Privacy Notice

Last updated: October 7th 2022

Argyle Systems Inc.’s (“Argyle,” “we,” “us,” or “our”) mission is to empower consumers by giving them tools to access and make their own data portable. Argyle’s data portability solutions and related offerings provide an easy way for you to connect your accounts containing your income and employment-related information and deliver that information to providers that need it in connection with your relationship with them. By facilitating the delivery of your data in a high quality and standardized manner to those providers that you direct and providing related services, we enable you and those providers to focus on building the relationships that benefit you.

Argyle knows privacy is very important to you. We believe in consent and transparency in data collection and use. You own your data and have the right to grant or revoke access. Helping you understand our privacy practices is core to our mission. In this Privacy Notice (“Privacy Notice”), we describe what kinds of information (including personal information) we may obtain from and about you through your use of (i) Argyle Link, the consumer-facing part of the Argyle Platform  (“Employment Data”), and (ii) Argyle’s website (https://www.argyle.com) (the “Argyle Website” and that information “Your Data”). The Argyle Platform and the Argyle Website are together the “Services.” We explain how we may use and disclose that information, the steps we take to keep it secure, your choices regarding our use of this information, and how you can contact us if you have any questions about our privacy practices. Capitalized terms used but not defined in this Privacy Notice shall have the meanings given in the End User Terms.

Argyle Link

A. Employment Data

At your instruction, we use log-in credentials you provide on Argyle Link to electronically retrieve information from C Locations and transmit that information to the Clients that you direct and with whom you have a contractual relationship (such as insurance providers, mortgage lenders, or their service providers). The information we retrieve on your behalf from Data Locations varies depending on what information is available under your credentials, and the information we transmit varies depending on what information the specific Client has requested that you provide. That information generally includes:

Identity and Address Information: Your first and last name, personal and/or business phone number, street address, zip code, and email address, your date of birth, gender, marital status, picture, Social Security Number, and other government IDs, vehicle information, and other identifiers;

Career Information: Employer name and address, job title, employment type, employee ID, employment status, date of hire, termination date and reason, performance rating and achievements, hours worked (e.g., shift information), timestamps, work location, certifications, and licenses; and

Income and Financial Information: Compensation (including, as applicable, bonuses, commission, tips, and overtime), payout type and dates, currency, fees deductions, withholdings, reimbursements, balances, filing status, bank account and routing number, and credit card number and expiration date; and

When providing Your Credentials, you give Argyle the authority to act as your information transfer agent and instruct Argyle to access and transmit information from the relevant Data Locations to the Client that has requested that you provide that information. You communicate those instructions to us through Argyle Link.

B. How We Use Employment Data

Service-Related Usage: We use your Employment Data to provide and support the Argyle Platform, including delivery of Employment Data to those Clients you direct, and to communicate with you and Clients (including for purposes of support and account maintenance). 

Analyzing and Improving the Argyle Platform:  We may run calculations and analytics, and/or aggregate, normalize, clean, and make derivative works of Employment Data in order to (i) analyze and understand usage trends and preferences, (ii) monitor and analyze the effectiveness of the Argyle Platform, (iii) improve and further enhance the Argyle Platform including through development of products, services, features, and functionality; and (iv) test the Argyle Platform and our infrastructure to make sure the Argyle Platform is working correctly.

C. How We Share Employment Data

We share Employment Data only in the following circumstances:

  1. Clients: We share Employment Data with Clients at your instruction as described in the End User Terms.
  2. Service Providers: We share Employment Data with third parties that provide services to us, such as customer support, providers of information technology and system security, integration services (including integration builds and related support),  and other organizations that provide similar services. We do not, however, authorize  any such third parties to use or disclose your Employment Data except as necessary to perform the activities described in Section I.B. of this Privacy Notice or as required for such third parties’ compliance with legal requirements.
  3. Legal Requirements; Affiliates and Successors:  We may disclose Employment Data as required for compliance with legal requirements and to affiliates and successors as set forth in Section II.C. of this Privacy Notice.

We are not in the business of selling your Employment Data, and we use and share it only as described in this Privacy Notice. We do not use or share your Employment Data for any kind of marketing or advertising.

