Privacy Policy

At Halfmore, we strive to empower families by transforming everyday tasks into opportunities for financial growth and education. Our mission is to create a world where every family can secure their children's financial future. We are a community rooted in the principles of innovation and inclusivity. Central to nurturing this community is our commitment to earning and maintaining your trust. This begins with being transparent about how we handle your information and upholding your fundamental human right to privacy, as we navigate the path of financial literacy and security together.

This Privacy Policy for Halfmore, Inc. and its affiliates (“we,” “us,” “our” or “Halfmore”) describes how and why we collect, store, use and/or share (“process”) information about you and your family. It applies to everyone who: visits our websites that link to this Privacy Policy (the “Site”), uses our mobile applications (“Apps”), financial accounts and cards ,uses our platforms - including touch technologies, electronic services, social networking sites, interactive features, online services or any of our described online activities we own or control that link to this Privacy Policy or otherwise uses the services we provide (collectively, the “Service”). For more information regarding the Service, please review our Terms and Conditions (the “Terms”).

Key terms: In this Privacy Policy, we refer to “you” as a visitor to our Site, user of our App and Service and/or the individual, parent or guardian who is responsible for the account(s) you create using our Service (the “Custodian” as defined in our Terms). We use “your family” to refer to anyone affiliated with your account on the Service, such as any child or children you sign up for the Service. If you designate any other individual to be responsible for the Service, such as your spouse, or authorized user (the “Authorized Approver” as defined in our Terms), “your family” also includes that individual. Capitalized terms used but not defined in this Privacy Policy shall have the same meanings ascribed to them in the Terms.

1. Types of Information We Collect and How

We collect the following categories of personal information:

• Identifiers and contact details: such as name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.

• Official identification information: such as Social Security number, government issued Driver’s License, State ID Card, passport, Employer Identification Number (EIN) and/or any related information that is necessary to comply with legal obligations.

• Demographic information: such as age, date of birth, gender, and pronouns.

• Transaction information: such as purchases made with the Service, transaction history, trading history, and account balances.

• Financial information: such as transaction information, tax identification number, brokerage account numbers for Roth IRAs, and bank account numbers pertaining to financial accounts you choose to link to the Service.

• Location information: such as information related to your state, city, or neighborhood.

• Device information: such as computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information associated with IP address, such as city, state or geographic area.

• Usage information: such as the pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages and screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communications with us and information provided: such as any customer service requests or social media interactions you or your family initiate and other information you or your family choose to provide to us through the Service, such as any images or photographs submitted or posted, or information submitted through the available chat features.

• Contract information: such as employment start dates, hours worked, assigned chores, completed chores, roles, salary information, other schedules you may want to post and enter into the calendar.

• Preferences: such as marketing preferences and inferences about any Service you may be interested in.

We collect personal information from a variety of sources, including:

• From you and your family: including identifiers and contact details, demographic information, financial information, location information, communications with us, and preferences.

• Automatically, from your and your family’s devices: including device and usage information, some of which we collect via cookies and other technologies as described below.

• Social media networks: including information you and your family provide to us and your communications with us on social media channels, such as Facebook, YouTube, TikTok, Twitter, and Instagram, and any demographic information such platforms provide to us.

• Other third parties: including information we receive from:

  • Financial service providers, including Plaid, which allow us to verify you own the bank account you elect to use as a funding source, verify the amount requested is available to fund your Linked Account and complete the transfer of funds to your other Linked Accounts.

  • Payment service providers, including Astra, which allow us to process transactions, manage payment scheduling, and ensure the secure handling of your financial data.

Cookies and other similar technologies

We use the term “cookies and other similar technologies” to refer to small data files, including cookies, pixel tags, and/or other technologies provided by your browser or associated applications.

Like many digital platforms, Halfmore, our service providers, and advertising partners may collect device information, device and usage information and other personal information automatically using cookies and other similar technologies to help us enable functionality, analytics and online advertising. These technologies include:

• Cookies. You can learn more about cookies and how to control them at www.allaboutcookies.org and you can set preferences for which cookies you wish to remove or reject in your browser.

