Wolfia Inc. Privacy Policy

Last updated: January 16, 2024

This Privacy Policy discloses the practices of Wolfia Inc. (“Wolfia,” “we,” “us,” or “our”) concerning the Personal Information (as defined below) we obtain by and through your access and use of the Wolfia website (https://www.wolfia.com/). The website allows access to the Wolfia Platform which enables financial institutions to continuously monitor the compliance for specific regulations including Regulation E, Anti-money laundering or Bank Secrecy Act.

Wolfia is committed to protecting your privacy. This Privacy Policy sets forth the online data collection and usage policies and practices that apply to the Wolfia Platform. This privacy policy does not apply to any third-party websites, services or applications, even if they are accessible through the Wolfia Platform.

By using the Wolfia Platform, you are accepting and consenting to the use of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use the Wolfia Platform. Please review this Policy carefully.

This policy is supplemental to, and forms an integral part of, the Wolfia Terms of Service (Wolfia Terms), and is effective upon its incorporation into Terms of Service. The terms of this policy shall follow the Wolfia Terms. Defined terms not defined in the Privacy Policy shall have the same definition as in the Wolfia Terms.

1. Changes to the Privacy Policy

The effective date of this Privacy Policy is set forth at the top of this page. We may occasionally update this Privacy Policy to reflect company and customer feedback. We encourage you to periodically review this Privacy Policy to be informed of how we are protecting your information. We will endeavor to provide you with advanced notice of any material changes to the Privacy Policy. By continuing to use the Wolfia Platform after such changes take effect, you agree to be bound by the modified Privacy Policy. If any such changes materially alter your rights, we will notify you of these changes, by posting notice on the Wolfia website or by sending you an email to the email address we have on file for you. We will not make changes that have a retroactive effect unless we are legally required to do so.

2. Your Responsibilities

Within the scope of the Wolfia Terms and in its use of the Wolfia Platform, End User (as defined in the Wolfia Terms) shall be responsible for complying with all requirements that apply to it under applicable data protective, privacy, and security laws with respect to your processing and transmittal of information to Wolfia. You acknowledge and agree that you shall be solely responsible for:

  • Accuracy, quality, and legality of any information, including any user content;
  • Complying with all necessary laws concerning the collection and use of user content, including obtaining any necessary consents and authorizations;
  • Ensuring You have the right to transfer, or provide access to, the user content to Wolfia for purposes of providing the Wolfia Platform under the Wolfia Terms.

What We Mean by Personal Information

For purposes of this Privacy Policy, “Personal Information” means any information from or about a person or household that either identifies a person directly or that makes a person identifiable when it is combined with other information from or about that person from any source.

What Information We Collect About You

We collect information about you when you provide it to us, when you use our Wolfia Platform, and when other sources provide it to us, as further described below.

Information that is necessary for the use of Wolfia and its Wolfia Platform

We ask for and collect the following Personal Information about you when you use the Wolfia Platform, including transferring any such information to our third-party payment processing service to facilitate use of the Wolfia Platform. We use this information for the purposes of providing our services, responding to any queries you may have, operating and improving the web site, fostering a positive user experience and delivering the products and services that we offer. This information is also necessary for us to comply with various legal obligations. If you choose not to provide this information, we cannot provide you with access to the Wolfia Platform.

  • Account Information. When you use third party login credentials to login to or access the Wolfia Platform, we require and have access to your email address or username.
  • Device Information. Depending on how you access the site, we may collect information regarding the type of device on which the Wolfia Platform are used or downloaded, the operating system name and version of the device used to access the Wolfia Platform, device manufacturer, application version accessed on your device, device ID, IP address, and geolocation data.
  • User Content. This consists of all End User applications, text, documents, or other content or information uploaded, entered, or otherwise transmitted by you in connection with your use of the Wolfia Platform.

