Last Updated: March 10, 2023
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, employment, and other work-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.
1. Argyle Link
1.1. Employment Data: At your instruction, we use log-in credentials you provide on Argyle Link to electronically retrieve information from Data 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:
a. 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;
b. 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
c. 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.
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.
1.2. How We Use Employment Data:
a. 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).
b. 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. Aggregated, De-Identified Information. We may use Employment Data to create aggregate, statistical, or de-identified information that does not identify a specific person, and we may use that information for any permissible purpose or share that information with third parties.
1.3. How We Share Employment Data: We share Employment Data only in the following circumstances:
a. Clients: We share Employment Data with Clients at your instruction as described in the End User Terms.
b. 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 1.2 of this Privacy Notice or as required for such third parties’ compliance with legal requirements.
c. 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 2.4 of this Privacy Notice.
d. Aggregated, De-Identified Information: We may share aggregate, statistical, or de-identified information that does not identify a specific person that results from our use of Employment Data as set forth in Section 1.2.c.
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.
1.4. Client and Third Party Use of Employment Data. Section 1 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 notices. 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.
1.5. 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.
2. Argyle Website
2.1. Your Data: Separate from Employment Data, we collect the following information in connection with your use of the Services:
a. 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.
c. Service Providers and Partners: We may receive information about you from our service providers such as analytics services, and our partners such as ad campaign information (e.g., the ads you click on).
2.2. Data Commingling. Except with respect to Your Data that is information we collect automatically in connection with your use of Argyle Link, we do not commingle your Employment Data with Your Data. Our use, sharing and disclosure practices for Your Data are set forth in this Section 2 of the Privacy Notice.
2.3. How We Use Your Data: We use Your Data to provide the Services and to operate our business, including:
a. 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.
b. 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.
c. 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.
d. Advertising: Argyle, its business partners and advertising/marketing companies use Your Data, subject to your consent where required, 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.
e. Aggregated, De-Identified Information: We may use Your Data to create aggregate, statistical, or de-identified information that does not identify a specific person, and we may and we may use that information for any permissible purpose or 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.
2.4. 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.
c. Compliance with Legal Requirements: We may disclose Your Data if required or permitted to do so to:
(i) Comply with applicable laws and legal processes;
(ii) 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
(iii) 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 share aggregate, statistical, or de-identified information that does not identify a specific person that results from our use of Your Data as set forth in Section 2.3.e.
2.5. Retention and Deletion of Your Data. We retain Your 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. At all times, Your Data will only be processed as required by law or in accordance with this Privacy Notice.
2.6. 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.
2.7. 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.
3.1. Children’s Privacy: We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of the Services is directed to children under the age of 16. 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 16, we will promptly take steps to delete such information and terminate the child’s account.
3.2. How We Protect Your Data: We use physical, organizational, and technical safeguards that are designed to protect the integrity and security of Employment Data and 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.
3.3. Updates to This Privacy Notice: We may update this Privacy Notice from time to time 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. If we make material changes we will let you know.
3.4. 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 Notice.
3.5. Notice to Nevada Residents: If you are 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 or the Client you connected your account to through Argyle.
3.6. Notice to EU and UK Residents. If you are a resident of the European Union or the United Kingdom, you have additional rights under the General Data Protection Regulation and the United Kingdom General Data Protection Regulation (respectively the “GDPR” and the "UKGDPR"). For more information about your rights thereunder, please visit our GDPR Notice.
3.7. 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]