Privacy Policy
Effective Date: 11.01.2025
Version: 1.0
This Privacy Policy outlines how Analog Financial, Inc. (“Analog,” “we,” “our,” or “us”) collects, processes, shares, and protects personal and financial information. As a financial technology (“fintech”) company, Analog is committed to maintaining transparency, accountability, and compliance with applicable data protection laws, including the Gramm-Leach-Bliley Act (GLBA), the California Consumer Privacy Act (CCPA), and the European Union and United Kingdom General Data Protection Regulations (GDPR and UK GDPR).
This policy covers:
This Policy applies to all individuals and businesses who interact with Analog Financial’s digital platforms, including customers, applicants, business partners, and visitors to our websites or mobile applications. It covers personal data collected through Analog’s proprietary financial systems, mobile apps, APIs, and third-party integrations.
While no organization can guarantee perfect security, Analog has implemented and continuously seeks to improve technical and organizational security measures to protect the information provided via the Services from loss, misuse, unauthorized access, disclosure, alteration, or destruction.
If you have created an account with us, you are responsible for keeping confidential any usernames and passwords you use to access our Services. Do not share this password with anyone else, and do not use this password for other services or products.
We also recognize the importance of protecting privacy where children are involved. Individuals under the age of 18 are not eligible for our Services. As such, our Services are not marketed to individuals under the age of 18, and we request that these individuals not provide any information through our Services. We do not knowingly collect or solicit any information from children under 18. In the event that we learn that we have inadvertently collected personal information from a child under age 18, we will take reasonable steps to delete this information. If you believe that we might have any information from a child under 18, please contact us at info@goanalog.com
Keeping your personal information accurate and up to date is very important. If your personal information is incomplete, inaccurate, or not current, please use the Contact Us option on our Services, or call us at the appropriate telephone number for changes listed on your account records or other account materials.
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 that you provide to us, or that we obtain automatically when you use our Services, and we may additionally obtain information about you from third parties. The personal information we collect is limited to what is required to provide our products or services and to support legal and risk requirements.
In addition to our banking partners, we also collaborate with third-party companies to perform certain business-related functions, which may also collect personal information from or about you. For more information about our Service Providers, please see “How We Use and Share Your Information,” below.
We collect personal information about you through your computer or mobile devices by the use of cookies and similar tracking technologies, as well as personal information you provide when you visit or use our Services, for example, when you:
Analog and our Partners may engage with customers on social media platforms such as Meta®, Twitter®, YouTube® and LinkedIn®, and others.
Any content you give Analog permission to post on official Analog-managed social media pages, such as pictures, information, or opinions, is subject to the Terms of Use and Privacy Policies of those respective platforms.
If you opt in, Analog may send SMS or MMS messages relating to account registration, one-time passcodes (OTP), identity verification, fraud alerts, security notifications, application status, transaction activity, customer support, and other operational account servicing communications. Message frequency varies. Message and data rates may apply. Reply STOP to opt out of non-essential messages. Reply HELP for assistance.
Analog does not use SMS as a general advertising channel. We do not sell, rent, or share mobile telephone numbers or SMS consent information with third parties or affiliates for their own marketing or promotional purposes. Mobile numbers and consent records are shared only with service providers acting on our behalf to deliver requested communications.
We do not sell Personal Information. We may disclose Personal Information to service providers, banking partners, payment processors, fraud prevention providers, regulators, law enforcement, or professional advisers where necessary to provide our Services or comply with law.
We use cookies and similar technologies to support website functionality, security, and analytics. You may manage cookies through your browser where applicable.
The type of personal information we collect from and about you online will depend on how you interact with us and may include:
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 (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. Analog 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.
To the extent we use Google or Facebook for advertising purposes on our Website, including remarketing features of those products, please see these links provided by these respective companies for opt-out purposes: Google / Facebook. We are not responsible for the scope of, or the honoring of, any such opt-outs, as opt-out preferences provided by these companies are not under our control.
You may 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 Do-Not-Track (“DNT”) signals, which are a privacy preference that users can set in certain web browsers, because 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.
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.
How do we use your personal information?
Personal information collected from and about you online described in this Policy, may be used for purposes including:
We may share the personal information we collect from and about you online described in this Policy (and subject to other legal restrictions and notices you may have received depending on your relationship with us), as set forth below. Analog does not sell your personal information.
In addition to the above, collected personal information may be aggregated and/or de-identified to remove any details that identify you personally. We may share this aggregated and/or de-identified information with third-party providers to help deliver products, services and content that are better tailored to the users of our online services and for our own business purposes where permissible under applicable laws and regulations.
Some companies may offer aggregation websites and services that allow you to share your data with them to consolidate your account information from different sources so that you can view it in one location or perform actions related to your accounts using their services. To do this, a third party may request you to authorize access to your Analog accounts by providing your Analog username and passcode or by providing your information-sharing consent directly to Analog. If you allow a third party to access your Analog accounts, please remember:
The third party may access, on your behalf, information about yourself, your Analog relationship, and your accounts at Analog.
