Privacy Policy

Date of Last Revision: October 9, 2024

This Privacy Policy (the “Policy”) describes and governs how Fortuna Inc. and its subsidiaries, affiliates, agents, and service providers (collectively, “Fortuna”, “we”, “us” or “our”) collect, use, share and protect information we collect through our website (myfortuna.com) (the “Website”), our mobile applications, and related services (collectively, our “Services”). This Policy only applies to the Services. The Services may contain links to other websites, platforms, or services we do not operate or control (“Third-Party Sites”). The policies and procedures described in this Policy do not apply to Third-Party Sites.

For individuals residing in the United States, you may also refer to the Fortuna Consumer Privacy notice, which provides additional details about our collection, use, and sharing of your personal information in connection with the financial services that we provide to individuals, and associated rights you may have under federal law.

Please read this Policy carefully to understand our policies and practices regarding your information. By continuing to interact with or use our Services, you consent to the practices described in this Policy. This Policy may change from time to time (see Changes to this Policy). Your continued use of the Website or our other Services after we make changes is deemed acceptance of those changes, so please check the Policy periodically for updates.

Fortuna is a product of Grit Financial Inc. and is also subject to Grit Privacy policies which may found at https://gritfinancial.org/privacy-policy/

INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us and our Services, and the requirements of applicable law. As further described below, we collect information you provide us, or that we obtain automatically when you use our Services, and we may also obtain information about you from third parties. In order to provide our Services, we partner with or otherwise use third-party companies to perform certain business-related functions on our behalf (“Service Providers”). Our Service Providers may also collect personal information from or about you. For more information about our Service Providers, please see “How We Share Your Information,” below.

A. Information you provide directly to us

Registration information. If you open an account, we collect your email address and login details, your zip code, your country, your social security number, your date of birth, your phone number, and any additional information you choose to provide us.
Financial and Transaction Information. This information may include bank account information and payment card numbers you add to your account, income information, the age of your account(s), any card information issued to you in connection with your use of our Services, when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, and the devices and payment methods used to complete the transactions. We may use Service Providers, such as Plaid, to assist us in collecting and verifying this information. For more information about the types of information that Plaid collects and how it is used, please review Plaid’s privacy policy.
Public Communications. Certain areas and aspects of our Services may permit you to post comments, leave feedback, send thank-you notes or otherwise communicate with others. Please be advised that some information that you provide may be publicly accessible, such as information posted in forums or comment sections. Any content, including such comments, feedback, and notes that you choose to post through our Services are available to the public by default. We may also collect information through forums and communities, surveys and customer support communications, your communication to us of ideas for new products or modifications to existing products, feedback and other solicited or unsolicited submissions. Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Take care not to share personal information unless you intend for that information to become public, and only where such sharing does not violate this Policy or our Terms of Use.
Communications to Fortuna. You may contact us via a contact form, email, by chat services or by other means (for example, with questions about our Services, for customer support, or to let us know your ideas for new products or modifications to existing products). You may also choose to respond to surveys that we send out. When you contact us, we collect the information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message.
Information relating to third parties. You can choose to provide us with information relating to third parties, but only to the extent that such sharing does not violate this Policy or our Terms of Use (collectively, “Third-Party Data”). If you use any feature of the Services that allows you to communicate with third parties, either by submitting Third-Party Data to the Services or otherwise permitting the Services to automatically access Third-Party Data in your possession, you acknowledge, represent, and agree (a) that you have the authority of the relevant third party for us to access and use the relevant Third-Party Data, (b) that you have notified these third parties and informed them how their information is collected and used by Fortuna to provide the Services, and (c) your sharing of the Third-Party Data complies with our Terms of Use and this Policy.
Biometric information. We may use Service Providers for identity verification and fraud prevention purposes. These Service Providers, such as Persona Identities, Inc. (“Persona”), may collect biometric information in order to perform these functions. Fortuna does not receive, store, or have access to this information; however, you are encouraged to review Persona’s privacy policy for more information about the information it collects and how that information is used.

