Treasury Curve Privacy Policy
Effective Date: May 1, 2024
Treasury Brokerage LLC, d/b/a Treasury Curve, provides an automated treasury management system (our “Services”) to corporations, public sector entities, hedge funds, and similar enterprise entities (our “Customers”). This Privacy Policy applies to all entities affiliated with Treasury Brokerage LLC, including Treasury Technologies, LLC and Treasury Holdings, LLC (collectively, “Treasury Curve”).
Treasury Curve does not provide Services to individuals, nor are our Services used or intended to be used primarily for personal, family, or household purposes. This Privacy Policy describes how we process information as a processor or service provider on behalf of our Customers (“Customer information”). If you are an employee or consumer of one of our Customers, please contact the Customer directly for information regarding how they use and share your information.
Please note, in providing our Services to Customers, we may collect limited business contact information of individuals working for our Customers. In the European Economic Area (“EEA”) and United Kingdom (“UK”), this limited business contact information may constitute personal data, so we provided additional rights and disclosures below with regard to this personal data.
Please click the following links to learn more about our Privacy Policy:
Treasury Curve processes and safeguards Customer information on behalf of our Customers in accordance with our agreements with Customers. We limit the collection and use of Customer information to the minimum required to deliver Services in accordance with our agreements with Customers.
Treasury Curve protects the confidentiality of Customer information in accordance with our agreements with Customers. For example, we limit employee access to Customer information, and we maintain appropriate physical, electronic and procedural safeguards to protect Customer information.
You may give us personal data by signing up for an online account, inputting information while using our Services, contacting us through our chat service, or contacting us by phone or email for information or customer service.
The categories of personal data that we may collect include:
- Identifiers, such as name, postal address, online identifier, IP address, email, account name, or other similar identifiers.
- Professional or employment-related information.
In addition, like many website operators, we collect data that your browser sends whenever you visit our website(s). This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our websites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This data may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.
Third Party Websites. The Treasury Curve site may contain links to third-party websites. When you click on a link to any other website or location, you will go to another site and another entity may collect personal data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
- To provide you with our Services, which includes:
- maintaining and servicing accounts,
- providing customer service,
- processing and fulfilling orders and transactions,
- verifying Customer information, and,
- processing payments.
- To provide analytic services, such as analyzing Customer usage and improving services offered.
- To conduct market research and project planning.
- To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Sites.
- To fulfill our legal and financial obligations.
We may share your personal data in the following ways:
With Consent. We may share your data with other users or the public with your consent.
Affiliates and Service Providers. We share your data with our third-party service providers and any subcontractors as required to offer you our Services. The service providers we use help us to:
- Run, operate, and maintain our Sites through third-party platforms and software tools;
- Perform content moderation and crash analytics;
- Run email messaging campaigns;
- Provide measurement services (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
- Provide payment attribution; and,
- Provide technical and customer support.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging data with other companies and organizations for the purposes of fraud protection.
To make our website work properly, we sometimes place small data files called cookies on a device. A cookie is a small text file that a website saves on a computer or mobile device when someone visits the site. It enables the website to remember actions and preferences (such as login, contents of shopping cart, or other preferences) over a period of time. To learn more, please see our Cookie Policy.
Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.
You may wish to restrict the use of cookies. Please be aware that some features of our website may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:
In providing our Services to Customers, we may collect limited business contact data of individuals working for our Customers. In the EEA and UK, this limited business contact data may constitute personal data.
We provide the following information to further help EEA and UK individuals understand their potential privacy rights regarding the limited business contact data that we collect from our Customers.
Lawful Bases for Processing (EEA and UK Individuals). If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your personal data is as follows:
- The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.
- Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and Services, direct marketing to you, and improvement of our Services.
- Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal data to record your requests to exercise your rights and to verify your identity for such requests.
- Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
- In some limited cases, we may also have a legal obligation to collect personal data from you in response to lawful requests by public authorities, including to meet law enforcement requirements.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided at the end of this Privacy Policy.
EEA or UK Individuals’ Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:
- Access your personal data;
- Correct inaccurate information in your personal data;
- Request erasure of your personal data without undue delay;
- Request restriction of, in certain circumstances, the processing of your personal data;
- Request receiving a portable copy of your personal data held by us, and to have that portable copy transmitted to another controller; and,
- To object to the processing of your personal data.
To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.
International Transfers of Data. Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).
This may entail a transfer of your personal data across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal data transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.
Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.
Our Services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 16 has provided us with personal data, we will take steps to delete such information.
Information in our control, including personal data, may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal data.
We implement a variety of security measures to maintain the safety of information when you enter, submit, or access your personal data. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal data obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.
We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, 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-enrollment with our products or Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
This Privacy Policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal data to our Sites. The date the Privacy Policy was last updated is indicated at the top of this page.
If you are an employee or consumer of one of our Customers, please contact the Customer directly for information regarding how they use and share your personal information.
If you are an EEA or UK individual who wants to exercise their rights regarding the limited business contact information we may have, please contact us at 877-982-8783, by mail at 648 Menlo Avenue, Suite 2, Menlo Park, CA 94025 or via email at info@treasurycurve.com.
