PRIVACY POLICY

Effective as of July 11, 2019

Table of Contents

1. The Information We Collect
2. How We Use Information
3. Why And How We Share Information
4. How We Keep Your Information Secure
5. Your Choices
6. Contact Us

At Bento Technologies Inc., (“Bento,” “Bento for Business,” “we,” or “us”) we honor your privacy preferences and always ensure that your personal data is safeguarded when you engage with us and our company. We are committed to earning your trust by our commitment to transparency, security, putting you in control of your privacy choices, and using your personally-identifiable information (“personal information”) for no other purpose than as communicated to you. We gather various types of personal information from our users, as explained in more detail below, and we use this personal information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some personal information with third parties, but only as described below.

By using our websites, the Bento financial operating platform (“Bento Services”), the Bento mobile application (“app), and any related products or services you are agreeing to this Privacy Policy. If you do not agree to these terms, you may not enroll in or use Bento Services. Your use of the Bento Services is at all times subject to the Terms of Service, which incorporates this Policy.  Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service

From time to time we may update our Privacy Policy. When changes are made to this policy, we will update the effective date at the top of this document. A change in the effective date will serve as your notice that the policy has changed. If we make a substantial change to the policy, we will send you an email notification, update our website or provide you an alert to your mobile device or computer, or both. If you choose to continue using Bento’s products and services after receiving such notification, you are agreeing to the revised privacy policy. We will provide previous Privacy Policies on our website, so you can see the changes we made.

Issuing Bank Notice

Pursuant to this policy, you direct the applicable Issuing Bank to share your transactional data with Bento, and you direct Bento to share your data with its users, vendors, partners, and affiliates at its discretion (subject to this Privacy Policy), in a way that may otherwise be contrary to such Issuing Bank’s stated and disclosed privacy policy.

1.  The Information We Collect

1.1  Information You Provide to Bento When You Sign Up for Our Services

When you sign up for Bento Services, we are required by federal law to collect “nonpublic personal information” to verify your identity.

We also collect information to establish and maintain your account, including but not limited to:

As a result of completing a transaction using Bento Services, we may also collect information, including but not limited to:

We may also collect information you upload and/or send through Bento Services including:

1.2  Information We Collect Through the Bento Services

When you use Bento Services, we collect information from your computer or mobile device, including but not limited to:

1.3  Use of Cookies and Other Technologies

We use various technologies to collect and store information related to your use of Bento Services. We may collect and store information locally on your device using mechanisms such as browser web storage, session and persistent cookies and web beacons. A cookie is a text file that our website transfers to your device’s hard drive for record-keeping purposes and to enhance the quality of your visit to our website. We use these technologies to personalize Bento Services for you and to collect information about usage of Bento Services. Under the section below entitled “Your Choices,” you can learn about how you may disable or alter our usage cookies.

Our public facing website supports Do Not Track. However, Bento Services do not support Do Not Track requests at this time meaning we collect information about your online activity both while using the Services and after leaving our Services.

1.4  Information from Third Parties

As a result of your accessing your Deposit Account or Cardholder Account through Bento Services, the applicable Issuing Bank collects information such as:

By using Bento Services, you direct the applicable Issuing Bank to share all such information with us.

We may also acquire information about you from third parties in order to verify your identity, process your transactions, detect and prevent fraud, or other similar purposes.

When using Bento Services, you may have the option to provide us with information from third parties, such as Facebook, Twitter, Google, and LinkedIn.

1.5  Personal Information from Children

We do not knowingly solicit or collect personal information from any individuals under the age of 13, or about individuals under the age of 13. If you are under 13, please do not attempt to register for the Bento Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us immediately using one of the means specified in Section 6 (“Contact Us”) below.

2.  HOW WE USE PERSONAL INFORMATION

2.1  We use Personal Information to Provide and Improve Bento Services

Bento uses your information to provide and improve Bento Services, for the purposes of:

1. Providing you with customer/technical support
2. Providing you services such as processing and tracking your transactions, and connecting you with other users, including those you have stored as contacts in your mobile device, those we reasonably believe you may know, and those you are connected to in other networks
3. Answering questions regarding your account and services
4. Monitoring and analyzing how you and other users use Bento Services
5. Improving and building features and services you or other users may want
6. Minimizing fraud and abuse of Bento Services
7. Communicating with you about changes to Bento Services
8. The status and security of your account and data, and administrative information
9. Other reasonable uses related to providing, maintaining, and improving Bento Services

2.2  We use Personal Information for Marketing and Development Purposes

Bento may also use your information for marketing and promotional purposes, such as:

1. Directly marketing to you products and features from Bento
2. Providing you with offers and deals from third parties (including, for example, with respect to Third Party Services)
3. Performing internal marketing analytics
4. Providing you with gifts as part of your using Bento Services
5. Connecting you with commercial users whom we believe you may be interested in
6. Providing you with the opportunity and means to enter into contests such as sweepstakes and raffles
7. Discovering your tastes so that our promotions and marketing are more tailored to you

As noted above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we, or our partners or agents may send you promotional email offers on behalf of our business or other businesses, or email you about your use of the Services.  If you do not want to receive communications from us, please indicate your preference by emailing us at support@bentoforbusiness.com.

