This Privacy Policy explains how Fundorah, Inc. (“Fundorah,” “we,” “us,” or “our”) collects, uses, shares, and protects information about you when you use the Fundorah mobile application and related services (the “Services”). Please read it alongside our Terms of Service.
Fundorah works with regulated financial partners to deliver the Services. Investment advisory services are provided by Quantbase, LLC ("Quantbase"), an SEC-registered investment adviser; brokerage, custody, and identity verification are provided by Alpaca Securities LLC (dba Alpaca Clearing), member FINRA/SIPC; and bank-account connections are powered by Plaid Inc. (“Plaid”). Each partner handles certain information under its own privacy policy, as described below.
1. Who This Policy Covers
This Policy applies to individuals who download, access, or use the Fundorah app and Services. The Services are intended for residents of the United States who are 18 years of age or older. Fundorah is not directed to children, though adults may open and manage custodial accounts on behalf of a minor as described in Section 8.
2. Information We Collect
Information you provide directly
- Account and profile information: name, email address, phone number, mailing address, and login credentials.
- Custodial and beneficiary information: information about the minor for whom you open a custodial account, such as the child’s name, date of birth, and, where required for the account, Social Security number. The minor's Social Security number is collected only to open the custodial account with Alpaca and is sent to Alpaca for that purpose. It is not used for anything else and is not displayed in full in the app.
- Identity verification information: date of birth, Social Security number or taxpayer identification number, government identification, and similar information required to open a brokerage account and satisfy “Know Your Customer” (KYC), anti-money-laundering, and other legal requirements. This information is collected to establish your account with Alpaca.
- Financial information you enter: debts, balances, interest rates, credit score, cashback amounts, and similar details you choose to record in the app.
Information from connected accounts
- Linked financial accounts (via Plaid): when you connect a bank or financial account, Plaid collects and provides us with account and transaction information in accordance with Plaid’s privacy policy and your authorization. Fundorah uses information from linked accounts only to provide the features you have turned on.
Information from our financial partners
- Brokerage and custodial account data (via Alpaca): account balances, holdings, transactions, and account status associated with the custodial investment accounts.
- Advisory data (via Quantbase): information related to the investment strategy or model applied to your custodial account(s).
Information collected automatically
- Device and usage data: device identifiers, IP address, app version, and information about how you interact with the Services, collected through standard technologies.
3. How We Use Information
We use the information we collect to: create and manage your account; open and service custodial investment accounts through our partners; verify your identity and comply with legal obligations; provide the debt, credit, cashback, and investing features of the app; communicate with you about your account and the Services; personalize and improve the Services; detect, prevent, and address fraud, security, and technical issues; and comply with applicable laws and regulatory requirements.
4. How We Share Information
We do not sell your personal information. We share information in the following circumstances:
- With our financial partners — Quantbase, Alpaca, and Plaid — as necessary to provide the Services (for example, to open and manage accounts, verify identity, and connect bank accounts). Each partner’s handling of your information is governed by its own privacy policy.
- With service providers who perform functions on our behalf (such as cloud hosting, analytics, and customer support), subject to appropriate confidentiality and data-protection obligations. We do not share your custodial account holdings, balances, or transaction data with analytics or advertising providers.
- For legal and compliance reasons, including to comply with laws, regulations, subpoenas, or government requests, and to enforce our agreements or protect rights, property, and safety.
- In connection with a business transaction, such as a merger, acquisition, financing, or sale of assets, subject to this Policy.
- With your consent or at your direction.
5. Our Financial Partners
Certain information you provide is collected and processed directly by our partners under their own terms and privacy policies. We encourage you to review them:
- Quantbase, LLC (SEC-Registered Investment Adviser): https://getquantbase.com/privacy-policy.
- Alpaca Securities LLC (Broker-Dealer & Custodian), member FINRA/SIPC: https://s3.amazonaws.com/files.alpaca.markets/disclosures/PrivacyPolicy.pdf .
- Plaid Inc. (Account Connectivity): https://plaid.com/legal/#consumers .
6. Data Retention
We retain personal information for as long as your account is active and as needed to provide the Services, and thereafter as required to comply with legal, regulatory, tax, accounting, and recordkeeping obligations — which, for financial and brokerage records, may be several years. When information is no longer required, we take reasonable steps to delete or de-identify it. Records relating to your advisory account are kept by Quantbase for at least five years, as required by the recordkeeping rules under the Investment Advisers Act. Brokerage and custodial records are kept by Alpaca under the rules that apply to it
7. Data Security
We use administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential. If we determine that your sensitive personal information has been accessed or used without authorization, or that this is reasonably likely to have happened, you will be notified promptly and in any event within 30 days, either by Fundorah or by the partner whose systems were affected.
8. Children’s Privacy & Custodial Accounts
The Services are not directed to children, and we do not knowingly collect personal information directly from children for their own use. Where you open a custodial account under the Uniform Transfers to Minors Act (UTMA), you provide certain information about the minor beneficiary as the adult custodian. That information is used solely to establish and service the custodial account through our partners.
9. Your Rights & Choices
Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of certain processing. To exercise these rights, contact us using the details in Section 12. We will respond as required by applicable law. Certain financial records may be exempt from deletion where retention is legally required. Requests that concern your advisory account records will be passed to Quantbase, and requests that concern your brokerage account will be passed to Alpaca.
10. Financial Privacy Notice
Quantbase, LLC will give you its own privacy notice under the Gramm-Leach-Bliley Act and Regulation S-P when your advisory account is opened, and once a year after that. That notice explains how Quantbase collects, uses, and shares your nonpublic personal financial information, and any right you have to opt out of that sharing. This Fundorah Privacy Policy describes Fundorah's own practices. It does not replace the notices you receive from Quantbase or Alpaca.
11. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will notify you through the Services or by other reasonable means and update the “Last updated” date above. Your continued use of the Services after changes take effect constitutes acceptance of the revised Policy.
12. Contact Us
If you have questions about this Policy or our privacy practices, contact us at:
Fundorah, Inc. · support@fundorah.com · 131 Continental Dr, Suite 305, Newark, Delaware 19713 · https://fundorah.com/support
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