to your bank account, verify your bank account, and confirm balance details. Any information that is shared with Plaid is treated in accordance with this Privacy Policy as well as Plaid’s Privacy Policy, available at https://plaid.com/privacy.

• Custody Partners. Eco partners with third parties to provide secure custody of your account balance. In addition to you directly agreeing to any terms and conditions from such partners, Eco may need to share certain account information with such third parties to verify and process transactions within your account.

• Service Providers. We contract with certain trusted third party consultants and vendors as part of our business operations. Our agreements with these third parties require them to only use your information in connection with the Services and to protect your information. These include third parties such as cloud storage providers, information technology firms, customer support software providers, and marketing partners.

• Professional Advisors. We may need to share your information with legal, accounting, compliance, insurance and other professional advisors in connection with complying with our legal obligations and business requirements.

• Potential Acquirors. In connection with, or in anticipation of, any sale, merger, financing or acquisition of Eco, we may need to share information as part of such process.

• Legal Processes. In connection with a valid legal request, to prevent fraud, and to protect our legal interests we may be required to share your information.

• Other. We may otherwise share your information if you give us permission or instruction to do so.

HOW WE PROTECT YOUR INFORMATION

Eco has implemented measures intended to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. You also play an important role in maintaining the safety and security of your information. Where we have given you access credentials, such as a username and password, you are responsible for keeping these credentials confidential. Unfortunately, the transmission of information via the Internet is not completely secure, and no company, including Eco, can fully eliminate security risks. Although we have implemented measures to protect your information, we cannot guarantee the security of your information transmitted to or from us, including via email, or the security of any links accessible from our Site.

HOW YOU CAN OPT OUT OF CERTAIN PRACTICES

In addition to the circumstances described above, from time to time, we may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, under certain circumstances, or from allowing us to use your Personal Information for a purpose that is incompatible with the purposes for which we originally collected it, or subsequently obtained your authorization, by reaching out to support@eco.com or by mail as provided for in the Sharing of Information Disclosure. If you choose to limit the use of your Personal Information, certain features or services may not be available to you.

THIRD PARTY SITES

This Site may, from time to time, contain links to websites owned and operated by third parties (“Third-Party Sites”). We encourage you to review the privacy policies of such Third-Party Sites so that you understand how those websites collect, use, and share your information. We are not responsible for the privacy notices, practices, or other content on Third-Party Sites.

NON-U.S. SITE VISITORS

This Site is intended for use by residents of the United States of America only. You should be aware that the United States and other countries have not harmonized their privacy regulations. This Privacy Policy is intended to comply with United States requirements. By using the Site, you agree to the level of privacy protection set out in our Privacy Notice.

CHILDREN’S INFORMATION

Eco does not knowingly collect personal information from any person under the age of 18.

ACCESS TO YOUR INFORMATION

You can update, modify, or delete personal information you’ve provided to us by emailing Eco at support@eco.com. We may retain certain information as required by law or for necessary business purposes.

California Civil Code Section 1798.83 permits Site users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

CONTACT US

If you have any questions or concerns, please do not hesitate to contact us.

Eco, Inc.

2261 Market Street, #4348

San Francisco, CA 94114

Attn: Legal Department

support@eco.com