Privacy Notice
Last updated: October 1, 2026
Argyle Systems Inc. (“Argyle,” “we,” “us,” or “our”) builds consumer-directed verification technology that you can use to share records about you — from accounts you connect, and from other sources you direct Argyle to ask — with organizations you have a separate relationship with, including your bank, insurance provider, mortgage lender, property lessor, gig-work assistance provider, prospective employer, or a government agency administering public benefits. We believe in transparency about how that works.
This Privacy Notice (“Privacy Notice”) describes the information we obtain from and about you (a) in connection with your use of Argyle’s platform (the “Platform”) and from the other sources described in Section 1.1 (together, “Your Records”), and (b) through your use of Argyle’s website at argyle.com (the “Website,” and that information, “Your Data”). The Platform and the Website are together the “Services.” It explains how we use and share that information, how we protect it, the choices you have, and how to reach us.
We are a financial institution under the Gramm-Leach-Bliley Act, and we use and share Your Records consistent with our obligations under that Act. See our GLBA Privacy Notice.
Capitalized terms used in this Privacy Notice have the meanings given here or in the Consumer Terms.
1. Platform.
1.1 What We Obtain and Where It Comes From. You reach your records through the Platform in the ways described in Section 1 of the Consumer Terms. Your Records come from two sources, and you also give the Platform your Credentials.
(a) Records you connect. At your direction, the Platform uses the Credentials you provide through Argyle Link to obtain the information available under those Credentials at the Data Location you select, and delivers it — or the part of it a recipient requests — to the Partner whose process brought you to Argyle Link, to another company that Partner uses to provide you the products, services, or benefits you are seeking, and to any other third party you direct.
(b) Your Credentials. To create a Connection you give the Platform your Credentials for the Data Location you select — a username and password, a one-time passcode, or whatever else that Data Location uses to sign you in, including through a separate identity service it relies on. We use your Credentials only to make and maintain the Connection you directed, and we protect them with the safeguards described in Section 3.2. Partners never receive your Credentials. When a Connection ends, the Platform is designed to delete the Credentials you provided to create it; your Credentials for other Connections are not affected.
(c) Employer outreach requested by a Partner. In some cases Argyle contacts an employer directly — for example, by calling its verifications line — at a Partner’s request, as described in Section 3.1 of the Consumer Terms. Argyle obtains the fact and outcome of that contact, the employer’s response, and any recording or transcript of the call. Section 1.6 describes the capacity in which Argyle acts and what follows from it.
1.2 What the Records Contain. Your Records include both individual pieces of information — a pay date or an employer name, for example — and whole documents, such as a paystub or a tax form. What Argyle obtains depends on the source. From a Data Location it is what is available under your Credentials there, and the Platform is not designed to reach anything more; from an employer contacted at a Partner’s request, it is what that employer provides. In general, they include, to the extent available:
(a) Identity and address information. Your first and last name, personal or business phone number, street address, zip code, and email address; your date of birth, gender, marital status, Social Security number and other government identifiers; 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.
(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 other payment-account information — including related documentation such as paystubs and tax forms.
(d) Other work-related information. Gig or task count, request and acceptance times, start and end times, pick-up and drop-off times and locations, break start and end times, and distance traveled.
(e) Employer responses. The fact and outcome of the contact, the employer’s response, and any recording or transcript.
(f) Tax records. The contents of the Tax Records you direct Argyle to obtain. These may include income reported to the tax authority by employers and other payers whose records you did not connect and, where the record relates to a jointly filed return, information about the person who filed with you. The collection, use, sharing, and retention practices described in this Privacy Notice apply to Tax Records, except to the extent applicable law restricts a particular use.
For Argyle’s full data taxonomy, see the Data Sets section of Argyle’s technical documentation at docs.argyle.com.
Some of this is “sensitive personal information” or “sensitive data” under state privacy laws — your Social Security number and other government identifiers, your financial account and routing numbers, and your Credentials. Section 1.1(b) describes how we handle your Credentials. We collect and use this information only to do what you directed the Platform to do and for the security, fraud-prevention, and service-quality purposes described in Section 1.4.