• Pixels. We may use pixels (also known as web beacons and clear GIFs) on our Site and in our HTML formatted emails to track the actions of users on our Site and interactions with our emails, such as when an email was opened. Pixels are embedded invisibly in image files within webpages or HTML formatted emails. Most browsers and devices allow you to configure your device to prevent images and any pixels embedded in them from loading.

• SDKs. Software Development Kit (SDK) refers to third party computer code incorporated into our Site or Apps to enable functions and tracking similar to those enabled by the other technologies described above, including to enable third party analytics and advertising services.

• Session Replay. We may use services that employ software code to record users’ interactions with the Services in a manner that allows us to watch and analyze visual reconstructions of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement.

• Chatbot features. The Service may provide users with chatbot features to get information and support. The third parties that support these features may access, monitor and record the information you submit to the chat, as well as your device data and usage data described above, to enable the chat and for the other purposes described in this Privacy Policy, including training, quality assurance and service improvement. When you use these features you are not communicating with a human.

You are free to decline optional cookies and similar technologies if permitted by your computer, browser, mobile phone, or other device, although doing so may affect your use of the Service. We do not control the third parties’ tracking technologies or how they may be used.

Recording and monitoring

When you call us by phone for support or use the Service’s chat features, we and our third-party vendors may monitor and record the conversations for the purposes described in this Privacy Policy, including for quality assurance, training, and service improvement. We and our third-party vendors may also collect your internet and usage information associated with your use of the Service’s chat features for the same purposes. When you use our chatbot features, or interactive voice response features over the telephone, you are not communicating with a human.

2. How We Use Personal Information

We use personal information for the following purposes:

• To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request. This includes:

  • Processing and analyzing account transactions and payments, and notifying you and your family about them;

  • Providing customer support and notifying any additions, updates, or changes in the Service, answering questions and responding to requests, and otherwise communicating with you and your family;

  • Testing, personalizing, developing and improving the Service, including for analytics, machine learning, and to create new algorithms or other tools, so we can better cater to your interests; and

  • Providing services or features you request

• To market our products and services, including:

  • Direct marketing, such as sending direct marketing communications as permitted by law, including by email, text messages or telephone call;

  • Referrals, such as facilitating, managing and confirming referrals from you, your family, and our business partners; and

  • Interest-based advertising, such as engaging third-party advertising companies and social media companies to display ads promoting our and other services across the ite or App.

• To maintain the security and integrity of the Service, our technology, assets and business, including:

  • Detecting, preventing, and investigating fraud, cyberattacks or other unauthorized, unethical or illegal activities;

  • Evaluating, monitoring and auditing the security of the Service, and troubleshooting and debugging;

  • Performing identity verification on our own behalf and on behalf of regulated business partners

  • Enforcing our Terms, including to prevent potential breaches; and

  • Protecting our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).

• To comply with applicable laws, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• With your consent, including the use of personal information for any purpose which you provide consent.

3. How We Share Personal Information

We do not sell personal information. We may share personal information as follows:

• Within your family. Information you or your family provide may be accessible to other members of your family through the Service. For example, you and any Authorized Approver will be able to see the Linked Account activity of your child on the Service, and the Authorized Approver may be able to see certain information about you, such as your name and your Linked Accounts.

• Processing transactions. To process payments and other transactions on the Service, we share information with the person you or a member of your family are paying or from whom you or a member of your family are receiving a payment.

• Service Providers. We engage with select service providers who provide services to support our operations such as: open banking interface providers (i.e., Plaid); gather your data from financial institutions (i.e., Plaid); payment processors (including merchant acquirers and automated clearinghouse (ACH) payment processors); insurance providers for mobile phone protection and purchase protection; identity verification services; cloud hosting providers (i.e., Google Cloud ); email/SMS delivery (i.e., Mailjet and Sinch); customer support (i.e., Intercom); EIN creation (i.e., IRS); functionality providers, providers of information technology, marketing, consumer research, analytics, and cybersecurity services; and other service providers pursuant to written agreement with us.

