PRUNE

Last Updated on September 19, 2024

Your privacy is important to us. This Privacy Policy (“Policy”) applies to services provided by Prune, Inc. (“we”, “us”, or “Prune”) and our website, product pages, mobile or web applications, or other digital products that link to or reference this Policy (collectively, the “Services”) and explains what information we collect from users of our Services (a “user”, “you”, or “your”), including information that may be used to personally identify you (“Personal Information”) and how we use it. We encourage you to read the details below. This Policy applies to any visitor to or user of our Services.

We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by posting a new Policy to this page, and/or by sending notice to the primary email address specified in your account. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically reviewing this Policy to check for any changes. Changes to this Policy are effective when they are posted on this page. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy.

Scope and Applicability

When you sign up for an account with Prune, Prune may collect and use your personal information on behalf of Bangor Savings Bank (Prune’s “Bank Partner”) to facilitate the provision of banking services pursuant to the Bangor Savings Bank Privacy Notice. The personal information processed in such cases is subject to our Bank Partner’s privacy notices and laws such as Gramm-Leach-Bliley Act and may be excluded from some comprehensive state privacy laws. Federal law requires our Bank Partners to provide notice to certain consumers to explain what personal information they collect, how they share it, and how consumers may limit our Bank Partners’ sharing of the information. The privacy practices of our Bank Partners are subject to their privacy notices, which we strongly suggest you review. Prune is not responsible for our Bank Partners’ information practices or privacy notices but may publish the notices and process data subject requests as their service provider.

Our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy disclosures of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Prune, we are not responsible for these third parties’ information practices.

What Information Do We Collect?

Information You Provide to Us

In signing up for an account for the Services, we may receive the following information about you, the Customer you represent, and other individuals associate with such Customer:

Contact Information, including your first name, last name, email address, phone number, and address.
Identifying Data, such as date of birth, residential address, social security number and driver's license, passport or other government-issued identification, and any information captured on such identification or through our identification verification process.
Third Party Information, including information you provide about any co-workers, contractors, vendors or other potential referrals, such as their Contact Information.

Financial Data, including your account number from our Bank Partners, Prune account transaction history, information about your linked non-Prune accounts (such as transaction information and balances, payroll account information, etc.), and payment card information.
Employment information, including occupation, information about your employer, employee email address, and income details (such as source of income, approximate or expected income and how frequently you are paid).
Physical characteristics, demographic information and similar details, such as sex, gender, race, color, marital or family status, citizenship status, military or veteran status, signature, language preference and national origin, present in documents (e.g., IDs, tax returns) you provide.
Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or Services.
Voice recordings, such as when you call Prune’s member services.
Biometric Data, including information that we or our identity verification partners may collect through documents that contain your photograph or by requiring you to provide a photo of yourself. This information and data derived from these images may be considered biometric data and may be used to verify your identity or meet regulatory obligations. We will retain biometric data for 5 years after the account is closed or as long as necessary to satisfy the purpose of collection, unless otherwise required by law.
Transaction Data, including information associated with transactions made via your account.
Information you provide through member services interactions and that you provide about your experience with Prune, including via questionnaires, surveys, participation in user research or other feedback.
Communications and Online Content, including content within any messages you send to us (such as when contacting support or asking a question). We also collect content within any messages you exchange with other users through the Services.
Marketing Data, such as your contact preferences and webinar /event registration, attendance and participation information.
Referral Data, including information you provide about any potential referrals as part of our affiliate referral program, such as their name, email address, and phone number.
Other Data, including any information, documentation or files that you provide, including information you choose to provide, such as through our “Contact Us” feature, emails or other communications (such as with member services), referrals, chatbots, surveys, research participation, on social media pages, or in registrations and sign-up forms.

Information We Collect Automatically

We may automatically collect or generate through the Services the following “Technical Information”:

Device data, including information about the type of device or browser you use, your device's operating software and settings, your internet service provider, and device identifiers, such as IP address and advertising identifier.
Usage data, including, but not limited to, search terms entered, pages viewed, and other usage behavior identified by analytics events.
Location data, including approximate geographic location derived from your IP address.
Network and internet information, including, URLs, Internet Protocol addresses, bounce rates, use of spoofing, active (TCP/IP) ports, number of sessions initiated, click streams, location information and network/Wi-Fi access points.
Mobile App data: We may obtain information from your mobile device such as your device type, machine or mobile device identification number, location data including time zone, language setting, browser type and IP address.