B. Information passively or automatically collected

We also automatically collect certain information based on your use of our Services. This data would include your activities on our Services. For example, we, or our third-party partners, may collect:

Activity Information. This information may include details of the activities you carry out when using our Services, including visits to our Website. We may also collect your geographic location when you use a location-enabled device with our Services and sensor data from your device.
Technical Information. This information may include the Internet protocol (“IP”) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and device identification information. Some of this information, such as your IP address, may identify your geographic region, time zone, and other rough location data.

C. Information we obtain from Third Parties

Your employer. We may collect information directly from your employer to provide you the Services. This information may include information necessary for us to complete the registration processes, verify your identity, and for similar administrative purposes. For example, your employer may provide us with your name, address, phone number, and payroll information.
Other Third Parties. We may also obtain information about you from third parties in connection with our fraud prevention, detection, and mitigation processes.

COOKIES AND THIRD-PARTY INTEGRATIONS

A. Use of Cookies

When you use our Services, we and certain of our Service Providers may use cookies, web beacons, pixel tags, and other tracking technologies (collectively, “Cookies”) to customize our Services, content, and advertising, as well as to measure the effectiveness of promotions and ensure that our Services are functioning properly.

Essential Cookies. Some Cookies are strictly necessary to make our Services available to you (“Essential Cookies”). We cannot provide our Services without these Essential Cookies.
Non-Essential Cookies. We also may use Cookies to maintain and improve our Services or your experiences, and for marketing purposes (collectively, “Non-Essential Cookies”). Some of the Non-Essential Cookies used are set by us to collect and process certain data on our behalf and some are set by third parties. Non-Essential Cookies may collect information about your online activities over time and across third-party websites or other online services. The manner in which these third parties collect, use, store, and disclose your information is governed by the policies of such third parties. Fortuna shall have no liability or responsibility for the privacy practices or other actions of any third party that may be enabled within, or integrated with, the Services.

B. Your Choices Regarding Cookies

You can stop or restrict the placement of some types of Cookies on your device or remove them by adjusting your preferences as your browser or device permits. You can also consult the “Help” section of your browser for more information (e.g. Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). However, please note that cookie-based opt-outs are typically not effective on mobile applications. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others. Please note that we do not recognize or respond to browser-initiated DNT signals, which are a privacy preference that users can set in certain web browsers, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and developing a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

The online advertising industry additionally provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, the Your Ad Choices for App tool, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

To the extent we use Google or Facebook for advertising purposes on our Website, please see these links provided by these respective companies for opt-out purposes: Google / Facebook. We are not responsible regarding the scope of, or the honoring of, any such opt-outs, as opt-out preferences provided by these companies are not under our control.

HOW WE USE YOUR INFORMATION

We use the information that you provide (or otherwise permit the Services to access) for the following purposes:

Communicating With You. We may use the information we collect to contact you for administrative purposes (e.g., to provide services and information that you request or to respond to comments and questions). Subject to your preferences regarding marketing communications, we may also use the information we collect to send you communications relating to the Services, such as updates on events, communications relating to products and services offered by us and by third parties, and communications about services we believe will be of interest to you.

If you access the Services through a mobile device and if you have chosen to provide us with your mobile number, or other electronic means to your mobile device, we may communicate with you to provide information regarding your Fortuna account by phone or text message. You can reply STOP to such text messages to opt out of any informational text messages about your account.

Providing the Services. We use the information we collect to operate, maintain, and provide our Services, such as enabling access to the Services, customer support, or to complete transactions.
Security and Fraud Prevention. We use the information we collect to secure our Services and to verify identity, prevent fraud, and to continually improve these aspects of our Services. This may include a request for your mobile telephone number to conduct multi-factor authentication when you create an account and/or at the time you set up withdrawals as a beneficiary.
Analytics, Research and Product Development. We use the information we collect to analyze data usage trends and preferences in order to improve the accuracy, effectiveness, security, usability or popularity of our Services. We further use data in connection with our research on our customer demographics, interests and behavior.
Customization. We use the information we collect, such as device identifiers, to learn how users interact with our Services in order to personalize the content of our Services.
Legal. We use information we collect to defend our legal rights, comply with national, state, local, federal, regional or international laws, and to enforce our Terms of Service and this Policy.
Aggregated Data. We may aggregate, anonymize and/or de-identify information collected from or about you so that the information no longer identifies you (“Aggregated Data”).

