Privacy Policy

We take privacy seriously.

Last updated March 12, 2021

If you visit any of Quo websites, download or use the Quo App, apply for or receive a Quo Loan, use Quo Home, Quo Goals, Quo Savings or redeem Quo Rewards (together, our “Services”), Quo (“Quo,” “we,” “us,” “our”) will ask for, collect, and store personal information about you (your “Personal Data”). We would not be able to provide our Services to you without the Personal Data you provide us, which is why we want you to know that we take our responsibility to protect your Personal Data very seriously. We also want to make very clear how we use your Personal Data so that you can make informed choices about your use of our Services.

This document (our “Privacy Policy”) explains how we collect and use your Personal Data, how and with whom we share your Personal Data, and how we protect your Personal Data. This Privacy Policy applies to the Quo websites (the “Website”) and the Quo App, and is subject to the Quo Terms of Service available at https://quo.com/tos/. If you have questions about this Privacy Policy, or have suggestions for how we can improve it, please contact us at privacy@quo.com.

If you do not want us to collect Personal Data from you or share Personal Data with any third parties or otherwise disclose your Personal Data, you should not use the Quo App, apply for a Quo Loan, or use our Services.

1.Personal Data We Collect

In the table below, we provide the list of categories of Personal Data that Quo has collected within the last twelve months and some examples for a better understanding. We also have identified the main sources and purposes for collection:

Categories of Personal Data

Examples

Sources of Personal Data

Purposes for Personal Data Collection

Identifiers

First and last name and middle initial, date of birth, email address, mobile telephone number, mailing address, username, password, or other Quo Account access credentials.

Consumer directly (e.g. forms you complete or services you obtain from us)

 

Third parties (e.g., Alliance Reservations Network, LLC)

·       Keep track of the Personal Data associated with your Quo Account

·       Help you access and restore access to your Quo Account

·       Prevent others from accessing your Quo Account

·       Send administrative information to you

·       Keep track of your travel reward bookings

Customer Records

Unique identifiers associated with your bank including bank account names, bank routing and account numbers, bank account transaction history, social security numbers, driver’s license or other valid government photo identification, credit report.

Consumer directly (e.g. forms you complete or services you obtain from us)

 

Third Parties (e.g. credit reporting agencies)

·       Determine your eligibility for a Quo Loan

·       Calculate your Quo Rewards

·       Recommend other products and services to you

·       Permit our financial partners to verify your identity

·       Permit us and our financial partners to comply with applicable consumer protection laws

·       Provide Quo Services to you and our customers

Internet or other electronic network activity information

Browser type, IP address, computer or mobile device unique ID number, operating system, referring and exit pages, device event information.

Consumer indirectly (e.g. from activity on our websites or App)

·       Analytics

·       Advertising and marketing

·       To keep our websites and App safe and secure

·       Improve our services

Professional or employment-related information

Name, address and telephone number of your employer

Consumer directly (e.g. forms you complete or services you obtain from us)

 

·       Determine your eligibility for a Quo Loan

 

Geolocation Data

Approximate location based on IP address

Consumer indirectly (e.g. from activity on our websites or App)

·       Analytics

Characteristics of protected classifications under California or federal law

Marital status (Wisconsin only), military service history

Consumer directly (e.g. forms you complete or services you obtain from us)

 

·       Permit Quo and its partner financial institutions to comply with state consumer protection laws.

·       Permit our financial partners to comply with the Servicemembers Civil Relief Act.


2. Personal Data Shared with Third Parties

Except as described in this Privacy Policy and unless otherwise expressly authorized by you in writing, Quo will never share, sell, or communicate your Personal Data to or with anyone for any reason. We only share and disclose your Personal Data with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection.

Categories of third parties with whom Personal Data has been shared

Why we share your Personal Data

Is Personal Data shared for a business purpose?

Service Providers

 

We may share your Personal Data with service providers including third party vendors, consultants, contractors who perform services for us or on our behalf and require access to such information to do that work.

 

Specifically, we share your Personal Data with:

·       Twilio to verify your mobile phone number and address; and

·       Plaid to verify your bank account credentials and all other information associated with the bank account.

Yes

Purchasers of Our Business

We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Yes

Law Enforcement

We may share your Personal Data in order to comply, as necessary, with applicable laws and regulatory requirements, as well as legal process, respond to mandatory legal or governmental requests or demands for information, enforce our agreements, policies, procedures and terms of use, and protect ourselves, our customers, or the general public from illegal activities.

No

Payment Processors

We may share your Personal Data with our payment processors as necessary to enable them to process payments, and for anti-fraud purposes.

Yes

Business Partners and Quo Affiliates

We may share your Personal Data with our Business Partners as necessary to provide you with the Quo Services.

 

Specifically, we may share your Personal Data with:

·       SynapseFi LLC and other financial institutional partners in connection with Quo Loan and Quo Savings;

·       Even Financial, Inc and other financial partners so you can apply for a personal loans;

·       Alliance Reservations Network, LLC and other travel partners so you can access discounts as part of the Quo Travel program; and

·       Our mortgage broker affiliates so you can access a network of mortgage brokers as part of the Quo Home program.

