Guardian Fiduciary Accounting Services Inc. Privacy Policy: January 31, 2024

 

This document describes how Guardian Fiduciary Accounting Services Inc. handles the personal information we collect in connection with our website, app and other products and services which we refer to in collectively as Easy.

Personal Information We Collect

Information You Provide

Account information, such as your name, address, email, password, and mobile phone number, that you provide when you register for or sign into an Easy account.

Identity verification information, such as your date of birth, Social Security number and other government-issued identification numbers that we use to verify your identity, as may be required by law, for the delivery of certain services.

Financial information, such as your financial account details, bank account online login information, bank account and routing numbers and credit card information linked to your Easy account. We also collect information about your income activity, expense goals and spending data that you provide when using our products and services.

Payment information, including your name, payment card information, and billing information, that you provide when you purchase a product or service. This information is processed by our third-party payment processor Stripe. We do not have access to payment card numbers.

Information about your billers, such as the username and password you use to sign into your online accounts with your billers, biller account numbers and mailing addresses.

Information about your transactions with us and others, including information associated with your transactions such as amount received, amount paid for products or services, amounts transferred from one account to another account of yours or to another person, account balance, and merchant information.

Information that you voluntarily provide when using our products and services or through responses to surveys and questionnaires.

Feedback or correspondence, such as the information you provide when you contact us for technical support or provide us with feedback and suggestions.

Marketing information, such as your preferences for receiving communications about our products and services.

 

Information We Obtain From Other Sources

Online financial account information. When you link or connect your financial accounts or other third-party services to your Easy account, you direct the third-party service to send us information as controlled by that service or as authorized by you via your privacy settings on that service, such as your account information, account balances, and transaction history.

Other sources. We may obtain personal information such as contact details, product usage metrics, and demographic data from other companies or third parties, including advertising partners and data enrichment platforms, to help us recognize you when you use our products and services, to customize and improve your experience, and to monitor the performance of our marketing programs.

Automatic Data Collection

We may automatically collect data when you use our sites, products, and services. For information on the types of data we collect and how you can control our collection of this data, please see the “Analytics, Cookies, Web Beacons and Similar Technologies” section below.

How We Use Personal Information

Easy uses the personal information we collect to operate, improve, and personalize the products and services we offer, to run our business, to develop new products, or to market other products and services that we believe you might be interested in.

Specifically, we use personal information to:

Operate our business, including informing you about your account or providing security updates;

Improve your experience with our products and services;

Understand your needs and interests, and personalize your experience with the products and services;

Develop new products and services;

Advertise, promote, or market our or our partners' products and services;

Comply with applicable laws or respond to lawful legal process from law enforcement and government agencies; and

Protect Easy’s rights.

We may create and use de-identified information for our business purposes, including to comply with lawful requests from government agencies, to analyze the effectiveness of our products and services, to improve and add features to our services, and to analyze the general behavior and characteristics of users of our services. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes.

How We Share Personal Information

Except as described in this Privacy Statement, we will not, without your permission, sell, publish or share information you entrust to us that identifies you or any person.

We may share your personal information with:

Service providers. Companies and individuals that provide services on our behalf or help us operate our services or our business (such as hosting, information technology, customer support, security and fraud prevention, payment processors, email delivery, website analytics, identify verification, marketing and data enrichment services).

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.

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.

Parties you authorize. Third parties you access through our products and services.

Business transferees. If Easy is acquired by another company, or in the event of a merger, consolidation, change in control, transfer of assets, reorganization, or liquidation, we may transfer information about your relationship with us (including personal information) to the new owner. The new owner will assume responsibility for your personal information.

Security of Your Data

Easy takes the security of your data seriously. We use technical and administrative security measures such as, but not limited to, firewalls, encryption techniques, and authentication procedures, among others, to maintain the security of your online sessions. However, no security measures are failsafe, and we cannot guarantee the security of your personal information. Security of your data stored on your desktop or accessed other than through an Easy online service is your responsibility. You should help protect your data by protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. 

Data Retention

Easy may retain your personal information for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our services. We may retain your personal information longer in order to comply with our contractual obligations, to protect ourselves from any potential disputes or as otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of such information, the potential risk of harm from unauthorized use or disclosure of such information, the purposes for which we process it, and the applicable legal requirements.