Information you provide to us

At any point you may choose to provide us with additional personal information in order to obtain a better user experience when using the Wolfia Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent. This information includes:

  • Transaction and customer information uploaded to our platform including other information related to the financial regulation we are monitoring.
  • Your personally identifiable information, including account profile information, and connection information when using the Wolfia Platform including IP address, operating system, and browser type of the connecting device.
  • Depending on how you choose to use the Wolfia Platform, you may provide us with contact information such as your: name, email address, and profile picture. We do not require your profile picture to be an actual picture of yourself.
  • Financial information. To purchase our Services, you may need to provide a valid payment method (i.e., credit or debit card) and its associated account information (“Payment Information”). Your Payment Information will be collected and processed by our authorized payment vendors. We do not directly collect or store your Payment Information in the ordinary course of processing transactions. That Payment Information is provided directly to Our third-party payment processors whose use of your Personal Information, including Payment Information” is governed by their Privacy Policies.

You may otherwise choose to provide us information when you fill in a form, update or add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care or support team, share your experience with us, or use other features of the Wolfia Platform.

Information we collect automatically when you use the Wolfia Platform

When you use the Wolfia Platform, we automatically collect certain information about your usage of the Wolfia Platform and how you use the Wolfia Platform. This information is necessary to ensure the best Wolfia Platform experience is available to you as well as enable us to comply with any applicable legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Wolfia Platform.

  • Location Information. To better effectuate that service and provide Customers with the best experience, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. You can control the information Wolfia may connect in your mobile device’s settings menu. Wolfia may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
  • Usage Information. We collect information about your interactions with the Wolfia Platform such as the pages or content you view, your searches, and communications.
  • Log Data and Device Information. We automatically collect log data and device information when you access and use the Wolfia Platform, even if you have not created an account or logged in. That information includes, among other things: details about how you’ve used the Wolfia Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Wolfia Platform.
  • Cookies and Similar Technologies. To collect information contemplated in this section, may use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer or device; (ii) store your preferences and settings; (iii) understand the web pages of the Wolfia Platform you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Site and to tell us how and when you interact with our Wolfia Platform. We may also use Cookies to monitor aggregate usage and web traffic routing on the Wolfia Platform and to customize and improve the Wolfia Platform. Unlike persistent Cookies, session Cookies are deleted when you log off from the Wolfia Platform and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you do not accept Cookies, you may not be able to access all portions or features of the Wolfia Platform. Some third-party service providers that we engage may also place their own Cookies on your hard drive. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties. “Flash Cookies” are local stored objects used to collect and store information about your preferences and navigation to, from, and on the Wolfia Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies.

Information we receive from third parties in connection with the Wolfia Platform

Please note that we may use certain third-party service providers and business partners on the Wolfia Platform to enhance your experience or deliver certain services. Such third parties include third party payment processors, third party usage analytics providers, third party error monitoring software, and third party incident response software. These third parties may collect Personal Information in performing their services and/or functions on the Wolfia Platform.

5. How we use your information

We use your information for various purposes depending on the types of information we have collected from and about you, in order to:

  • Respond to your request for information and provide you with more effective and efficient service.
  • Contact you by email regarding Wolfia and the Wolfia Platform.
  • Customize the content you see on the Wolfia Platform.
  • Secure the Wolfia Platform and resolve technical issues being reported.
  • Help us better understand your interests and needs, and improve the Wolfia Platform, including through research and reports, and test, improve, and create new products, features, and services. We automatically analyze and aggregate information to improve and develop similar features, to better integrate the Wolfia Platform you use, or to improve the Wolfia Platform similarity functionalities for purposes of providing information to Customer. We also test and analyze certain new features with some Customers before rolling the feature out to all Customers.
  • To allow access to third party services’ accounts.
  • For our business purposes we have a legitimate interest, when we:
  • Operate the Wolfia Platform, including by transferring any information to necessary third parties to enable us to provide and operate the Wolfia Platform.
  • Apply information security policies and controls on the Wolfia Platform, including overall integrity, identity management and account authentication.
  • For research and development to improve Wolfia’s Services.
  • Investigate and prevent fraudulent transactions, unauthorized access to the Wolfia Platform.
  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
  • For other purposes for which we obtain your consent.

6. Information shared with third parties

We will not share any Personal Information that we have collected from or about you with any third party except as described in this Privacy Policy. We do not share Personal Information with third parties for their direct marketing purposes.

Information Shared in Order to Provide the Wolfia Platform

We may share your Personal Information to the extent necessary to provide the Wolfia Platform. This includes, but is not limited to, updating, securing, and troubleshooting, as well as providing support.