• Other Parties. We share personal information when we have reason to believe that disclosing the information is necessary to prevent fraud, damage to person or property, protect and secure our business, assets, user accounts or enforce legal rights or comply with subpoena, court order, legal process or obligations, including as needed to support auditing, compliance, and corporate governance functions. We also share personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law or court order.

• Your network. When you use the Service to engage with individuals outside of your family, those individuals will be able to see your name and/or username, profile photo, and any other information you choose to share.

• Advertising Networks and Analytics. We may allow advertising networks to collect information on our Site for the purposes of serving ads that are more relevant. We also work with partners that assist us with ad campaign measurement and analytics on our Site and App.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

• Successor Entities. We may disclose or transfer your personal information to a successor entity (or its representatives) in the event of a corporate merger, divestiture, consolidation, reorganization, sale of assets or other corporate changes respecting Halfmore (including, in connection with bankruptcy or similar proceedings), and in connection with due diligence and negotiations relating to any such transactions.

We may also share information if the information has been aggregated, de-identified, or otherwise does not identify you personally, and otherwise with your consent.

4. Your Choices

We provide you and your family with the following choices.

• Marketing Preferences. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us via email (support@halfmore.co).. You will then be removed from the marketing lists. However, you may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

• Update Your Information. You can edit or update personal information in your account by reviewing the account settings and profile across the family of accounts. It is your responsibility to make sure that personal information of everyone in your family is accurate. You should promptly update your and your family’s personal information if it changes or becomes inaccurate.

• Change location and motion detection settings. You can change what location you share within the settings of your device. Please note that by changing these settings we may not be able to provide you with our Service.

• Closing Account(s) and Deletion of Personal Information. As the primary accountholder of your family account created by you for the use of the Services (“Halfmore account”), you can close your Halfmore account as well as any secondary accounts (the “Secondary account”) created under Halfmore account by other member of your family (the “Secondary Accountholder”) within the settings of the App. If you close the Secondary account, such Account will no longer be accessible, but we may retain personal information from that Account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Terms, or take other actions as required or permitted by law. Further, you may delete the Secondary account or designate it as the primary Linked Account, and may also update or correct certain of your, your family member’s or the Secondary Accountholder’s information through your Halfmore account settings.

• Opt-Out. There are a number of ways to limit online tracking on our Site, which we have summarized below:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

  • Using privacy plug-ins or browsers. You can block our Site from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, downloading and enabling Global Privacy Control, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.

  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by adjusting your browser cookies settings or using our “Do Not Sell or Share My Personal Information” tool in the footer of our Site.

The rights described above are not absolute, and, in certain cases, we may decline your request if limitations on these rights apply or as otherwise permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Please note that your rights regarding nonpublic personal information protected under the Gramm-Leach-Bliley Act may differ. Please refer to the separate GLBA notice shared with you when you create your account.

5. Data Retention

We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.

Once the retention period of personal information expires, we delete your personal information from our records and will be irrevocably destroyed. If applicable laws require us to retain your personal information after your use of our Services or the expiration of the retention period, we will store your information in a separate database or storage space.

6. Security

Our information security program is managed by dedicated information security personnel with commercially reasonable information security measures to protect personal information against loss, misuse, and unauthorized access. These measures include, but are not limited to, data encryption, cyber threat detection, and internal access controls. We regularly have our information security program assessed and validated by independent security audit experts. You and your family are responsible for maintaining the security of your usernames and passwords used to access the Service. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

7. Information from Children

At Halfmore, our goal is to help parents plan and manage wealth for their children, and we take our responsibility to your children seriously. The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) requires us to inform parents and legal guardians about our practices for collecting, using, and disclosing personal information from children under the age of 13. In accordance with the COPPA, we will not knowingly collect any information from children under the age of 13 on our Site without verifiable parental or legal guardian consent. If we learn that we have collected personal information from a child under 13 without the consent of the child’s parent or legal guardian, we will either delete the information or immediately seek the parent’s or legal guardian’s consent for that collection.

Collection of Children’s Personal Information

Before collecting any personal information from children under the age of 13, we will obtain verifiable consent from the child’s parent or legal guardian.