Accessing Your Information

You may access, review, and update your name, e-mail address, user ID, password, and physical address any time. If you registered for third party services through us, you may access your personal information with such third-party services directly. You may choose to close or request that we delete your account at any time.

Communications Preferences

We may send periodic product or service-related alerts, weekly summaries, notifications, newsletters, promotions, or other information via phone, e-mail, in-product messaging and text. You may follow the unsubscribe instructions in promotional e-mail message you receive, and Desktop Easy software users can opt in or out of most types of in-product communication by accessing Preferences.

Your Usage Data

Usage Data Collection

When you first register, purchase, or activate Easy, we capture your information as specified in the product registration or purchase screens. On an ongoing basis, we collect basic information about your computer configuration and how you use Easy. In some cases, we may offer you third party products and services that can be accessed through Easy, or as part of an Easy service.

How We Use Usage Data

We may deploy our own technologies or use third parties to help us compile reports regarding your connection to, and use of, these products and services. These reports (including usage data) are sent to us to help us improve our products and services, to verify product or service functioning, to diagnose and correct problems, and to support our user base. These reports generally include information about things like computer configuration, such as computer type or monitor resolution; application use, such as the features, summaries of data that you use, or time spent on parts of our site; and other information that relates to usage patterns and third-party products and services that our users access through Easy.

How We Share Usage Data

We may share your information with vendors or partners who are under a contractual obligation to protect the privacy of this information, and who have a legitimate need to know the data (for example, to provide the service that we have contracted with them to provide, or to provide jointly offered products and services that we believe you might be interested in). We may also utilize usage data to determine what Easy products and services we think you would like to be informed of. You are always free to opt out from any marketing communications from us by following the unsubscribe instructions in our marketing e-mails.

We may share anonymous or de-identified usage information as described earlier under the heading, “How We Share Personal Information.”

Analytics, Cookies, Web Beacons and Similar Technologies

We may deploy our own technologies or use third parties to help us analyze usage of our products and services. These technologies are generally called “analytics.” For example, we may use analytics to help us measure the performance of our online promotions or analyze activity within our products. We may permit third parties who provide analytics services for us to use cookies and similar technologies to perform these services.

We use cookies and similar technologies, including app identifiers, to help us recognize you across different services, products, and devices; to learn about your interests both on and off our services; to improve your experience, increase security, and offer relevant products and services; and to measure use and effectiveness of our services and serve advertising.

These technologies may capture log information about you, your computer or mobile device, such as your computer’s or mobile device’s operating system, manufacturer and model, browser type, browser history, search history, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area.

Online Tracking Opt-Out

You may limit online tracking through a variety of means, including blocking cookies in your browser. 

You should be aware that some technologies are essential to operating Easy and you may not be able to disable or turn off their functionality. If you choose to reject cookies or similar technologies, some services may not be available, or some service functionalities may be limited or unavailable. Please review your browser manufacturer’s help pages for assistance with changing your settings.

By visiting our services, you consent to the placement of cookies and beacons in your browser and HTML-based e-mails in accordance with this Privacy Statement.

Opt Out of Push Notifications

If you opt in to receive push notifications within our apps, 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 app.

Desktop Software and Connected Services

Some Easy services or features running on your computer or mobile device may require an Internet or on-line connection. When you are connected to the Internet from within the software, we may also include product updates and messages, service information, and help content in the Internet transmissions. Web and mobile products and services may synchronize with the information on your desktop computer to help keep the data accurate and provide additional online services.

Location Data; Do Not Track

If you choose to use a product or service that uses information about your location, we may collect location information from your device and will notify you of this collection. You may control or disable the sharing of location information via your device setting and/or the service.

Minors

Easy does not knowingly collect information from minors. Easy products and services are not intended for minors.

Changes to Our Privacy Statements

We may update this Privacy Statement periodically. If we make material changes to the way we process your personal information, we will provide you notice via an update to the version of this Privacy Statement posted on our site, via website notification, or by email or in-product messaging.

Contact Us

If you have questions or concerns regarding this Privacy Statement, our security practices, or our information processing practices, please contact us by writing to gordon@guardianfas.com.


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