Privacy policy.

Last Updated: January 22, 2024 

GLBA Privacy Notice 

This Privacy Policy describes how Stackwell Capital, Inc. and Stackwell Capital Advisers, LLC  (collectively, “Stackwell”) handles the personal information of individuals to whom we may  market and provide our platform, as well as the information we collect on our website and application, from third parties, and from other sources.  

About Stackwell 

Stackwell provides individual consumers with financial advice, investment management, and  digital banking services. 

Information We Collect 

When you interact with our services, we may collect: 

• Account Information, such as your first and last name, email address, phone number, and  primary address.  

• Financial Information, such as your bank account number and credit or debit card  information. 

• Transaction Information, such as information about the transactions you make on our  services, including the type of transaction, transaction amount, and timestamp. 

• Correspondence, such as your feedback, questionnaire and other survey responses, and  information you provide to our support teams, including via our help chat. 

• Marketing information, such as your preferences for receiving communications about  our services and publications, and details about how you engage with our  communications. 

• Device Data, such as your computer’s or mobile device’s operating system type and  version, manufacturer and model, browser type, screen resolution, RAM and disk size,  CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language  settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 5G), and  general location information such as city, state or geographic area. 

• Online activity data, such as pages or screens you viewed, how long you spent on a page  or screen, browsing history, navigation paths between pages or screens, information  about your activity on a page or screen, access times, and duration of access, and whether  you have opened our marketing emails or clicked links within them.

• Social Media Information. We may maintain pages on social media platforms, such as  Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact  with our pages on those platforms, the platform provider’s privacy policy will apply to  your interactions and their collection, use and processing of your personal information.  You or the platforms may provide us with information through the platform, and we will  treat such information in accordance with this Privacy Policy.  

• Information We Get From Others. We may get information about you from other  sources as required or permitted by applicable law, including public databases. We may  combine the information collected from these sources with the information we get from  this application in order to comply with our legal obligations and limit the use of our  services in connection with fraudulent or other illicit activities. 

• Other Data not specifically listed here, which we will use as described in this Privacy  Policy or as otherwise disclosed at the time of collection. 

We use the following tools for automatic data collection: 

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify  the visitor’s browser or to store information or settings in the browser for the purpose of  helping you navigate between pages efficiently, remembering your preferences, enabling  functionality, helping us understand user activity and patterns, and facilitating online  advertising. 

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality  but can store larger amounts of data, including on your device outside of your browser in  connection with specific applications. 

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that  a webpage or email was accessed or opened, or that certain content was viewed or  clicked. 

How We Use Information 

We use your personal information for the following purposes: 

Service delivery, to: 

• Establish and maintain your account on the platform; 

• Conduct research and analysis relating to the platform, our application, and our business; 

• Process payments and complete transactions with you; 

• Communicate with you about the platform and our application, including by sending you  push notifications with announcements, updates, security alerts, surveys, offers, and  support and administrative messages; and

• Provide support for the platform, and respond to your requests, questions and feedback.

Research and development. As part of these activities, we may create aggregated, de-identified  or other anonymous data from personal information we collect. We may use this anonymous data  and share it with third parties for our lawful business purposes. 

Marketing and advertising. 

• Direct marketing: We may use the information we collect to market our services to you.  This may include sending you communications about our services, features, promotions,  surveys, news, updates, and events, and managing your participation in these promotions  and events. 

• Interest-based advertising: We may engage third-party advertising companies to display  our ads on their online services. We may also share information about our users with these  companies to facilitate advertising for our services to them or similar users on other online  platforms. For more information, or to understand your choices, please visit the Your Choices section below. 

Compliance and protection. We may use your personal information to: 

• Comply with applicable laws, lawful requests, and legal process, such as to respond to  subpoenas or requests from government authorities; 

• Protect our, your or others’ rights, privacy, safety or property (including by making and  defending legal claims); 

• Audit our internal processes for compliance with legal and contractual requirements and  internal policies; 

• Enforce the terms and conditions that govern our platform; and 

• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or  illegal activity, including cyberattacks and identity theft. 