Treasury Curve Privacy Policy
Effective Date: May 1, 2024
Treasury Brokerage LLC, d/b/a Treasury Curve, provides an automated treasury management system (our “Services”) to corporations, public sector entities, hedge funds, and similar enterprise entities (our “Customers”). This Privacy Policy applies to all entities affiliated with Treasury Brokerage LLC, including Treasury Technologies, LLC and Treasury Holdings, LLC (collectively, “Treasury Curve”).
Treasury Curve does not provide Services to individuals, nor are our Services used or intended to be used primarily for personal, family, or household purposes. This Privacy Policy describes how we process information as a processor or service provider on behalf of our Customers (“Customer information”). If you are an employee or consumer of one of our Customers, please contact the Customer directly for information regarding how they use and share your information.
Please note, in providing our Services to Customers, we may collect limited business contact information of individuals working for our Customers. In the European Economic Area (“EEA”) and United Kingdom (“UK”), this limited business contact information may constitute personal data, so we provided additional rights and disclosures below with regard to this personal data.
Please click the following links to learn more about our Privacy Policy:
Treasury Curve processes and safeguards Customer information on behalf of our Customers in accordance with our agreements with Customers. We limit the collection and use of Customer information to the minimum required to deliver Services in accordance with our agreements with Customers.
Treasury Curve protects the confidentiality of Customer information in accordance with our agreements with Customers. For example, we limit employee access to Customer information, and we maintain appropriate physical, electronic and procedural safeguards to protect Customer information.
You may give us personal data by signing up for an online account, inputting information while using our Services, contacting us through our chat service, or contacting us by phone or email for information or customer service.
The categories of personal data that we may collect include:
- Identifiers, such as name, postal address, online identifier, IP address, email, account name, or other similar identifiers.
- Professional or employment-related information.
In addition, like many website operators, we collect data that your browser sends whenever you visit our website(s). This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our websites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This data may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.
Third Party Websites. The Treasury Curve site may contain links to third-party websites. When you click on a link to any other website or location, you will go to another site and another entity may collect personal data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
- To provide you with our Services, which includes:
- maintaining and servicing accounts,
- providing customer service,
- processing and fulfilling orders and transactions,
- verifying Customer information, and,
- processing payments.
- To provide analytic services, such as analyzing Customer usage and improving services offered.
- To conduct market research and project planning.
- To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Sites.
- To fulfill our legal and financial obligations.
We may share your personal data in the following ways:
With Consent. We may share your data with other users or the public with your consent.
Affiliates and Service Providers. We share your data with our third-party service providers and any subcontractors as required to offer you our Services. The service providers we use help us to:
- Run, operate, and maintain our Sites through third-party platforms and software tools;
- Perform content moderation and crash analytics;
- Run email messaging campaigns;
- Provide measurement services (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
- Provide payment attribution; and,
- Provide technical and customer support.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging data with other companies and organizations for the purposes of fraud protection.
To make our website work properly, we sometimes place small data files called cookies on a device. A cookie is a small text file that a website saves on a computer or mobile device when someone visits the site. It enables the website to remember actions and preferences (such as login, contents of shopping cart, or other preferences) over a period of time. To learn more, please see our Cookie Policy.
Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.
You may wish to restrict the use of cookies. Please be aware that some features of our website may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:
In providing our Services to Customers, we may collect limited business contact data of individuals working for our Customers. In the EEA and UK, this limited business contact data may constitute personal data.
We provide the following information to further help EEA and UK individuals understand their potential privacy rights regarding the limited business contact data that we collect from our Customers.
Lawful Bases for Processing (EEA and UK Individuals). If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your personal data is as follows:
- The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.
- Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and Services, direct marketing to you, and improvement of our Services.
- Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal data to record your requests to exercise your rights and to verify your identity for such requests.
- Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
- In some limited cases, we may also have a legal obligation to collect personal data from you in response to lawful requests by public authorities, including to meet law enforcement requirements.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided at the end of this Privacy Policy.
EEA or UK Individuals’ Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:
- Access your personal data;
- Correct inaccurate information in your personal data;
- Request erasure of your personal data without undue delay;
- Request restriction of, in certain circumstances, the processing of your personal data;
- Request receiving a portable copy of your personal data held by us, and to have that portable copy transmitted to another controller; and,
- To object to the processing of your personal data.
To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.
International Transfers of Data. Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).
This may entail a transfer of your personal data across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal data transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.
Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.
Our Services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 16 has provided us with personal data, we will take steps to delete such information.
Information in our control, including personal data, may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal data.
We implement a variety of security measures to maintain the safety of information when you enter, submit, or access your personal data. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal data obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.
We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, 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-enrollment with our products or Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
This Privacy Policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal data to our Sites. The date the Privacy Policy was last updated is indicated at the top of this page.
If you are an employee or consumer of one of our Customers, please contact the Customer directly for information regarding how they use and share your personal information.
If you are an EEA or UK individual who wants to exercise their rights regarding the limited business contact information we may have, please contact us at 877-982-8783, by mail at 648 Menlo Avenue, Suite 2, Menlo Park, CA 94025 or via email at info@treasurycurve.com.
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