You should use caution and ensure that the third party has appropriate policies and practices to protect the privacy and security of any personal information you provide or to which they are gaining access.
Use of your information by the third party is governed by your agreement with them, not by Analog.
We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your username and passcode.
If you share your Analog username and passcode or other information about your accounts with others, we will consider that you have authorized any transaction or action initiated by using the access information you provide.
If you decide to revoke the authority you have given to a third party, we strongly recommend that you change your Analog passcode to ensure that the third party cannot continue to access your account.
When you sign up for an account with Analog, we may collect and use your personal information on behalf of our Bank Partners to facilitate the provision of banking services pursuant to our Bank Partners’ Privacy Notice. The privacy practices of our Bank Partners are subject to their privacy notices, which we strongly suggest you review. Analog is not responsible for our Bank Partners’ information practices or privacy notices.
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.
Depending on your location, you may have certain rights regarding your personal information under applicable laws, including the California Consumer Privacy Act (“CCPA”), the General Data Protection Regulation (“GDPR” and “UK GDPR”), and the Gramm-Leach-Bliley Act (“GLBA”). Analog respects these rights and will not discriminate against individuals for exercising them.
Access and Portability: You have the right to request access to the personal information we maintain about you, including details regarding the categories of data collected, how it is used, and the third parties with whom it is shared. You may also request a copy of your personal information in a portable, readily usable format, where feasible. If we have maintained your personal information for longer than 12 months, you may exercise your right to know looking back to January 1, 2022
Correction (Rectification): If any of the personal information we maintain about you is inaccurate or incomplete, you may request that it be corrected or updated.
Deletion (Right to Erasure): You may request the deletion of your personal information, subject to certain exceptions permitted by law. For example, we may retain data necessary to complete transactions, detect or prevent fraud, comply with legal obligations, or maintain business records.
Opt-Out of Sale or Sharing: Analog does not sell personal information. However, you may choose to opt out of the sharing of your personal information for purposes of targeted advertising or cross-context behavioral advertising. To exercise this right, please contact us using the information provided under “Contacting Analog.”
Limit Use and Disclosure: We do not collect nor engage in uses of sensitive personal information that would trigger a right to limit use and disclosure of sensitive Personal information under applicable state privacy law.
Opt-Out of Profiling with Legal or Significant Effects: You may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not engage in such activities as described under applicable state privacy law, so there is no need to exercise this right.
Right to Non-Discrimination: You will not be discriminated against for exercising any of your privacy rights. This means Analog will not deny you goods or services, charge different prices, or provide a different level or quality of services based on the exercise of your rights.
Right to Lodge a Complaint: If you are located in the European Union or the United Kingdom, you have the right to lodge a complaint with your local Data Protection Authority (“DPA”) if you believe we have not complied with applicable data-protection laws. A list of EU supervisory authorities is available here.
To exercise any of the above rights, please contact us at privacy@heyanalog.com or by mail at the address listed in “Contacting Analog.” We may require verification of your identity before fulfilling your request.
Information We Collect
As more fully described above, we collect (and have collected within the last twelve (12) months) the following categories of personal information:
· Identifiers
· Commercial information
· Internet or other electronic network activity
· Protected Classifications
· Geolocation data
· Employment Information
· Sensitive Personal Information
· Inferences
Disclosure of personal information to Third Parties and Other Recipients
Categories of personal information that May Be Sold, Shared, or Disclosed | Categories of Third Parties to whom personal information May Be Sold, Shared, or Disclosed | Business or Commercial Purpose of Selling, Sharing, or Disclosing personal information |
Identifiers |
| · Provide the services · Communicate with you · Monitor the services · Market & Advertise the services · Respond to Inquiries and Fulfill Requests · Improve the services · Support business operations · With your Consent |
Inferences |
| · Provide the services · Market & Advertise the services · Improve the services · Support business operations · With your Consent |
Protected Classifications |
| · Provide the services · Support business operations · With your Consent |
Sensitive Personal Information |
| · Provide the services · Support business operations · With your Consent |
Internet or Other Electronic Network Activity |
| · Provide the services · Monitor the services · Improve the services · Market & Advertise the services · Support business operations · With your Consent |
Geolocation Data |
| · Provide the services · Monitor the services · Improve the services · Market & Advertise the services · Support business operations · With your Consent |
Analog processes personal data only when it has a lawful basis under applicable data-protection laws. These include:
Your personal information may be transferred to, stored, or processed in countries other than your own, including the United States, where data-protection laws may differ from those of your jurisdiction.
When we transfer personal information outside your jurisdiction, we implement appropriate safeguards to protect your information in compliance with applicable law. These measures may include the use of Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms recognized under the GDPR or UK GDPR.
Analog 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, including by posting an updated “Last Modified” date on this page. Please review this Policy periodically for any updates or changes. 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. If you disagree with our revisions to the Policy, you can deactivate your account or otherwise discontinue the use of our Services.