D. Client and Third Party Use of Employment Data

Section I of this Privacy Notice only addresses our collection, use, and sharing of Employment Data. Clients will use, share, and process Employment Data that we deliver to them on your behalf (and any other information they may collect about you separately from Argyle) in accordance with their own privacy policies. Our Privacy Notice also does not cover any websites, mobile applications, products, or services provided by other third parties (including any Client Applications). We encourage you to review the privacy policies or notices of Clients and/or those third parties for information about their data privacy and security practices.

E. Retention and Deletion of Employment Data

We retain Employment Data for no longer than necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required under applicable law. As permitted under applicable law, even after you stop using a Client Application or terminate your account with one or more Clients, we may still retain your information (for example, if you still have an account with another Client). At all times, Employment Information will only be processed as required by law or in accordance with this Privacy Notice.

Argyle’s systems are designed to automatically delete your Employment Data when you delete Your Credentials for a Data Location via Argyle Link (as integrated into a Client Application). The exceptions to this may be if: (a) you’ve established a connection with another Client Application through Argyle that is still active; (b) Argyle needs your Employment Data to continue providing you with an Argyle service you requested, or to carry out another notified purpose with your consent; (c) Argyle is required by law to keep your Employment Information; or (d) Argyle needs your information to help prevent fraud or protect privacy, provide support, or investigate misuse and misconduct.

Argyle Website

A. Your Data

Separate from Employment Data, we collect the following information in connection with your use of the Services:

  1. Information you provide to us:  We collect information you provide to us when you use the Services or otherwise communicate with us including contact information, such as your name, postal address, email address, and phone number, information shared with us in emails, messages or requests for support; and any other information about yourself that you choose to provide.
  2. Information we collect automatically:  Like most online services, we automatically receive standard technical information when you connect with the Services. We collect this information through browser cookies, pixels, web server logs, web beacons, and similar technologies. These features enable us to personalize your experience with the Services, understand how you use them, maintain a persistent session, and improve and further develop the Services. Information we collect automatically includes or could include: browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), user agent string (e.g., operating system and browser type/version), and the date and time of your interactions; information about your interactions with the Services, such as which pages of our Website you visited and how much time was spent on the page.
  3. Information collected through third-party analytics services:  We use Google Analytics and, from time to time, other third–party web analytics services to evaluate your use of the Services and to help us improve our performance and to develop new products, services, features, and functionalities. The third–party analytics services collect and analyze information about your online activities on the Argyle Website, third-party websites, apps, and other online services, and across your electronic devices. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. For a list of our third party analytics services and how to opt-out, please contact us at: [email protected]. Please be advised that if you opt out of any third party analytics service, you may not be able to use the full functionality of the Services.
  4. Tracking Data:  We collect tracking data using first and third-party cookies, pixels, web server logs, web beacons, and similar data collection and tracking technologies on the Argyle Website, third party websites, apps and online services, and across your devices (such as IP address, browser, type, ISP, platform type, device type). Third parties such as advertising networks and analytics providers may also collect information about your online activities over time and across different websites and devices when you access or use the Services. However, we do not currently track, or let third parties track, personally identifiable information about your online activities over time and across different websites, apps, and devices when you use our Services.
  5. Service Providers and Partners:  We may receive information about you from our service providers such as analytics services (above), and our partners such as ad campaign information (e.g., the ads you click on).

Geolocation Information:  We collect or receive information from your device or browser including geographic location, typically your log-in location for the Services, such as a city or country. We do not “track” your precise geolocation information, but we need to use your general location in order to provide the Services. We will not collect your geolocation information when you are not logging in or use the Services. For information about how to turn off geolocation services please seen Section II.C of this Privacy Notice.

B.

Except with respect to Your Data that is information we collect automatically in connection with your use of Argyle Link, we do not comingle your Employment Data with Your Data. Our use, sharing and disclosure practices for Your Data are set forth in this Section II of the Privacy Notice.

C. How We Use Your Data

We use Your Data to provide the Services and to operate our business, including:

  1. Service-Related Usage:  We use Your Data to provide and support the Services, such as communicating with you and other End Users, managing End User accounts, providing support services, and maintaining our systems. We also use Your Data to communicate with Clients and respond to their support requests, including account management, and offering technical support.
  2. Analyzing and Improving the Services:  We may run calculations, aggregate, normalize, clean, and make derivative works of Your Data in order to (i) understand and analyze usage trends and preferences, (ii) monitor and analyze the effectiveness of the Services, (iii) improve the Services and develop new products, services, features, and functionality; and (iv) test the Services and our infrastructure to make sure the Services are working correctly.
  3. Marketing:  If you enter your contact information on the Argyle Website and opt-in to receive electronic marketing communications from us, we may provide you with promotional materials that could be useful, relevant, valuable, or otherwise of interest to you. We will not send you marketing emails if you have not signed up for this, and you can unsubscribe from receiving such emails at any time by clicking on the “unsubscribe” link at the bottom of all our marketing emails.

Advertising:  Argyle, its business partners and advertising/marketing companies use Your Data to tailor, analyze, manage, report and optimize advertising you see on the Services, and on other sites and apps that you access and/or use through your devices. By accessing and using the Services, you consent to the processing of Your Data for these purposes.

D. How We Share Your Data

We share, transfer, or disclose Your Data if you consent to us doing so, as well as in the following circumstances:

a. Service Providers:  We also share information with third parties who provide services to us, such as customer services, website management, information technology and IT security, auditing, payment processing, data analytics, advertising, and other similar service providers (e.g., our affiliates other entities with which we are building technology integrations). We do not authorize these individuals or entities to use or disclose Your Data except for as necessary to engage in the activities described in Section II.B. of this Privacy Notice or to comply with legal requirements.

b. Marketing and Advertising:  Argyle shares some of Your Data, including Tracking Data, with marketing firms and advertisers/remarketing providers for the purpose of Marketing and Advertising (as described above). You may set your mobile device to limit ad tracking, in which case we will not be able to see your ADID or IDFA.  By accessing and using the Services, you consent to the processing of data about you by these third parties advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Notice.

d. Compliance with Legal Requirements:  We may disclose Your Data if required or permitted to do so to:

  • Comply with applicable laws and legal processes;
  • Respond to requests from law enforcement authorities, public and government agencies or officials, or other persons or entities with appropriate legal authority or justification to receive such information, including persons or entities outside your country of residence; and
  • Protect our rights, privacy, safety, or property, and / or that of our affiliates, you, or others. d. Affiliates and Successors:  We may share some or all of Your Data with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us. Further, as we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, Your Data may be part of the transferred assets.

e. Aggregated, De-Identified Information:  We may use Your Data to create aggregate or statistical information that does not directly identify a specific person, and we may share that information with third parties. For example, we may share anonymous and aggregated reports and information on user demographics and industry patterns with third parties.

E. Links to Other Websites, Devices, Apps and Features

The Services may contain links to third-party websites (“External Sites”). We have no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for their content, use or privacy practices. We strongly suggest that you review the applicable privacy policies and terms of service when visiting any External Sites.

F. Cookies and Your Choices

Cookies are small packets of data that a website stores on your device or browser so that you device will recall your preferences and usage patterns for future visits. We use both 1st and 3rd-party session cookies and persistent cookies. If you do not want us to place a cookie on your device, you may be able to turn that feature off. You can find out how to do this for your specific browser by clicking “help” on your browser’s menu. On mobile devices, you can decide how Your Data is shared by adjusting the privacy and security settings. Please note, however, that if you decide not to accept cookies from us, certain aspects of the Services may not function properly or as intended. To find out more about cookies on our Services and other websites and apps that you access or use, including how to see what cookies have been set and instructions for turning off the feature, visit: www.aboutcookies.org or www.allaboutcookies.org.

If you have consented to geolocation services through your browser’s settings, please consult your browser’s documentation regarding how to turn off location services. Note, however, that if you disable location services, you may not be able to use the full array of features and functionalities available through the Services.

G. Do Not Track

Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, the Services do not respond to “Do Not Track” settings or other related mechanisms.