2.3  In Accordance with U.S. law

Bento is an U.S.-based company headquartered in California. Both Californian and U.S. law govern the information we collect. By accessing or using Bento Services or otherwise providing information to us, you consent to the processing and transfer of personal information in and to the U.S.

3.  WHY AND HOW WE SHARE PERSONAL INFORMATION

3.1  Providing Information to Third Parties

When you sign up for Bento Services, you are directing Bento to share personal information with third parties as outlined below. The personal information that Bento shares includes both the personal information that Bento collects from you directly and the personal information that Bento collects from third parties.

3.2  Business and Legal Purposes

We may provide your personal information to Third Parties for business and legal purposes, including for the purposes of:

1. Providing and improving Bento Services and/or marketing Bento and third-party products and services to you, as described above
2. Providing personal information to Third Party Providers as and to the extent described in the Terms of Service
3. Meeting the requirements of any applicable law, regulation or legal process, including complying with orders from courts of law, regulatory agencies, and law enforcement
4. Investigating fraud inside and outside Bento Services
5. Broader business dealings such as mergers, asset sales, financings, and acquisitions (note: if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your information could be one of the assets transferred to or acquired by a third party)
6. Reporting to credit bureaus

3.3  Promotional and Marketing Purposes

We may also provide your personal information to third parties for promotional and marketing purposes, including for the purposes of:

1. Helping you find people you may know, even if you are not yet connected through Bento Services, and helping those people find you
2. Helping you find merchants you may be interested in and helping merchants that are registered with Bento find you

3.4  Limitations on Promotional and Marketing Use

For the third-party promotional and marketing purposes outlined directly above, Bento will never share bank account or routing number, bank account username, password, business tax identification number or your social security number, unless you direct us to do so.

3.5  Reserved Rights

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.

4.  HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

4.1  Our Security Precautions

We have implemented policies and procedures that are designed to protect both your confidentiality and the security of your nonpublic personal information. We store and process your personal information using third party servers located in data centers in the United States. These centers are protected by physical, electronic, and procedural safeguards in compliance with applicable federal and state regulations. Additionally, Bento uses firewalls and data encryption where reasonable. We also enforce restrictions on physical access to our office and files and limit digital access to sensitive data in order to ensure that only those employees who require the access to fulfill their job responsibilities actually have it.

4.2  Notification of Security Breach

Despite Bento’s efforts to keep your information secure, we cannot guarantee the security of your information. As a result, we strongly encourage you to take action to protect your personal data and any device you use to access Bento Services. In the unlikely event that we come to learn that either our system or your account specifically has suffered a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps, by email, text message, phone call, a notice on the Bento website, or any other way, depending on the requirements of applicable law.

4.3  Links to Other Sites

We are not responsible for the privacy practices of any third parties or the content of sites that are linked from Bento Services and we strongly encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

5.  YOUR CHOICES

5.1  Location Information

Bento may collect information regarding your location. You may be able to prevent this collection through your device operating system settings or by following the standard uninstall process to remove our mobile application from your device. Similarly, you may be able to control how your browser interacts with cookies. However, if you remove stored cookies or block them from being set, you may affect the availability and functionality of Bento Services.

5.2  Your California Privacy Rights

California Civil Code Section 1798.83 permits Bento users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as described below.

5.3  Opting Out of This Policy

If you no longer wish to use Bento Services and would like to delete or deactivate your Bento Account, please contact us. As stated above, your usage of the Bento Services is contingent on your expressly opting in to this Privacy Policy. If you change your mind after agreeing and wish to opt out at a later date, you must contact us to cancel your Bento Account. You can do so by sending an email support@bentoforbusiness.com. We are required by law to retain some of your information and may also do so for legitimate business purposes (e.g., internal analytics).

6.  HOW TO CONTACT US

6.1  Ways to Contact Bento

If you have comments or questions about our Privacy Policy, you may contact the Company here: