Privacy Notice

Last Updated: October 25, 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 income, employment, and other work-related data portable. Argyle’s payroll connectivity and data portability platform (“Platform”) and related offerings are designed to provide an easy way for you to connect your accounts containing your income, employment, and other work-related information and deliver that information to third parties that need it in connection with your separate relationship with them, who are also our business customers, or to such other recipients as you may consent or direct, including through our self-service offering, Argyle Passport, and enabling you to verify those connections. By facilitating the delivery of your data in a high-quality and standardized manner to those Partners or other recipients, we enable you and them to focus on building the relationships that benefit you. Argyle knows privacy is very important to you. We believe in transparency in data collection and use. 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 and Argyle Passport, the consumer-facing sides of the Platform (“Employment Data”), and (ii) Argyle’s website (https://www.argyle.com) (the “Website” and that information “Your Data”). Argyle’s Platform and 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.

Consumers who apply for or use Argyle’s Platform in connection with applying for using other financial products or services (e.g., personal loans, mortgages, insurance, or earned wage access)  should review our GLBA Privacy Notice.

Please note that we may continue to collect and retain Employment Data until you remove the Connections with respect to that data, and we use and disclose Employment Data in accordance with our obligations under the GLBA. You can remove Connections between a Data Location and a Partner through Argyle Link accessible to you through the Partner Application or Access URL, through Argyle Passport, or by emailing us at privacy@argyle.com.

Capitalized terms not defined in context have the meanings given in the Consumer Terms.

1. Platform

1.1. Employment Data.

a.   At your instruction, the Platform uses the Credentials you provide through Argyle Link to:

(i) log in and create a Connection to the Data Location(s) you select;

(ii) programmatically retrieve information from the Data Location(s) available under those Credentials (including periodic refreshes or updates to that information for the duration of the applicable Connection, to the extent technically feasible);

(iii) process and deliver that information to (1) the Partners (as defined in Consumer Terms) that you direct, which are organizations with which you may have a contractual or other relationship, such as your bank, insurance provider, mortgage lender, property lessor, gig-work assistance provider, or prospective employer (including to the Partners’ service providers acting on the Partners’ behalf), or other third parties to which you may consent or direct, (2) or other recipients as you may direct through Argyle Passport.

b. The information the Platform retrieves on your behalf from Data Locations (including periodic refreshes or updates, to the extent technically feasible) varies depending on what information is available under your Credentials for the applicable Data Location. That information generally, to the extent available, includes:

(i) 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;

(ii) 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;

(iii) 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 (including, for clarity, related documentation, including paystubs and tax forms); and

(iv) Other Work-Related Information: Gig/task count, gig/task request and acceptance times, gig/task start and end times, pick-up and drop-off times, gig/task start and end locations, break start and end times, distance traveled.

The Platform is not designed to retrieve information unless that information is available under your Credentials. In general, if the information is available under your Credentials, the Platform retrieves it. Together that information along with your Credentials is “Employment Data.” For a comprehensive list of Argyle’s data taxonomy for Employment Data, see the “Data Sets” section of Argyle’s technical documentation. Connections remain until removed, as described in more detail in Section 3 of the Consumer Terms (Removing Connections).

c. The information we transmit varies depending on what information the specific third party has requested via the Platform (in all instances, to the extent available under your Credentials). 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 Partner that has requested that you provide that information or such recipient as you instruct via Argyle Passport as set forth in more detail in the Consumer Terms. You communicate those instructions to us through Argyle Link.

1.2. How We Use Employment Data.

a. Platform-Related Usage: We use your Employment Data to provide and support the Platform as described in the Consumer Terms, including delivery of Employment Data to those Partners and other recipients you direct, and to communicate with you and Partners (including for purposes of support and maintenance).

b. Analyzing and Improving the 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 Platform, (iii) improve and further enhance the Platform including through the development of products, services, features, and functionality; and (iv) test the Platform and our infrastructure to make sure the Platform is working correctly.

c. Aggregated, De-Identified Information: We may use Employment Data to create aggregate or de-identified information that does not identify (and cannot reasonably be used to 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. Partners: We share Employment Data with Partners or other third parties at your instruction as described in the Consumer 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. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.