1.3 Direction Records. Argyle creates and keeps a record of the direction itself: the Data Location you selected, the confirmation you gave in Argyle Link and when you gave it, the Partner whose process brought you to Argyle Link, the deliveries made under your direction, and technical details of the session in which you acted, such as your IP address and device information (your “Direction Records”). Direction Records are our record of what you authorized. They do not contain Your Records. They are not Your Records and not Your Data, and Section 1.8 explains how long we keep them and why.
1.4 How We Use Your Records and Direction Records.
(a) Providing the Platform. We use Your Records and Direction Records to provide and support the Platform as described in the Consumer Terms, including delivering them to the recipients described in Section 1.5, and to communicate with you and with Partners about support and maintenance.
(b) Analyzing and improving the Platform. We may standardize, categorize, merge, aggregate, normalize, and otherwise process Your Records and Direction Records, in order to analyze usage trends and preferences, monitor and analyze how well the Platform works, improve and extend the Platform and develop new features, and test the Platform and our infrastructure.
(c) Aggregated information. We may use Your Records and Direction Records to create aggregated and statistical information about groups of people, from which individual identities have been removed and which is not linked to any individual. We may use it and provide it to others for any lawful purpose.
(d) De-identified information. We may also create de-identified information from Your Records and Direction Records, and we take reasonable measures to ensure it cannot be associated with you or your household. We do not attempt to re-identify it, except to test whether our de-identification works. We may use it and provide it to others for any lawful purpose.
(e) Direction Records. We use Direction Records to provide and support the Platform, to establish and administer your direction, to respond to your requests, to comply with law, and to protect against fraud and misuse. We may provide a Direction Record to a Data Location, a Partner, a regulator, or a court to establish that you authorized what Argyle did. We do not use Direction Records for marketing or advertising, and we do not sell them or share them for advertising.
1.5 How We Share Your Records. We share Your Records and Direction Records only in the following circumstances and, as to Direction Records, as described in Section 1.4(e).
(a) Partners and other recipients. At your direction, we share Your Records with the Partner whose process brought you to Argyle Link, with another company that Partner uses to provide you the products, services, or benefits you are seeking, and with any other third party you direct. What we deliver to a Partner on your behalf is what that Partner selects, using the Partner-facing features and functionalities of the Platform, in connection with providing you those products, services, or benefits. That may be less than what the Platform obtains, and it is never more. Section 4 of the Consumer Terms sets out the authority you grant Argyle to do this.
(b) Service providers. We share Your Records and Direction Records with third parties that provide services to us, such as customer support, information technology and system security, integration services, and similar functions. We do not authorize them to use or disclose Your Records or Direction Records except as necessary to perform the activities described in Section 1.4 or as required for their own compliance with law. Our service providers may be located in the United States, Canada, or other jurisdictions.
(c) Legal requirements, affiliates, and successors. We, and our service providers, may disclose Your Records and Direction Records as required for compliance with legal requirements, and to affiliates and successors, as described in Section 2.4.
(d) Aggregated and de-identified information. We may share the information described in Sections 1.4(c) and 1.4(d).
Argyle does not sell Your Records or Direction Records, and does not share them for cross-context behavioral advertising or any other targeted advertising. We do not use them for marketing or advertising. We use and share them only as this Privacy Notice describes.
1.6 When a Partner Asks Instead of You. Where Argyle contacts an employer at a Partner’s request under Section 1.1(c), the capacity in which Argyle acts depends on whether you have connected a Data Location in connection with that product, service, or benefit. Where you have, Argyle acts both as your agent under Section 4 of the Consumer Terms and on that Partner’s behalf under the authorization you gave that Partner, and this Privacy Notice governs what Argyle does with what it obtains. Where you have not, Argyle acts only on that Partner’s behalf (and not on yours), and Argyle handles what it obtains under its agreement with that Partner; those records become available to you through Argyle Passport only if that Partner directs Argyle to make them available. Argyle acts on a Partner’s behalf as to those records only as described in this Section 1.6.
1.7 What This Notice Does Not Cover. Section 1 addresses only Argyle’s own collection, use, and sharing of Your Records. Three things sit outside it.