Information Shared with Our Service Providers

We may engage third-party services providers to work with us to administer and support our business. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. Examples include hosting our web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These companies and individuals may be located in a country whose data protection legislation is different from your country, and they will have access to your Personal Information as necessary to perform their functions, but they may not share that Personal Information with any other third party or use that data for any other purpose.

Information Disclosed in Connection with Business Transactions

We may disclose Personal Information to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings.

Information Disclosed for Our Compliance with Laws

We may disclose your Personal Information if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith – after considering your privacy interests and other factors – that such action is necessary to:

  • Conform to legal requirements or comply with legal processes (including subpoenas);
  • Enforce or apply our terms of use and other agreements, including for billing and collections purposes;
  • Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
  • Stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in an Aggregate or Anonymized Manner

We may aggregate and/or anonymize Personal Information collected through the Wolfia Platform so that such information does not identify you as the source of the information. We may use such information to improve the Wolfia Platform, by and through any third-party we use to integrate Wolfia Platform. However, such information is not considered Personal Information because it is anonymized and aggregated in such a way that it cannot reasonably be linked back to the individual.

Information Disclosed to Others in Accordance with Your Preferences

We may disclose such Personal Information to third parties if you consent to such disclosure. For example, when configuring your profile, you may have the option to indicate that you would like to receive information about the opportunities, products or services of third parties.

7. International Transfer

Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States or Canada and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States or Canada and process it there. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country.

8. Your Choices About Your Information

Information Collected by Us

We respect the choices that you make with respect to your privacy and therefore provide you with the following options with respect to your Personal Information. You may request:

  • Access to your Personal Information to know what information we have collected about you;
  • That we correct your Personal Information if such data is out of date or incorrect; or
  • That we delete any Personal Information that you have provided to us (please note that if you choose to exercise your right to delete, we cannot delete your Personal Information without also deleting your user account).

In the event you decide to exercise these rights, we will do our best to honor your request upon a verified request.

Information Collected by Others

When you use the Wolfia Platform, certain information is collected via web technologies as described above. That technology can sometimes be used to track your online activities and provide you with personalized advertising. If you do not wish to submit your cookies or receive advertising, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Section 4.

Please note that we do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

9. Data Security

We use commercially reasonable administrative, technical, and physical measures to safeguard your information in our possession against loss, theft and unauthorized use, disclosure or modification. Please be aware, however, that no method of transmitting and storing information over the internet is completely secure. Accordingly, we cannot guarantee the absolute security of any information. Furthermore, we are not responsible for any breach of security or for any actions of any third parties that receive the information.

10. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11. Use of Data for Machine Learning and Model Training

Wolfia employs advanced artificial intelligence (AI) technologies to analyze transaction data. This includes, but is not limited to, transaction amounts, dates, merchant categories, and payment methods. Our AI algorithms are designed to identify patterns and anomalies that may indicate financial crimes or non-compliance with regulatory standards.

We may use the data we collect to train our machine learning and large language models to improve our services. This process helps enhance the accuracy, efficiency, and effectiveness of our models. The data used in training may include anonymized user interactions, transactional data, and other relevant information that does not personally identify you.

We are committed to responsible data usage and ensuring privacy in our model training processes. We utilize advanced techniques to protect your data and ensure that it is used appropriately in improving our technology.

12. Your Choice to Opt-Out

You have the option to opt-out of having your data used for machine learning and model training purposes. If you choose to opt-out, your data will not be included in the training datasets, and your experience with our services will remain unaffected.

To opt-out, please adjust your settings in your account or contact us directly at privacy@wolfia.com. Once we receive your request, we will ensure that your data is excluded from any future model training activities.

13. Children

The Wolfia Platform is not directed to children under 18 and we do not knowingly collect Personal Information from children under 18. If you become aware that a child has provided us with Personal Information without parental consent, please contact us through privacy@wolfia.com. If we become aware that a child under 18 has provided us with Personal Information without parental consent, we will take steps to remove the data and cancel the child’s account.

14. Contact Information

If you have any questions regarding this policy or would like to exercise your rights, please contact us at privacy@wolfia.com.