Yes

3. Cookies and Trackers

We also use cookies and other activity tracking tools to help the Websites, Quo App and our Services work better. These tools allow us to:

• Provide you Services that allow you to email or chat with our customer service team

• Perform website analytics

• Improve the advertisements you see

• Prevent fraud and prevent attacks against our websites and Services

• Advertise Quo products and services, and additional products and services from our partner companies

We use cookies and trackers to assign you a unique identifier so we can record:

• Websites you visit

• Length of time the advertisement was visible

• IP Address

You can block cookies at any time using your web browser settings or Quo App settings, but doing so may limit your browsing experience and your ability to use certain features of the Quo App. We do not currently respond to “Do Not Track” or DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Quo also uses Google Analytics. The following link explains how Google uses data when you use its partners’ websites and applications: www.google.com/policies/privacy/partners/. Your use of Quo’s website is evidence of your consent to Quo storing and accessing cookies and other information on your computer or phone and Quo’s use of Google Analytics in connection with such activities. Please read the information at the link provided so you understand what you are consenting to.

4. Updating Your Personal Data

While we make every effort to ensure that all Personal Data we collect and store is accurate, complete, and up-to-date, you can help us by promptly notifying us if there are any changes to your information. You will be able to view and change aspects of your Personal Data by logging in to your Quo Account.

5. California Privacy Rights

As a California consumer, you have the following choices regarding our use and disclosure of your Personal Data subject to certain limitations under the California Consumer Privacy Act (“CCPA”):

  1. Right to know. You may request, up to twice in a 12-month period, the following information about the Personal Data we have collected, used, disclosed or sold about you during the past 12 months:
  2. the categories and specific pieces of Personal Data we have collected about you;
  3. the categories of sources from which we collected the Personal Data;
  4. the business or commercial purpose for which we collected the Personal Data;
  5. the categories of third parties with whom we shared the Personal Data; and
  6. the categories of Personal Data about you that we disclosed for a business purpose and sold to third parties, and the categories of third parties to whom the information was disclosed or sold.
  7. Right to delete. You may request that we delete the Personal Data we have collected from you, subject to certain limitations under the CCPA.
  8. Right to opt-out from sale of Personal Data. You have the right to opt-out of the sale of your Personal Data. We do not sell your Personal Data.
  9. Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

To submit a request to exercise any of the rights described above, you may email us at privacy@quo.com or fill out this online form. We will verify your identity before responding to your request by either verifying that the email address from which you send the request matches your email address that we have on file, or by requiring you to log into your account.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request under the CCPA on your behalf, we require the authorized agent to submit the following information so that we can confirm their authority to act on your behalf:

  1. Evidence of authorization to act on behalf of the California consumer: (1) California Secretary of State authorization, (2) notarized written permission from the California consumer, or (3) power of attorney.
  2. Evidence of identity of the California consumer: (1) first and last name, (2) email address, and (3) password.

NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL DATA TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING PRIVACY@QUO.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.

6. How We Protect Your Privacy

We are committed to protecting the privacy and confidentiality of your Personal Data. We limit access to your Personal Data to our authorized employees or agents and we contractually require our business partners and service providers to limit their use of your Personal Data. We also maintain physical, technical, and administrative safeguards to protect your Personal Data against loss, misuse, damage or modification, and unauthorized access or disclosure.

7. Social Media

The Quo websites and the Quo App may include social media features, such as the Facebook “Like” or “Share” buttons. These features may collect your IP address and which pages or features you are using or visiting on the Quo website or the Quo App, and may set a cookie to enable the feature to function properly. Social Media features are either hosted by a third-party or hosted by us. Your interactions with these features are governed by the privacy policy of the company providing them. We do not control and we take no responsibility for the use of your Personal Data by these third-party sites.

8. Third-Party Links

The Quo websites and the Quo App may contain links to other websites or apps. Your access to and use of such linked sites is not governed by this Privacy Policy but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the Personal Data practices of such third-party websites. Please review the privacy policies of such sites before you disclose your Personal Data to them.

Synapse is our backend software provider, and partners with financial institutions to provide FDIC insurance. Synapse’s API, and their relationship with financial institutions, enables us to offer banking services and products. By agreeing to Quo’s Terms of Service and Privacy Policy, you also agree to Synapse’s terms and policies below:

  1. https://synapsefi.com/tos
  2. https://synapsefi.com/privacy

9. Children’s Privacy

The Quo websites and the Quo App are not intended for children. We do not knowingly collect, use, sell, or share any Personal Data from anyone under the age of 16. If we become aware that a child under the age 16 has provide Data to us, we will delete it.

10. Changes to this Privacy Policy; Other Policies

We may change this Privacy Policy from time to time to reflect changes in our practices concerning the collection, use, and sharing of Personal Data. The revised Privacy Policy will be effective immediately upon posting to the Quo websites, by notification through the Quo App or through email. If you continue to use the Quo websites and the Quo App after we make changes then you will be deemed to have agreed to the changes, so please check this Privacy Policy periodically for updates.

11. Contact Us

If you have any questions or concerns about this Policy, please contact: privacy@quo.com

12. NOTICE TO NEVADA RESIDENTS.

We are providing you this notice pursuant to Nevada law. You may be placed on our internal Do Not Call List by calling 628-777-3934 by writing to us at 2225 E Bayshore Rd., Suite 200, Palo Alto, CA 94303. For more information, contact us at the address above or email privacy@quo.com. You may also contact the Nevada Attorney General’s office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste. 3900, Las Vegas, NV 89101; telephone number: (702) 486-3132; email BCPINFO@ag.state.nv.us.