(a) What a Partner does with your records. A Partner’s use of records you deliver to it is governed by its own obligations to you — under any agreement between you, its privacy notice, applicable law, or otherwise. See Section 5 of the Consumer Terms. Review the terms, privacy notice, and other disclosures that Partner gives you before you deliver records to it.
(b) Third-party sites and applications. This Privacy Notice does not cover websites, mobile applications, products, or services provided by third parties, including any Partner Application. Review their own privacy notices.
(c) Records Argyle processes for a customer. Where Argyle processes records on behalf of one of its business customers and under that customer’s own privacy notice — rather than at your direction under the Consumer Terms — that processing is governed by that customer’s notice and its agreement with Argyle, not by this Privacy Notice.
1.8 How Long We Keep Your Records, and How They Go Away. We keep Your Records for no longer than reasonably necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required by law. When Your Records are no longer necessary for those purposes, we delete them or keep them in a form that does not identify you and cannot reasonably be used to identify you. In deciding how long that is, we consider what you directed the Platform to do, whether your direction remains in effect, what the law requires, and the limitations periods that apply to claims. At all times we process Your Records only as required by law or as this Privacy Notice describes.
Where you end a Connection, the Platform is designed to delete Your Records obtained through it, other than any records held in an Argyle Passport account. Where a Connection ends in another way, we keep what we have already obtained as this Section 1.8 describes. You can ask us to delete Your Records at any time by emailing privacy@argyle.com.
We keep Your Records after a Connection ends only where we need it to continue providing a service you asked for, we are required by law to keep it, or we need it to prevent fraud, protect privacy, provide support, or investigate misuse.
Direction Records are different. We keep your Direction Records after we delete Your Records obtained under them, and after a Connection ends, because they are our record that you authorized what Argyle did. They do not contain those records. Asking us to delete Your Records does not delete your Direction Records, and we may keep them indefinitely. A Direction Record also sits within a continuous record of the directions other people have given, so it cannot be removed without altering that record.
1.9 Managing Your Connections. You can see the Data Locations you have connected, and end a Connection, through Argyle Link and Argyle Passport. To stop delivery to a particular Partner, to ask what we hold about you, or to ask us to delete Your Records, email us at privacy@argyle.com — though we may need additional information from you to identify you and the Connection or delivery concerned. Ending a Connection does not reach Your Records a Partner has already received. If you want a Partner to delete Your Records delivered to it, you should reach out to that Partner.
2. Website.
2.1 Your Data. Separate from Your Records and Direction Records, we collect the following in connection with your use of the Services.
(a) Information you provide. Contact information such as your name, postal address, email address, and phone number; information you share in emails, messages, or support requests; and anything else you choose to provide.
(b) Information we collect automatically. Like most online services, we and third-party analytics providers receive standard technical information when you connect with the Services, through browser cookies, pixels, web server logs, web beacons, and similar technologies. This includes browser and device information such as unique device identifiers, mobile carrier, IP address (which may indicate your general location), user agent string (e.g., operating system and browser type and version), the date and time of your interactions, and information about how you use the Services. See our Cookie Policy for more.
(c) Information from service providers and partners. We may receive information about you from our service providers, such as analytics services; and from Partners in connection with your separate relationship with them.
(d) Geolocation information. We collect general geographic location from your device or browser — typically your log-in location, such as a city or country. We do not track precise geolocation, and we do not collect location information when you are not logging in or using the Services. See our Cookie Policy for how to turn location services off.
2.2 Data Commingling. We do not commingle Your Data with Your Records or Direction Records. Information we collect automatically when you use Argyle Link or Argyle Passport is governed by Section 1, not by this Section 2. This Section 2 governs our use and sharing of Your Data.
2.3 How We Use Your Data. We use Your Data to provide the Services and operate our business, including as follows.
(a) Providing the Services. To provide and support the Services — communicating with you and other users, managing accounts, providing support, and maintaining our systems — and to communicate with Partners and respond to their support and account-management requests.
(b) Analyzing and improving the Services. To run calculations on, aggregate, normalize, clean, and make derivative works of Your Data in order to understand usage trends and preferences, monitor how well the Services work, improve them and develop new features, and test our infrastructure.
