Foyer Holdco Inc. (“Foyer,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us in using our mobile application and website (collectively, the “Platform”) and the services provided through the Platform (collectively, “Services”).
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 GLBA Consumer Privacy Notice (provided below), which offers you certain choices with respect to the use and sharing of your personal information.
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage with an updated “Last Modified” date above. Please review this Privacy Policy periodically.
We collect Personal Information from you through your use of the Platform and Services. “Personal Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personal Information:
We may collect the following Personal Information that you voluntarily provide to us:
• To create an account on the Platform, you will provide us with certain Personal Information, which may include your first and last name, phone number, and email address. You will also need to establish a username and password for future sign ins.
• We are partnered with Pacific West Bank to provide banking services through our platform. To open a deposit account with Pacific West Bank (“Pacific West”) through the Platform, you will provide us with your legal name, email address, phone number, date of birth, Social Security number, physical address, and a copy of your driver’s license or other form of identity. We also use Unit Finance Inc. (“Unit”), a third party service provider to us, to enable us to offer banking services and products with Pacific West. Unit and Pacific West will also receive this personal information. Unit’s privacy policy is available here and Pacific West’s privacy policy is available here.
• To deposit money into your deposit account with Pacific West, through the Platform, you will provide us with your bank account information, including but not limited to the financial institution name, account name, account type, account ownership, account number, and routing number. We use Plaid to enable us to offer this banking service. Plaid’s privacy policy is available here.
• To interact with the Platform or Services, you may send us feedback, questions, comments, suggestions, ideas or interact with us in any other way, and you may need to provide us with your log-in information, name and email address.
• To apply for a job, you will provide us with your name, email address, and any other Personal Information that you may provide in your resume or featured on your LinkedIn profile.
• To contact us, you will provide us with your name and email address.
We automatically collect certain Personal Information through your use of the Platform and Services, such as the following:
•We collect usage information, such as which of the pages on the Platform you access, the frequency of access and what you click on while on the Platform.
• We collect information about the device you are using to access the Platform, such as hardware model, operating system, application version number and browser.
• In addition to the device information listed above, when you access the Platform on your mobile device, we collect and aggregate information about whether you are accessing the Platform via a mobile device or tablet, device type and carrier.
• We collect location information from Platform visitors on a city-regional basis.
In some cases, we may receive certain Personal Information from you about a third party including those of real estate service providers or mortgage lenders you may be currently working with. For example, as part of our account registration process, you may provide the name, email address, and phone number of a third party. If you submit any Personal Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy.
We use the Personal Information we collect to provide the Platform and Services to you, to improve our Platform and Services, and to protect our legal rights. In addition, we may use the Personal Information we collect to:
• Process your account registration;
• Provide you with the option to open a deposit account;
• Provide the Foyer Match;
• Provide you with the option to make deposits to your deposit account; • Provide you with a Foyer Home Account and related services and features; • Provide you with gift contributions from family and friends;
• Provide you with the option to pursue a mortgage;
• Contact you regarding our products and services that we feel may be of interest to you;
• Communicate with you about the Platform or Services or to inform you of any changes to the Platform or Services;
• Provide support;
• Maintain and improve the Platform and Services;
• Defend our legal rights and the rights of others;
• Efficiently maintain our business; and
• Comply with applicable law.
We may share the Personal Information that we collect about you in the following ways:
• With service providers who perform data or Platform-related services on our behalf (e.g. hosting, maintenance, backup, analysis, etc.);
• With mortgage lenders in connection with the Foyer Match;
• With real estate agents who you may decide to contact through the Platform; • To service providers to prepare, deploy and analyze advertising content;
• To the extent that we are required to do so by law;
• 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 person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information;
• To any other person or entity as part of any business or asset sale; and • To any other person or entity where you consent to the disclosure.
You acknowledge and agree that Foyer may receive certain incentive compensation from mortgage lenders and real estate agents with which we share your Personal Information.
Like many other businesses, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).
