Privacy Policy

Last Updated: September 29,2020

This privacy policy (“Privacy Policy”) describes the ways New York Digital Investment Group LLC and its subsidiaries (“We”, “Us”, or “NYDIG”) collect, store, use, disclose, and protect your personal information. We use the term “personal information” to describe information that can be associated with you and can be used to identify you. Personal information does not include information that does not identify a specific person. “You” or “your” means you as a participant in or as a user of the products and/or services offered by NYDIG. Please carefully read the Privacy Policy in its entirety.

You acknowledge that you have read, understand, and agree to the practices regarding your personal information described in this Privacy Policy when you access or use NYDIG’s online services and website.

We reserve the right to modify, alter, or otherwise update this Privacy Policy at any time to address changing legal obligations, technologies, business practices, and our users’ needs. We encourage you to check back periodically so that you are always aware of the most current policies and practices that NYDIG has in place to protect your information.

1.Information We Collect

When you use NYDIG online services, we may collect certain information about you. Examples of information we may collect include your name, address, telephone number, date of birth, email address, other means to contact you, your bank account information, and other information you may supply to us or one of our service providers in connection with providing services to you. We may also collect information about you that you otherwise submit to us or one of our service providers, such as through email and other means.

In addition, we may collect information related to your use of our website such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your NYDIG online services access, the specific pages, buttons, images, links, and forms that you access while visiting NYDIG online services, the type of device you use to access NYDIG online services (such as a phone, tablet or computer), your mobile carrier, and your Internet service provider.

2. Our Use of Information

We may use your information to (i) provide information, products, or services you request from NYDIG; (ii) verify your identity when accessing NYDIG’s services; (iii) enforce our terms of use and any other agreements between you and NYDIG; (iv) improve, modify, customize, and measure NYDIG online services; (v) provide you with information about NYDIG products and services while you are on NYDIG online services or after you visit NYDIG online services; (vi) compare information for accuracy and verify our records; or (vii) detect and prevent fraud or other criminal activities.

3.Sharing Information in Connection with NYDIG Online Services

To provide NYDIG online services, we may share some of your information with service providers who are authorized to use your information only as necessary to support our business operations, such as those who provide data storage, payment, technology support and services, customer service, risk solution provision, analytics, fraud prevention, and marketing services. We maintain contracts requiring all of our service providers to implement the same commercially-reasonable protections for your information as NYDIG. NYDIG and its service providers may have systems or operations based outside the United States, and you recognize that by using NYDIG’s website and services your information may be transferred outside of the United States.

We may also share some of your information as otherwise permitted or required by law or as authorized by you. This may include sharing information with affiliates of NYDIG.

4. Cookies and Similar Technology

When you access NYDIG online services, we, or third parties we hire to track how our website is used, may place small data files called “cookies” on your computer, mobile phone, or other online access device. Cookies are pieces of data stored on your device that are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server so that we can recognize your device.

A “session cookie” may be sent to your computer or other access device when you login to NYDIG online services. This type of cookie recognizes you if you visit multiple pages on a site during the same session, so that you do not need to be prompted for your password on each page. Once you log out or close your browser, this cookie expires and no longer has any effect. “Persistent” or longer-lasting cookies can be used for other purposes, such as to record user experience preferences when you use a website. These cookies do not expire once you log out or close your browser. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of NYDIG online services.

We and our third party service providers may also use technologies similar to cookies to track your interaction with NYDIG online services. Some of these technologies include web beacons, pixels, tags, and Flash objects. As with cookies, you are free to decline such technologies if your browser permits. You should refer to your browser’s instructions to remove cached history and images from your device. Deleting or disabling cookies will not remove Flash objects. You should refer to Adobe’s website https://www.adobe.com for more information on how to disable these objects.

NYDIG and the third parties who assist in operating NYDIG online services do not respond differently or limit their practices under the terms of this policy when you access those online services with a browser that uses a “do not track” signal or similar mechanism.