We only collect the minimal amount of personal information necessary for your children to use our Service as the Account Owners. Specifically, we collect the following information:

• first name, last name
• date of birth
• home or other physical address
• parent’s email address
• telephone number

We may ask for certain information that is not personally identifiable such as gender, school name, grade level, daily meal routine, bedtime, or/and daily tasks and schedule in connection with your child’s use of the Service and help us improve our Service. We store your child’s username and password on our system when the child registers for the Service. We may also store the IP address from which the child accesses the Service in connection with the child’s use of the Service.

Registration

During the registration process, we ask for your mobile phone number and date of birth, which we use to determine your age and eligibility for the Service. Children under the age of 18 must register for our Service with their parent or guardian as follows:

• Children under 13. Parents or guardians must initiate the registration process on behalf of children under the age of 13. We request, via digital consent during the registration process, that you represent that you are the parent or legal guardian of any child under the age of 13 for whom you register an account and that you consent to our collection and use of the child’s personal information in accordance with this Privacy Policy. If a child under 13 initiates the registration process without a parent or guardian the registration session will end, and we will inform the child that the child will need a parent or guardian to create an account. In those cases, we delete the personal information from children under 13 until a parent or guardian initiates a new registration.

• For those younger than 18, a parent’s mobile phone number is required so that we can provide the parent with information about how to download the App and finish registering an account.

Parental Choices and Controls

You can update or change the personal information of your child at any time through the account settings.

At any time, you can refuse to permit us to collect further personal information of your child by closing that sub-account by calling Halfmore Customer Service at 1-650-507-7477. If you close an account, we will mark the account in our database as “Closed,” but may retain personal information from the account to deactivate the account with our service providers, allow you to reactivate the Halfmore account for some period in the future, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Terms, or take other actions as required or permitted by law.

If you request that we delete your child’s personal information, we will delete as much information as we are legally permitted. Due to regulatory recordkeeping obligations, we may be required by law to retain some information associated with a closed account.

Disclosure of Children’s Personal Information

We do not sell or rent children’s personal information to third parties. We disclose such personal information only for limited purposes such as:

• We may share children’s information with third-party service providers who assist us in operating and providing the Service, but only to the extent necessary for them to perform their services in which they are obligated to protect the confidentiality and security of the information.
• We may disclose children’s personal information if required by law or to comply with legal obligations or respond to lawful requests from authorities.

Security

We take special precautions to protect the information of children using our Service. We use physical, technical, and administrative measures to safeguard and secure the information we collect. If you have a questions, please contact us by calling Halfmore Customer Service at 1-650-507-7477.

8. Location of Services

We are headquartered in the United States and currently our Service is only intended for residents of the United States.

9. Your Rights

If you are resident of California, Florida, or Texas, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

The exact scope of these rights may vary by state. To exercise any of these rights please email support@halfmore.co. To appeal a decision regarding a consumer rights request please email support@halfmore.co noting which decision you are appealing within 30 days.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your account profile page.

You may also send us an email at support@halfmore.co to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please note that your rights regarding nonpublic personal information protected under the Gramm-Leach-Bliley Act may differ. Please refer to the separate GLBA notice shared with you when you create your account.

Additional Information for California Resident

Exercise Your Rights

If you are a California resident, you may exercise your rights for the personal information covered by this Privacy Policy as follows:

• Right to Know: You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.

• Right to Access: You have the right to request access to categories and specific pieces of personal information about you that we collect, use, and disclose.

• Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

• Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

• Right to Opt Out of Sale or Sharing of Personal Information: you have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law).

• Right not to Receive Discriminatory Treatment: We will not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.

Your California Privacy Rights under California’s Shine the Light Law

Under California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their direct marketing purposes. To make such a request, please contact us via email, or write to us at the address below.

10. Changes to Privacy Policy

If we make any material changes to this Privacy Policy, we will change the Effective Date above. We encourage you to review this Privacy Policy to stay informed. If we make material changes and we need to provide additional notice, we will notify you via the email specified in your account or through the Service or the Site.

11. Contact Us

If you have questions about this Privacy Policy or our information practices, please contact us by email at support@halfmore.co,.

Our mailing address is:

Halfmore, INC.
650 Island Pl Redwood City, CA 94065