Privacy Policy

Date Last Revised: August 9, 2011
At Tradeoff, LLC ("Tradeoff" or "we" or "us") your privacy is important to us. Please take a moment to familiarize yourself with our privacy practices. This Privacy Policy (the "Policy") explains how we protect your personal information when you use our UrgeTM iPhone application ("Urge") and how we use that informatio¬n in connection with the services offered through Urge (the "Service"). We may update or modify this Privacy Policy periodically. The date last revised appears at the top of the Policy. Changes take effect immediately upon posting.

Collection and Use of Personal Information
"Personal Information" for purposes of this Policy means information that identifies you, such as your name, address, phone number, bank account information, or email address. In order to use Urge, you will need to register for an account, which involves providing a Personal Identification Number (PIN) required to register for the Services (collectively the "Registration Information"). You also must provide third-party account information ("Account Information") to allow us to access your account data at those financial institutions where you have bank accounts ("Account Information") in order to use the Services. All Registration Information, Account Information, and any other Personal Information entered by you is stored in an encrypted manner on your device and is used in order to operate and provide the Services. We do not store your personal information on our servers beyond the time that is required to complete a transfer of funds from your account.
We collect data on an aggregated basis. This information does not specifically identify you. For example, we collect data that tells us how much consumers have saved as a result of using Urge. We use this data to create products and services for you. We do not share any data with third party advertisers. We may use third party vendors or service providers to help us provide the Service to you, such as operating a particular feature or functionality of the Service. For example, we partner with Buxfer Inc., a third party company, that we use to provide account discovery and facilitate transferring funds between your bank accounts. Such third parties are prohibited from using any Personal Information for purposes unrelated to the Service. We require such third parties to maintain the confidentiality of the information we provide to them and information to which they access.

Your Privacy is Not for Sale
We do not and will not sell or rent your personal information to anyone, for any reason, at any time. We use and disclose your personal information only as follows:
• to analyze usage and improve the Service;
• to deliver to you communications relevant to your use of the Service;
• for research, planning, detecting and protecting against error, fraud or other criminal
activity;
• to third-party service providers that provide services to us and are bound by these same privacy restrictions; and
• to enforce Terms of Use or other policies that govern the Urge Service.
Notwithstanding the foregoing, we reserve the right to share or disclose your personal information when we determine that the disclosure of such information is necessary or appropriate:
• when required by any applicable law, rule regulation, subpoena or other legal process;
• to enforce our rights against you or in connection with a breach by you of this Privacy Policy; or
• to prevent prohibited or illegal activities.

Registration Information and Account Information
We recommend that you create a PIN that is unique to you and to which you are the only one privy. Please see the information under FAQs to get details relating to how to change your PIN. You are responsible for maintaining the security of your PIN. You should not provide this information to any third party. If you believe that it has been stolen or been made known to others, please change your PIN immediately via the Service. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Policy.

Your Data is Secure
In order to provide the Services, we store and transmit your information in a secure manner using 256-bit AES encryption that exceeds banking industry standard.
We maintain the security of your online session to protect Urge accounts from unauthorized access. When you register for the Service, we require a PIN from you for your privacy and security. We transmit information transmitted through the Service securely. We encrypt your PIN and online banking information so that it cannot be recovered easily.

Change of Control
Personal Information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control. If we sell, merge, or transfer any part of our business, part of the sale may include your personal information.

Questions or Concerns
If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, send an e-mail to support@myurge.com and write "Privacy Policy" in the subject line.

Date Last Revised: August 9, 2011

 

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