5. Storage and Protection of Personal Information

We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of your personal information. In order to help secure personal information collected from you as a NYDIG online services user, including sensitive financial data, the information is protected by secure socket layer (SSL) encryption when it is exchanged between your web browser and NYDIG online services.

After receiving your information, we employ commercially reasonable website security and customer verification procedures to protect your data. We store your personal information and user-specific settings and preferences using commercially standard database security software. User passwords and other sensitive information are saved in encrypted form to prevent unauthorized access or disclosure and accidental loss, alteration, or destruction. We regularly review our operational and business practices for compliance with corporate policies and procedures governing the security, confidentiality, and quality of our information. We require all of our employees, contractors, and other third parties to protect confidential information as a condition of doing business with us, and our business practices limit the use and disclosure of such information, including personal information, to authorized persons, processes, and transactions.

You play a critical role in protecting your information by maintaining up-to-date online security protections. Steps you take to ensure the security of your computer or other online access device, computer passwords, and other personal identifier authentication mechanisms are key components for the protection of your personal information.

Notwithstanding the steps that you and we take to protect your information, the internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by NYDIG in connection with NYDIG online services. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, physical, or other operational safeguards.

6. Suspicious Email

It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from NYDIG but you suspect may be from another source and might be fraudulent, please do not open or respond to this communication, and instead email us at [email protected] to ensure the safety of your account.

7. Personal Information on Children

We respect the privacy of children and encourage all parents to supervise their children’s computer usage. We do not market to or intend to invite children to visit NYDIG’s website, and we do not permit individuals under the age of 18 to open accounts with NYDIG. NYDIG does not knowingly collect or retain personal information from children under the age of thirteen (13). For more information on the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website at www.ftc.gov.

8. Notice to Persons Accessing NYDIG Online Services Outside the United States

If you access NYDIG online services outside the United States, any information you provide to us through NYDIG online services will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States and you recognize that your information may be subject to disclosure under United States laws and regulations, including the USA PATRIOT Act.

9. Contacting Us About Privacy Questions

If you have questions or concerns regarding this Privacy Policy, you should contact us by email at [email protected]nticbank.com.

10. Changes to this Privacy Policy

This Privacy Policy is subject to change. Please review it periodically. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the top of this Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the site. Your use of NYDIG’s website or services following these changes means that you accept the revised Privacy Policy.

FACTS
WHAT DOES NEW YORK DIGITAL INVESTMENT GROUP (NYDIG) DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
– Social Security number and account transactions
– Account balances and payment history
– Transaction history and purchase history

When you are no longer our customer, we continue to share your information as described in this notice.
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons NYDIG chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does NYDIG share?
Can you limit this sharing?
For our everyday business purposes –
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes
No
For our marketing purposes – to offer our products and services to you
Yes
No
For joint marketing with other financial companies
No
We don’t share
For our affiliates’ everyday business purposes – information about your transactions and experiences
No
We don’t share
For our affiliates’ everyday business purposes – information about your creditworthiness
No
We don’t share
For our affiliates to market to you
No
We don’t share
For nonaffiliates to market to you
No
We don’t share
Questions?
Call toll free 1-877-869-9041 or go to https://nydig.com/privacy-policy/

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Who we are
Who is providing this notice?
Certain subsidiaries of New York Digital Investment Group LLC (NYDIG), including NYDIG Execution LLC and NYDIG Trust Company LLC.
What we do
How does NYDIG protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does NYDIG collect my personal information?
We collect your personal information, for example, when you
– Open an account or provide account information
-Give us your contact information or use your debit card
-Make deposits or withdrawals from your account

We also collect your personal information from other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
– sharing for affiliates’ everyday business purposes – information about your creditworthiness
– affiliates from using your information to market to you
– sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.
– NYDIG does not share with our affiliates.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
– NYDIG does not share with nonaffiliates so they can market to you.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
– NYDIG doesn’t jointly market.
OTHER IMPORTANT INFORMATION
State Privacy Laws
State laws may provide you with other privacy protections. To the extent those state laws apply, NYDIG will comply with them when sharing your personal information.