c. Legal Requirements; Affiliates and Successors: We (and our Service Providers) 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. Partner and Third-Party Use of Employment Data. Section 1 of this Privacy Notice only addresses our collection, use, sharing, and otherwise processing of Employment Data. Partners collect, use, share, and otherwise process Employment Data that you deliver to them using the Platform (and any other information they may collect about you separately from Argyle) in accordance with your separate relationship with them, including under your separate agreement with them (if any), their own privacy notices, and/or the laws otherwise governing your relationship with that Partner. Please see Section 5 of the Consumer Terms (Relationships with Partners and Data Locations) for more information about your and our respective separate relationships with Partners. This Privacy Notice also does not cover any websites, mobile applications, products, or services provided by other third parties (including any Partner Applications). We encourage you to review the privacy policies or notices of Partners 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 as long as appropriate to fulfill the purposes for which it was collected as 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 Partner Application or terminate your account with one or more Partners, we may still retain your Employment Data. At all times, Argyle will only process Employment Data as required by law or in accordance with this Privacy Notice.

Argyle’s systems are designed to automatically delete your Employment Data when a Connection with respect to that Employment Data is removed, unless:

a. Argyle needs that Employment Data to continue providing you with an Argyle service you requested, or to carry out another notified purpose with your consent;

b. Argyle is required by law to keep that Employment Data; or

c. Argyle needs that Employment Data to help prevent fraud or protect privacy, provide support, or investigate misuse and misconduct.

You can remove Connections between a Data Location and a Partner through Argyle Link accessible to you through the Partner Application or Access URL, and you can also view and remove connections made to Partners using Argyle Passport. If you wish to remove a Connection (e.g., if you have lost access to the device or Partner Application or Access URL you used to create the Connection or you are having problems using Argyle Passport (e.g., Argyle Passport is not showing a Connection you believe you have made)), you may also email us at privacy@argyle.com and we will remove the Connection for you, though we may need additional information or other assistance from you to adequately identify you and the Connection(s) that you would like removed.

2. 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.

b. Information We Collect Automatically: Like most online services, we and third parties, like Google Analytics, 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. Please see our Cookie Policy for more information.

c. Service Providers and Partners: We may receive information about you from our service providers such as analytics services, our partners such as ad campaign information (e.g., the ads you click on) and from Partners in connection with your separate relationship with the Partner.

d. Geolocation Information: We collect or receive information from your device or browser including general 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 using the Services. For information about how to turn off geolocation services please see our Cookie Policy.

2.2. Data Commingling. Except with respect to Your Data that is information we collect automatically in connection with your use of Argyle Link and Argyle Passport, 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 users, managing accounts, providing support services, and maintaining our systems. We also use Your Data to communicate with Partners 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 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 (although you may continue to receive transactional messages from us).

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 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 2.3 of this Privacy Notice or to comply with legal requirements. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.

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. You may set your mobile device to limit ad tracking, in which case we will not be able to see your ADID or IDFA.  Please see our Cookie Policy for more information, including your choices for interest-based advertising.

c. Compliance with Legal Requirements: We (and our Service Providers) 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 (including in jurisdictions where we or our Service Providers are located); 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, with your consent where required by law. 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. To learn more about your choices for interest-based advertising, see our Cookie Policy.

3. General

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 Partner.

3.3. Job Applicants. When you visit the Careers portion of our website, we collect the information that you provide to us in connection with your job application, including business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys. We may also use this information to provide improved administration of the services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our terms of use.

3.4. Sweepstakes. We may operate sweepstakes, contests, raffles, and similar promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require registration or submitting personal information. If you choose to participate in a Promotion, your personal information may be disclosed to third parties as described in the terms applicable to that Promotion. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. If the terms applicable to a particular Promotion conflict with this Privacy Policy, the terms applicable to the Promotion shall control.

3.5. 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.

3.6. 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.

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 (respectively the “GDPR” and the “UKGDPR“). For more information about your rights thereunder, please visit 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 your personal information in our custody or control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records. If you have any questions about the manner in which we or our Service Providers (including our Service Providers outside Canada) treat your personal information, to withdraw your consent to our collection, use or disclosure of Employment Data or Your Data or to request access to or correction of your personal information, please contact us at the address set out in section 3.9.

3.9. 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 privacy@argyle.com.