How We Share Personal Information 

We may share your information with: 

Service providers. Companies and individuals that provide services on our behalf or help us  operate our platform or our business (such as hosting, information technology, customer support,  email delivery, and platform analytics services). 

Advertising partners. We may share personal information that we collect on our website with  third party advertising companies (including for the interest-based advertising purposes described  above), lead generation partners, and channel partners, resellers, and distributors that allow us to  explore and pursue growth opportunities.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers,  where necessary in the course of the professional services that they render to us. 

Authorities and others. Law enforcement, government authorities, and private parties, as we  believe in good faith to be necessary or appropriate for the compliance and protection  purposes described above. 

Business transferees. Acquirers and other relevant participants in business transactions (or  negotiations for such transactions) involving a corporate divestiture, merger, consolidation,  acquisition, reorganization, sale or other disposition of all or any portion of the business or assets  of, or equity interests in, Stackwell (including, in connection with a bankruptcy or similar  proceedings). 

Your Choices 

Access to information. To keep your information accurate, current, and complete, please contact  us as specified below. We will take reasonable steps to update or correct information in our  possession that you have previously submitted via the platform. 

Opt out of marketing communications. You may opt out of marketing-related communications  by following the opt out or unsubscribe instructions contained in the marketing communications  we send you. You may continue to receive service-related and other non-marketing  communications. 

Opt out of push notifications. If you opt-in to receive push notifications within the application,  we may send push notifications or alerts to your mobile device from time to time. You can  deactivate push notifications and alerts at any time by changing your device settings, changing the  push notification settings within the application, or deleting the application. 

Opt out of interest-based advertising. You may limit online tracking by: 

● Blocking cookies in your browser. Most browsers let you remove or reject third-party  cookies, including cookies used for interest-based advertising. To do this, follow the  instructions in your browser settings. Many browsers accept cookies by default until you  change your settings. For more information about cookies, including how to see what  cookies have been set on your device and how to manage and delete them, visit  www.allaboutcookies.org.  

● Blocking advertising ID use in your mobile settings. Your mobile device settings may  provide functionality to limit use of the advertising ID associated with your mobile  device for interest-based advertising purposes. 

● Using privacy plug-ins or browsers. You can block our websites from setting cookies  used for interest-based ads by using a browser with privacy features, like Brave, or  installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and  configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at:  https://tools.google.com/dlpage/gaoptout.  

● Platform opt outs. Some of our advertising partners offer opt out features that let you opt  out of use of your information for interest-based advertising, including: 

o Google: www.adsettings.google.com  

o Facebook: https://www.facebook.com/about/ads 

● Advertising industry opt out tools. You can also use these opt out options to limit use of  your information for interest-based advertising by participating companies: 

o Digital Advertising Alliance for Websites: outout.aboutads.info  

o Network Advertising Initiative: optout.networkadvertising.org  

Note that because these opt out mechanisms are specific to the device or browser on which they  are exercised, you will need to opt out on every browser and device that you use. 

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the  online services that you visit. We currently do not respond to "Do Not Track" or similar signals.  To find out more about "Do Not Track," please visit http://www.allaboutdnt.com. 

Other Sites and Services 

Our platform may contain links to websites and other online services operated by third parties. In  addition, our content may be integrated into web pages or other online services that are not  associated with us. These links and integrations are not an endorsement of, or representation that  we are affiliated with, any third party. We do not control websites or online services operated by  third parties, and we are not responsible for their actions. 

Information Security 

We employ a number of technical, organizational and physical safeguards designed to protect the  personal information we collect. However, no security measures are failsafe and we cannot  guarantee the security of your personal information. 

Children 

Our platform is not intended for use by children under 18 years of age. If we learn that we have  collected personal information through our platform from a child under 18 without the consent of  the child’s parent or guardian as required by law, we will delete it. 

Changes to This Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this  Privacy Policy, we will notify you by email or updating the date of this Privacy Policy and posting  it on the application.

How to Contact Us 

You can reach us by email at support@stackwellcapital.com or at the following address: 

Stackwell Capital, Inc. 

100 Summer St., Suite 1600

Boston, MA 02110