We use cookies and other tracking technologies to help us collect and process Technical Information. Please see the “How Do We Use Tracking Technologies” section below for more information.

Information We Receive from Third Parties

We also collect and receive information from other sources:

Financial Institution Partners, such as banks, card networks, payment processors, money transmitters, or other entities that provide or support delivery of financial services.
Identity Verification, Fraud and Compliance Monitoring, and Financial and Business Information Providers, which may help us supplement our understanding of your business and its personnel, maintain security, prevent fraud and comply with regulation and contractual obligations.
Service Providers, which help us operate our business.
Social Networks and Advertising Providers, including information provided by marketers and other websites on which Prune advertises, to help us identify or enrich our understanding of prospective customers, and to serve and measure advertising.
Joint Marketing, Business Partnership, Referrals, and Rewards Partners that we engage for joint marketing activities and our referrals and rewards programs.
Other Data Suppliers that provide information about industries, business trends, organizations and other matters related to our business
Publicly-Available Sources, including information in the public domain that helps us identify potential customers and partners or conduct due diligence and risk management for potential and existing customers

How Do We Use The Information We Collect?

We use the information we collect:

To deliver and improve the Services and your overall user experience.
To establish and manage your Prune account, and process and fulfill transactions.
To facilitate transfers or API connections between external bank accounts and your Prune account.
To collect fees and other amounts owed in connection with your Prune account.
To verify your identity, comply with legal and regulatory obligations applicable to us and our financial institution partners, determine the availability of Services offerings, and maintain your account.
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To respond to inquiries, provide customer support and resolve disputes.
To determine your eligibility for, and administer your participation in, certain features of the Services, including but not limited to surveys, promotions and rewards.
To link or combine user information with other Personal Information.
To develop, improve or expand our business, products and services.
To facilitate and manage referrals from business partners and third parties.
To conduct internal reporting, auditing, and research, including focus groups and surveys.
To compare and verify information for accuracy and update our records.
To email, message, or otherwise contact you with information and updates about us and the Services.
To respond to your comments and questions and provide customer service.
To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
To analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services.
To create targeted advertising to promote the Services and engage our users.
To develop de-identified information by removing or masking information that could be used to identify you and by aggregating or combining with other information.
In connection with a merger, acquisition, reorganization or similar transaction.
When required by law or to respond to legal process.
To protect our users, other individual lives, and/or the rights or property of Prune.
To maintain the security of the Services.
At your direction or instruction, or for any other purpose with your consent.

Do We Share Your Personal Information?

In addition to the specific situations discussed elsewhere in this Policy, we disclose Personal Information in the following circumstances:

With our corporate affiliates and subsidiaries.
Plaid: Prune uses Plaid Inc. (“Plaid”) to gather data from financial institutions. By using our service, you grant Prune and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal)
With our banking and other business partners to provide the Services.
With identity verification and customer validation services, as necessary to verify your identity and perform other compliance functions.
With credit reporting agencies and other financial information providers, to verify information about you.
With service providers that perform services to support our core business functions and internal operations, which may include database administrators, cloud computing services, payment processors, advertising services, and application services providers.
With third parties that we have partnered with, such as to jointly create and offer a product or service.
To support our audit, compliance, and corporate governance functions.
In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy).
If we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues.
If required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Prune may do business; (b) protect and defend the rights or property of Prune; (c) act in urgent circumstances to protect the personal safety of users, customers, and contractors/employees of Prune or others; or (d) enforce our Terms of Service or otherwise protect against any legal liability.
With your consent or at your direction.

How Do We Use Tracking Technologies?