(c) Marketing. If you give us your contact information on the Website and opt in, we may send you promotional materials. We do not send marketing email to anyone who has not signed up, and you can unsubscribe at any time using the link in any marketing message, though you may still receive transactional messages.
(d) Aggregated and de-identified information. To create aggregated, statistical, or de-identified information that does not identify a specific person, which we may use for any permissible purpose or share with third parties — for example, anonymous aggregated reports on user demographics and industry patterns. The commitments in Section 1.4(d) apply to de-identified information we create from Your Data.
2.4 How We Share Your Data. We share, transfer, or disclose Your Data where you consent, and in the following circumstances.
(a) Service providers. With third parties that provide services to us — customer service, website management, information technology and security, auditing, payment processing, data analytics, and similar functions, including affiliates and others with which we are building technology integrations. We do not authorize them to use or disclose Your Data except as necessary for the activities described in Section 2.3 or to comply with law. They may be located in the United States, Canada, or other jurisdictions.
(b) Compliance with legal requirements. We, and our service providers, may disclose Your Data where required or permitted in order to: (i) comply with applicable laws and legal process; (ii) respond to requests from law enforcement, public and government agencies or officials, or others with appropriate legal authority, including outside your country of residence; and (iii) protect the rights, privacy, safety, or property of Argyle, our affiliates, you, or others.
(c) Affiliates and successors. With our parent companies, subsidiaries, joint ventures, or other companies under common control, with your consent where the law requires it. As we develop our business we may buy or sell businesses or assets, and in a sale, merger, reorganization, dissolution, or similar event, Your Data may be among the transferred assets.
(d) Aggregated and de-identified information. We may share the aggregated, statistical, or de-identified information described in Section 2.3(d).
Argyle does not sell Your Data, and does not share it for cross-context behavioral advertising or any other targeted advertising.
2.5 How Long We Keep 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 by law. At all times we process Your Data only as required by law or as this Privacy Notice describes.
2.6 Links to Other Sites, Devices, Apps, and Features. The Services may link to third-party websites (“External Sites”). We do not control their content or privacy practices and are not responsible for them. Review the privacy notices and terms of any External Site you visit.
2.7 Do Not Track. Browsers offer a “Do Not Track” option, but there is no common standard for commercial websites, and the Services do not respond to those settings. Where your browser sends a global privacy control or similar opt-out preference signal, we treat it as a request to opt out of any sale or sharing of personal information, and we apply it to the browser and device that sent it. See our Cookie Policy for how to manage cookies.
3. General.
3.1 Age and Children’s Privacy. The Platform is for adults. You must be at least 18 years old to use the Platform, and we do not knowingly permit anyone under 18 to use it. No part of the Services is directed to children, and we do not knowingly collect, maintain, or use personal information from children under 13. We do not sell or share the personal information of anyone under 16. If you learn that a child has given us personal information, tell us at the address in Section 3.9. If we learn that we have collected personal information from a child under 13, we promptly delete it.
3.2 How We Protect Your Information. We use physical, organizational, and technical safeguards designed to protect the integrity and security of Your Records, Direction Records, and Your Data against loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We limit access to Your Records, Direction Records, and Your Data to personnel who need it to do their work. No security measures are perfect. We cannot guarantee the security of our databases, or that information will not be intercepted while in transit between us and you, a Data Location, or a Partner. If we learn of a security breach affecting your personal information, we notify you as the law requires, and we may also try to reach you at an email address or phone number we have for you.
3.3 Job Applicants. When you visit the Careers section of our Website we collect what you provide with your job application — business and personal contact information, professional credentials and skills, education and work history, and other resume information, including any diversity information you volunteer. We use it to run our recruitment activities and process applications, to monitor recruitment statistics, to respond to surveys, and as necessary to comply with law, respond to legal process, protect our rights or those of others, and investigate or help prevent violations of law or of our terms.
3.4 Sweepstakes and Promotions. We may run sweepstakes, contests, raffles, and similar promotions (each a “Promotion”), sometimes jointly with third parties, which may require registration or personal information. A Promotion is governed by its own official rules, which may allow the sponsor to use your name, voice, likeness, or other indicia of persona in associated advertising except where prohibited by law, and may require disclosure of your information in connection with winner selection, prize fulfillment, or a winners list. Where a Promotion’s rules conflict with this Privacy Notice, those rules control for that Promotion.
