Last updated on Sep 14, 2018.
FDIConnect provides aggregation services to users who wish to distribute their investment funds across multiple qualified banking institutions while managing such from a single account (“Service” or “Company Service”) via the Company website(s) offered from time to time at https://www.fdiconnect.com (collectively, the “Site,” or “Sites”). The Company Service is owned and operated by Fortress Deposits Inc. (“Company”, “we” or “us”).
2. Types and Uses of Collected Information. Company collects two types of information about you:
2.3 Mobile Data. Most of the other information we collect for mobile, such as your mobile device identification and mobile device type, the request type, your mobile carrier, your mobile carrier user identification, and the content of your request, does not by itself identify you to Company, though it may be unique or consist of or contain information that you consider personal.
3. How we use your personal data.
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process, and
(b) the purposes for which we may process personal data.
3.2 We may process data about your use of our website and Services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services.
3.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
3.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services.
3.5 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services.
3.6 We may process information contained in any inquiry you submit to us regarding the Services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling the Services to you.
3.7 We may process information relating to the Services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include first and last names, an email address to be used as a login, bank account information, and a password. The transaction data may be processed for the purpose of supplying Services and keeping proper records of those transactions.
3.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
3.10 If you exchange messages with others through the Service, we may store them to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to the operation and use of the Company Service. We may not deliver messages that we believe are objectionable, such as spam messages or requests to exchange reviews for compensation. If you send or receive messages through the Company Service via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business listed on the Company Service, we may contact you, including by phone or email, using the contact information you provide us, make publicly available, or that we have on record for your business.
3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.13 Please do not supply any other person's personal data to us unless we prompt you to do so and have that person or person’s authorization to do so.
4. Providing your personal data to others.
4.1 We will not sell your Personally Identifiable Information with other parties, except as may be required by law.
4.2 We may disclose your personal data to any member of our group of companies, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.3 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.4 We may disclose your inquiry data to one or more of those selected third-party suppliers of services via APIs as identified on our website, if any, for the purpose of enabling them to connect your account with their Services.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.6 We may, with your authorization, share your personal data with your CPA or other trusted advisor.
5. Release of Non-Personally Identifiable Information.
5.1 We may disclose or share Non-Personally Identifiable Information with Third Party Service Providers and the public. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) or use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our users to administer the Company Service. We may also publish this aggregated information for promotional purposes. Such data is collected on our behalf and is owned and used by us.
5.2 We may use Third Party Service Providers to serve ads when you participate in the Company Service. These companies may use Non-Personally Identifiable Information about your visits and use of the Company Service, and visits to other websites or locations to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.
6. Updating Information. If you are enrolled in the Company Service and have created an account, and you have a change to any of your Personally Identifiable Information, please email us with the changes. Or you can ask us to change this information by sending us a letter at the address at the end of this document. We encourage you to promptly update your Personally Identifiable Information if it changes, as out-of-date Personally Identifiable Information may negatively affect the quality of your Company Service experience.
7. Choices on Collection/Use of Information. You can always choose not to provide certain information, although a certain level of information is required to engage and participate in the Company Service.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies used by our service providers
10. Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Security of Information.
11.1 You may be able to access your Personally Identifiable Information via the Company Service with your password and username. This password is encrypted. We advise against sharing your password with anyone. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If we believe that the security of your information may have been compromised, we may seek to notify you of that development.
11.3 Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit card number, bank account information or other financial information, you should not send it electronically unless the email is encrypted, or your browser indicates that the access to our website is secure.
13. Notice of Privacy Rights to California Residents. California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (“COPPA”) and the California Business and Professions Code. As required by COPPA, we will provide you with the categories of Personally Identifiable Information that we collect through the Company Service and the categories of third party persons or entities with whom such Personally Identifiable Information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of Personally Identifiable Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. COPPA further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or physical mail to the address found below. When contacting us, please indicate your name, address, email address, and what Personally Identifiable Information you do not want us to share with our marketing partners. The request should be sent to the attention of our legal department and labeled “California Customer Choice Notice.” Please allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your Personally Identifiable Information or requesting this notice.
14. Children. The Company Service are not directed to people under the age of eighteen (18). If you become aware that your child has provided us with personal information without your consent, please contact us at the email address listed below. If we become aware that a child under this age has provided us with personal information, we take steps to remove such information and terminate the child’s account.
5000 Birch St., West Tower, Suite 3000 Newport Beach, CA 92660
FDIConnect is a consumer-focused provider of FDIC pass-through insurance for bank deposits. Through the Fortress Account, clients have access to our network of 400 of the highest yielding FDIC member banks in the nation. This access allows our clients the peace and mind of insuring their entire cash balance (up to $50 million per account) while receiving 10x the average money market rate.