GDPR Notice

A. Additional Rights

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may have additional rights with respect to your personal data under the EU General Data Protection Regulation (“EU GDPR”), and the EU GDPR as saved into United Kingdom law by the United Kingdom's European Union (Withdrawal) Act 2018 (“UK GDPR”) **(**together, the “GDPR”), as set forth in this GDPR Notice (the “GDPR Notice”). This GPDR Notice applies to your personal data (as defined in the GDPR) included in the Employment Data and/or Your Data. 

B. Lawful Basis(es) for Processing Your Personal Data

We will only process (as defined in the GDPR) your personal data if we have a lawful basis for doing so. Under the GDPR, the lawful bases we rely on for processing this information are:

a. Your Consent: In some cases, we process personal data based on the consent you expressly grant to us at the time we collect such data. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection. You can remove your consent at any time by contacting us via email at [email protected] with the subject line “GDPR Request.”

b. We Have a Contractual Obligation: We may process your personal data as a matter of “contractual necessity,” meaning that we need to process the data to provide the Services under our End User Agreement. When we process data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such data.

c. We Have a Legitimate Interest:  We process your personal data when we believe it furthers the legitimate interests of us or third parties. Our legitimate interests are:

  • Information Security
  • Operation and Improvement of our Services:
  • Audience Measurement and Marketing
  • Direct Marketing
  • General Business Development and Management
  • Protection or Enforcement of Right

d. We Have a Legal Obligation: We may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

C. Your Data Protection Rights

You have certain rights with respect to your personal data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected] with the subject line “GDPR Request.” You are not required to pay any charge for exercising your rights.

Where we are acting as a data processor of your personal data, we will advise you promptly so you can redirect your request to the appropriate data controller.

Where we are acting as a data controller of your personal data, there may be circumstances where we are not able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

  • Right of access: You can request more information about the personal data we hold about you and request a copy of such personal data.
  • Right to rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Right to erasure: You can request that we erase some or all of your personal data from our systems.
  • Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data.
  • Right to object to processing: You have the the right to object to the processing of your personal data in certain circumstances.
  • Right to data portability: You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Right to withdraw consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to [email protected] with the subject line “GDPR Request.” In such case, your personal data will no longer be used for that purpose.

Where we are acting as a data controller for your personal data, we will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Please note that all of these rights are subject to applicable exemptions and restrictions, and are not absolute rights. If we need to rely on these exemptions or restrictions, we will provide this information to you in our response.

D. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us at privacy[at]agltd.com with the subject line “GDPR Request.”

You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority of the European state where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

E. Transfers of personal data

We will transfer your personal data outside the EEA and/or the UK only when such transfer is necessary for the performance of a contract between us (or implementation of pre-contractual measures taken at your request), with your express consent, and/or through the use of the EU Commission-approved or UK Secretary of State-approved (as applicable) standard contractual clauses, if necessary, and in combination with additional safeguards. You can ask for a copy of these standard contractual clauses or other measures by contacting us at [email protected].

F. Updates to this GDPR Notice

If, in the future, we intend to process your personal data for a purpose that is not set forth in our Privacy Policy (or is incompatible therewith), we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Last Updated” at the top of this page will be updated accordingly.

General

A. Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Services is directed to children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at the contact information listed below. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

B. How We Protect Your Data

We use physical, organizational, and technical safeguards that are designed to protect the integrity and security of Employment Data Your Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security measures are perfect or impenetrable. We thus cannot guarantee the security of our databases, Employment Data, or Your Data, nor can we guarantee that your Employment Data will not be intercepted while being transmitted over the internet to and from us, a Data Location, or a Client.

C. Updates to This Privacy Notice

We may update this Privacy Notice from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Notice when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes.

D. Notice to California Residents

If you are a resident of California, you have additional rights under the California Consumer Privacy Act (the “CCPA”). For more information about your rights under the CCPA, please visit our CCPA Privacy Notice.

E. Notice to Nevada Residents

If you are located a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

F. How to Contact Us

If you have any questions or comments about this Privacy Notice, our privacy practices, or if you would like to exercise your rights and choices, please contact us at [email protected].