PRIVACY POLICY

Last Updated: November 1, 2024

1. INTRODUCTION

Aaim, Inc. ("Aaim," "we," "our," or "us") is committed to protecting your privacy and ensuring the security of your information. This Privacy Policy describes how we collect, use, share, and protect personal information in connection with our asset verification, valuation, and monitoring services (the "Services").

Our Services are primarily provided to financial institutions such as banks and credit unions ("Partner Institutions"). If you are accessing our Services through a Partner Institution, this Privacy Policy applies to information we collect and process in providing those Services.

Please read this Privacy Policy carefully to understand our practices regarding your information.

2. DEFINITIONS

Personal Information: Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to a particular individual or household.
Financial Information: Information related to your financial accounts, assets, transactions, and investment portfolios.
Partner Institutions: Financial institutions, including banks and credit unions, that use our Services.
Service Providers: Third-party vendors who assist us in providing our Services.

3. INFORMATION WE COLLECT

3.1 Information You Provide or Authorize

Account Information: When you authorize our Services through a Partner Institution, we may collect information such as your name, email address, phone number, and other contact information.
Financial Account Access: With your authorization, we collect information from your financial accounts at various financial institutions, including account numbers, balances, transaction history, investment holdings, and portfolio composition.
Authentication Information: Information used to verify your identity and authorize access to your financial accounts, which may include login credentials for financial institutions (though we implement security measures to protect this information).

3.2 Information Collected Automatically

Usage Data: Information about how you interact with our Services, including access times, pages viewed, and actions taken.
Device Information: Information about the device used to access our Services, including hardware model, operating system, unique device identifiers, and mobile network information.
Cookies and Similar Technologies: We use cookies and similar technologies to collect information about your interaction with our Services. For more information, please see our Cookie Policy.

3.3 Information from Third Parties

Financial Institutions: We may receive information from Partner Institutions or other financial institutions where you hold accounts.
Data Aggregators: We partner with financial data aggregation services (such as Plaid, MX, Finicity, and Quiltt) to access and analyze your financial account information when authorized.
Service Providers: We may receive information from service providers who help us verify identity, prevent fraud, and manage risk.

4. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

4.1 Providing and Improving our Services

To verify, value, and monitor your assets for lending purposes
To perform risk assessments and develop risk profiles
To process transactions and facilitate lending decisions
To maintain and improve our Services
To develop new features and services

4.2 Security and Protection

To verify your identity
To protect against fraudulent or unauthorized transactions
To ensure the security of your accounts and our Services
To monitor for and prevent suspicious or illegal activities

4.3 Communications

To respond to your inquiries and support requests
To provide important notices and updates about our Services
To send you technical notices and security alerts

4.4 Legal and Compliance

To comply with applicable laws, regulations, and legal processes
To enforce our terms, agreements, and policies
To protect our rights, privacy, safety, or property
To respond to requests from regulatory authorities

5. HOW WE SHARE YOUR INFORMATION

5.1 With Your Specifically-Authorized Partner Institutions

We share information with Partner Institutions as necessary to provide your chosen and specifically-authorized Services, including asset verification, valuation, and monitoring for lending purposes.

5.2 With Service Providers You've Authorized

We share information with service providers you've authorized to perform services on your behalf, such as data processing, analytics, fraud prevention, customer service, and advisory assistance.

5.3 For Legal Purposes

We may share information:

To comply with applicable laws, regulations, and legal processes
To respond to public and government authorities, including law enforcement
To protect our rights, privacy, safety, or property
To enforce our terms, agreements, and policies

5.4 In Connection with Business Transfers

If we are involved in a merger, acquisition, financing, or sale of business assets, your information may be transferred as part of that transaction with adequate, proper prior notice and rationale.

5.5 With Your Consent

We may share your information with third parties if and when you have given us consent to do so.

6. DATA SECURITY

We implement appropriate technical, administrative, and physical safeguards designed to protect your information from unauthorized access, use, or disclosure. Our security measures include:

Encryption of sensitive information in transit and at rest
Access controls and authentication requirements
Regular security assessments and penetration testing
Ongoing security monitoring and incident response procedures
SOC 2 compliance controls and regular audits

While we take reasonable measures to protect your information, no security system is impenetrable, and we cannot guarantee the security of your information.

7. YOUR RIGHTS AND CHOICES

Depending on your location, you may have certain rights regarding your personal information:

7.1 Access and Portability

You may have the right to access personal information we hold about you and to receive a copy of this information in a structured, commonly used, and machine-readable format.

7.2 Correction

You may have the right to correct inaccurate or incomplete personal information we hold about you.

7.3 Deletion

You may have the right to request deletion of your personal information in certain circumstances.

7.4 Restriction and Objection

You may have the right to restrict or object to our processing of your personal information in certain circumstances.

7.5 Withdraw Consent

Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

7.6 How to Exercise Your Rights

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. Please note that some of these rights may be limited where we have compelling reasons to continue processing your information.

8. CHILDREN'S PRIVACY

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will promptly delete that information.

9. INTERNATIONAL DATA TRANSFERS

Aaim is based in the United States, and the information we collect is governed by U.S. law. If you are accessing our Services from outside the United States, please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States and other jurisdictions. Your use of our Services or provision of any information constitutes your consent to such transfer, processing, and storage of your information in the United States and other jurisdictions, which may not provide the same level of data protection as your jurisdiction.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you through a notice on our website or through other appropriate channels. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

11. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: privacy@aaim.com
‍Address: 99 Wall Street, Suite 1610, New York, NY 10005
Phone: 212-931-6500

For individuals in the European Economic Area, the United Kingdom, or Switzerland, we may be a data processor processing data on behalf of our Partner Institutions. If you have questions or concerns about how your information is handled, you should contact the relevant Partner Institution.