3.5 Updates to This Privacy Notice. We may update this Privacy Notice to reflect changes in our practices. We note at the top when it was most recently updated, and we encourage you to check back. If we make material changes, we tell you.
3.6 Your State Privacy Rights. If you live in a state with a comprehensive consumer privacy law, you have rights in the personal information we hold about you. This Section 3.6 describes those rights and how to exercise them.
(a) What the laws do not reach. Most of these laws do not apply to personal information we collect, use, or disclose in connection with the Platform, because that information is subject to the Gramm-Leach-Bliley Act and its implementing regulations, or to the California Financial Information Privacy Act. See our GLBA Privacy Notice for your choices about that information, and Sections 1.8 and 1.9 of this Privacy Notice for how to end a Connection and ask us to delete Your Records — which you can do whether or not a state privacy law gives you the right. These laws also do not reach information that is publicly available, or that is aggregated or de-identified as described in Sections 1.4(c) and 1.4(d).
(b) Your rights. Where the law gives you these rights, you can: (i) know what personal information we have collected about you, where we got it, why we collected it, and the categories of third parties we disclosed it to; (ii) get a copy of it, including in a portable, machine-readable format, and ask us to send it to another company where we have the technical means to do so; (iii) correct it if it is inaccurate; (iv) delete it; (v) limit or object to how we use it, and withdraw a consent you gave us; (vi) opt out of the sale or sharing of it, of targeted advertising, and of profiling that produces legal or similarly significant effects; and (vii) limit our use of sensitive personal information. As Sections 1.5 and 2.4 say, we do not sell Your Records or Your Data and do not share either for targeted advertising, and we do not profile — so the opt-out right has nothing to reach.
(c) How to make a request. Email us at privacy@argyle.com. Tell us which right you want to exercise. We respond within the time applicable law requires.
(d) How we verify you. We have to be reasonably sure a request comes from you before we act on it. If you have an Argyle Passport account, signing in to it may be enough to verify you. If it is not, or if you do not have one, we ask for information that matches what we already hold and, where the law requires it for a request for specific pieces of personal information, a signed declaration under penalty of perjury that you are the person the information is about. We use what you give us to verify you and for nothing else, and we delete it when we are done.
(e) Authorized agents. You can have an authorized agent make a request for you. We ask for written permission signed by you, and we may contact you to confirm that you authorized the agent. If your agent holds a power of attorney for you, we do not ask you separately.
(f) If we don’t comply with a request. If we don’t comply with a request, we tell you why. You can appeal by emailing privacy@argyle.com with “Appeal” in the subject line. We respond to an appeal within forty-five days of receiving it, and if we deny the appeal we tell you how to submit a complaint to your state’s attorney general.
(g) No penalty for asking. We will not deny you the Services, charge you a different price or rate, give you a lower level of quality or service, or treat you differently in any other way because you exercised a privacy right.
(h) California: categories and sources. In the twelve months before the date at the top of this Privacy Notice, we collected the categories of personal information described in Section 2.1 — identifiers, internet and other electronic network activity information, geolocation data, professional and employment-related information, and inferences — from you directly, from your browser or device, from third-party analytics services, and from our business customers. We collected it for the purposes described in Section 2.3 and disclosed it for business purposes to the categories of recipients described in Section 2.4. California residents may also request information about disclosures to third parties for their direct marketing purposes; we make no such disclosures.
3.7 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. See our GDPR Privacy Notice.
3.8 Notice to Canadian Residents. Subject to applicable law, you have the right to access, update, and correct inaccuracies in the personal information we hold about you. To do that, to ask about how we or our service providers (including those outside Canada) handle your personal information, or to withdraw your consent to our collection, use, or disclosure of Your Records or Your Data, contact us at the address in Section 3.9. We may ask for information to verify your identity before we act.
3.9 How to Contact Us. If you have questions or comments about this Privacy Notice or our privacy practices, or you want to exercise your rights and choices, contact us at privacy@argyle.com.