HOW WE SHARE YOUR INFORMATION

There are certain circumstances in which we share information collected through the Services with third parties, as set forth below. Fortuna does not sell your personal information.

Successors-in-interest. We will share your information with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) and, in each case, any due diligence relating thereto.
Affiliates and Subsidiaries. We may share your information among our affiliates and subsidiaries, in order to provide our Services. The purposes for which we may share information with these entities include providing you with customer support; administering funds; authenticating accounts; sending you informational communications; and conducting the other activities described in this Policy.
Agents, Consultants, Vendors and Related Third Parties. We provide access to or share your information with our Service Providers so they can perform services for us. Examples of such functions include marketing, mailing information, data storage, security, identity verification, fraud prevention, payment processing, legal services, and maintaining databases. We limit the personal information provided in this context to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
Your Employer. Fortuna may share some Aggregated Data about your use of our Services with your employer. This information does not personally identify you.
Legal Requirements. Fortuna may disclose your information when we have a good faith belief that doing so is necessary to: (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to inquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organizations; (ii) protect and defend the legal rights, privacy, safety or property of Fortuna, its affiliates, subsidiaries, employees, agents, contractors, or its users; (iii) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or any applicable Terms of Use.
Your Consent. In certain situations, we may share your information in the event that you consent to or authorize the sharing of your information, such as if you link or login through an SNS account, or if you consent to our providing your contact information to a specific partner.
Aggregated Data. We may share Aggregated Data with our affiliates, agents, business partners, research facilities or other third parties.
Cookies and Other Electronic Technologies. Information is shared as stated in the Section of this Policy entitled “Cookies and Third-Party Integrations.”
Other Users of Our Services. We provide your information to other users of our Services if you choose to make your information publicly available in a publicly accessible area of the Services.

CHILDREN UNDER 13

Our Services are not designed for use by individuals under the age of 13. If you are under the age of 13, please do not use the Services or submit any information through the Services. If you have reason to believe that a child under the age of 13 has provided personal information to Fortuna through the Services, please contact us at privacy@myfortuna.com, and we will delete that information from our databases to the extent required by law.

SECURITY

While no organization can guarantee perfect security, Fortuna has implemented safeguards and continuously seeks to improve technical and organizational security measures to protect the information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We restrict authorized access to your personal information to those persons who have a legitimate purpose to know that information to provide the Services and to those persons you have authorized to have access to that information.

If you have created an account with us, you are responsible for keeping confidential the usernames and passwords you use to access our Services. Do not to share your password with anyone else and do not use the same password for other services or products. Please note that we will not contact you to request your password.

RETENTION AND DELETION OF YOUR INFORMATION

We retain your information for as long as we deem necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, your information is only retained to the extent permitted or required by applicable laws. When we no longer need to retain your information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.

When determining the retention period for your information, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information about you, and mandatory retention periods provided by law and associated limitations periods.

To close an account that you have created with us, please contact us at support@myfortuna.com. Closure or deletion of your account may mean that you lose access to the personal information and data associated with the account. Certain personal information or de-identified information associated with your account may nonetheless remain on systems owned or maintained by us when required to comply with the law, our contractual obligations, or in carrying out legitimate business functions.

MARKETING COMMUNICATIONS

Each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. In addition, if at any time you do not wish to receive future marketing communications, please contact us at the email address or postal address set forth under “Contacting Fortuna,” below. If you opt out of receiving marketing communications, we may still send you informational emails about your account or any Services you have requested, used, or received.

OTHER TERMS

Your access to and use of the Services is subject to Fortuna’s terms of use and other terms made available to you in connection with your use of the Services.

CHANGES TO FORTUNA’S PRIVACY POLICY

Fortuna reserves the right to update or modify this Policy periodically and at any time. We will notify you of any material updates or changes we make to this Policy. If you disagree with our revisions to the Policy, you can deactivate your account or discontinue the use of our Services. Please review this Policy periodically for any updates or changes to this Policy.

By using our Services and Services after any such update or modification, you acknowledge that you have read and understood the terms of the Policy as updated or modified.

CONTACTING FORTUNA

Please contact us if you have any questions about this Policy or the information practices of the Services.

You can contact us as follows:

My Fortuna Inc.

Phone: 888.463.3001

Privacy: privacy@myfortuna.com

General: support@myfortuna.com