We use Cookies to:
• Estimate audience size and usage patterns;
• Understand and save your preferences for future visits, allowing us to customize the Platform and Services to your individual needs;
• Advertise new content and services that relate to your interests; • Keep track of advertisements and search engine results;
• Compile aggregate data about Platform traffic and interactions to resolve issues and offer better Platform experiences and tools in the future; and
• Recognize when you return to the Platform.
We set some Cookies ourselves and others are set by other entities. We use Cookies set by other entities to provide us with useful information to help us improve the Platform and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Crashlytics, and other similar companies.
Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Platform.
You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.
You can opt out of Cookies set by specific entities by following the instructions found at these links:
Google: https://adssettings.google.com
Facebook: https://www.facebook.com/about/ads
Twitter: https://twitter.com/personalization
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
We also use mobile advertising identifiers (e.g., Apple’s Identifier for Advertising (“IDFA”) or Google’s Android Advertising Identifier (“AAID”)). Most mobile devices include an identifier that allows application publishers, such as us, and marketers to track user activity on mobile devices for advertising purposes. We use mobile advertising identifiers for the same purposes for which we use cookies.
We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Platform and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning
visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.
To ensure that your Personal Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use Unit and Plaid, banking application programming interfaces, and Twilio, a cloud communications platform.
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 Platform does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
Review and Request Changes to Your Personal Information: You may use your account to access, correct, or view certain Personal Information we have collected and which is associated with your account. To review or request changes to any of your Personal Information, please contact us at support@foyersavings.com. .
Marketing Communications: To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at support@foyersavings.com.
We maintain commercially reasonable security measures to protect the Personal Information 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 Information, we cannot guarantee absolute security.
The Platform and Services may contain links that will let you leave the Platform and access another website. Linked websites are not under our control. This Privacy Policy
applies solely to Personal Information that is acquired by us on the Platform. We accept no responsibility or liability for these other websites.
The Platform and Services are not intended for individuals under eighteen (18) years of age. We do not knowingly collect, use or disclose personal information from individuals under eighteen (18) years of age.
To contact us for questions or concerns about our privacy policies or practices please email us at support@foyersavings.com. or contact us at:
Foyer Holdco Inc.
253 Elizabeth Street
New York, New York 10012
10. GLBA CONSUMER PRIVACY DISCLOSURE. The disclosure that follows directly below is only applicable to Foyer customers and those consumers who have previously attempted to sign up for Foyer's products and services. It DOES NOT apply to consumers who make financial contributions to a Foyer customer via a unique webpage link or to any consumer visiting the Foyer website or mobile application who is not a Foyer customer or an individual who has previously attempted to sign up for Foyer products and services.
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
▪ Social Security number and income
▪ payment history and employment information
▪ credit history and credit scores
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Foyer Savings chooses to share; and whether you can limit this sharing.
For our everyday business purposes –
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes
No
For our marketing purposes –
to offer our products and services to you
Yes
No
For joint marketing with other financial companies
No
We don't share
For our affiliates’ everyday business purposes –
information about your transactions and experiences
No
We don't share
For our affiliates’ everyday business purposes –
information about your creditworthiness
No
We don't share
For our affiliates to market to you
No
We don't share
For nonaffiliates to market to you
No
We don't share
To Limit Sharing
Call (646) 360-0591 – our menu will prompt you through your choice(s) or
Visit us online: support@foyersavings.com
Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions
Call (646) 360-0591 or go to www.foyersavings.com.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We collect your personal information, for example, when you:
▪ apply for a product or service
▪ provide account information or pay your bills
▪ give us your contact information
We also collect your personal information from others, such as credit bureaus, affiliates or other companies.
Federal law gives you the right to limit only
▪ sharing for affiliates’ everyday business purposes – information about your creditworthiness
▪ affiliates from using your information to market to you
▪ sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
You choices will apply to everyone on your account.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
▪ Foyer Savings does not share with its affiliates.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
▪ Nonaffiliates we share with can include (insert as necessary).
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
▪ Foyer Savings doesn’t jointly market.