Some of the features on the Services may require the use of “cookies” - small text files that are stored on your device’s hard drive. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to remember your preferences, analyze trends, learn about our user base, provide relevant advertising, and operate and improve our Services. We may supplement the information we collect from you with information received from third parties, including information collected using third party cookies. You may delete and block all cookies from our Services, but parts of the Services may not work or your overall user experience may be diminished, since it will no longer be personalized to you. It may also prevent you from saving customized settings, like log-in information.

The following sets out how we may use different categories of cookies. If you prefer not to use cookies, you can modify your cookie preferences for our website here: https://app.prune.com/legal/data-privacy. In addition, most browsers will give you the ability to manage cookies through your browser settings. Please see below for more information about our cookie use and your options for managing browser cookie settings:

Type of Cookies	Description	Managing Settings
Required cookies	Required cookies enable you to navigate the Services and use their features, such as accessing secure areas of the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Services and to process your online transactions and requests.	Because required cookies are essential to operate the Services, there is no option to opt out of these cookies.
Performance cookies	These cookies collect information about how you use our Services, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identify you. Information is only used to improve how the Services functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Services.	To learn how to opt out of performance cookies using your browser settings, click here.
Functionality cookies	Functionality cookies allow our Services to remember information you have entered or choices you make and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.	To learn how to opt out of functionality cookies using your browser settings, click here.
Targeting or advertising cookies	From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Services. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Services. By way of example, as you browse the Services, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other Services based on your previous interaction with the Services.	To learn more about these and other advertising networks and their opt out instructions, click here.

In addition to cookies, we may use other tracking technologies to help us collect and process Technical Information:

Log Files, which are files that record events that occur in connection with your use of technology services, including the Services.
Pixels (also known as web beacons), which are code embedded in a website, email, application or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access technology that contains a pixel, the pixel may permit us or a separate entity to track your interactions. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising, and provide you with additional functionality.

Analytics and Interest-Based Advertising

We may use analytics services to help us understand how users access and use the Services and other aspects of our products and services. In addition, we work with agencies, advertisers, ad networks, and other technology services to place advertisements on our behalf on other websites and services. Our third party analytics services providers and advertising providers may use cookies and other tracking technologies to collect and store data Technical Information to be used for the purposes outlined in this Privacy Policy. For example:

Google Analytics. We use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Our third-party advertising service providers may use web pixels to recognize you when you visit the Services and to help determine how you found the Services. They may also use cookies, action tags, web beacons, and/or GIF tags placed in various places on the Services and our online ads to collect information about your visit and your interaction with our ads. To limit collection of information from mobile devices, including location data, please visit your device’s settings to set the “Limit Ad Track”, “Location Based Services,” or other similar feature on your device. You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the NAI (https://optout.networkadvertising.org/) or DAA (https://optout.aboutads.info/). If you opt-out of interest-based ads, you will still see ads on websites you visit, but those ads will not be based on your browsing behavior. For the Prune mobile app, iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs. You can change your preferences on your device.

How Do We Secure Your Personal Information?

We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. The safety and security of your Personal Information also depends on you. If you have an account with us, you are responsible for keeping your membership details confidential. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using the Services, you acknowledge that you understand and agree to assume these risks.

Data Retention

We retain your Personal Information while your account is in existence or as needed to provide the Services to you. This includes data you or others provided to us and data generated or inferred from your use of the Services. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Managing Your Privacy

All users may request to review, update, correct or delete the Personal Information furnished by a user in their user account by contacting us at support@prune.com or by accessing your user account settings. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account may become deactivated. If you wish to cancel your account, you may do so through your account page, and any personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may further retain your information as required by law or for our legitimate business purposes and/or as necessary to comply (or demonstrate compliance with) our legal and regulatory obligations, solve disputes, prevent fraud and enforce our rights.

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language) in those communications. For text message communications, you can text back “STOP” and we will send you a text message to confirm that you have been unsubscribed. You can also contact us at support@prune.com to opt out. Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our terms of service or privacy policy.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Children Under 16

The Services are not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at support@prune.com and the information will be deleted.

Third Party Direct Marketing

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

A Note to Users Outside the United States

Prune is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the laws of the country(ies) where the Services are controlled. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you have any questions about this Policy, your Personal Information, or the Services, you can contact support@prune.com.