Important Notice on Scope & Group Entities:
This notice governs non-UK/EEA users. Responsible legal entities depend on your location: UpholdInvest HQ Inc. (United States), UpholdInvest Operating Canada Ltd. (Canada), or UpholdInvest Worldwide Ltd. (Rest of World).
1. Scope & Data Controllers
This Privacy Notice describes how UpholdInvest collects, uses, and shares your Personal Data when you access our website, mobile applications, or APIs. When we say “UpholdInvest,” “we,” or “us,” we refer to the entity responsible for processing your data based on your residence:
2. How We Collect Personal Data
- Direct Collection: Provided directly when registering an account, submitting KYC identification documents, filling surveys, or contacting customer care.
- Automated Collection: Technical identifiers (IP addresses, OS, device motion parameters, cookies) captured when browsing our platform or using mobile apps.
- Third-Party Sources: Credit bureaus, identity verification services, mobile network operators (via Prove), and integrated financial platforms (Plaid).
3. Categories of Personal Data We Collect
| Category | Specific Data Elements Collected |
|---|---|
| Identity & KYC | Full name, residential address, phone, email, date of birth, SSN / Taxpayer ID, government ID photo. |
| Biometric Data | Facial recognition scan data extracted from selfies to cross-match official ID documents. |
| Financial & Banking | Linked bank routing numbers, account balances, transaction history, ACH processing details, risk scores. |
| Tax Residency | Tax residence jurisdiction, Tax Identification Number (TIN), signed FATCA/CARF self-certifications. |
| Device & Usage | IP address, browser plug-ins, device model, IDFA, OS version, location parameters, canvas fingerprints. |
4. Key Verification & Security Partners
To deliver bank-grade compliance and security, we integrate with trusted third-party service providers:
Facial recognition and selfie ID verification.
Document extraction for automated onboarding.
Seamless bank account linkage and balance checks.
5. AI & OCR Technology
We use Persona’s Document AI and Large Language Models (LLMs) to scan submitted documentation, extract key data fields (EINs, SSNs, addresses), and accelerate customer verification.
Additionally, we utilize pseudonymized analysis tools, including Snowflake LLM capabilities, to evaluate open-ended user feedback to enhance product features. AI outputs are not used for automated legal decision-making.
6. How & Why We Use Your Data
To execute orders, manage account balances, facilitate peer-to-peer transfers, and route asset trades.
To satisfy global Anti-Money Laundering (AML) mandates, local securities laws, and CARF/DAC8 tax reporting.
7. Targeted Advertising & Opt-Outs
With your consent, we combine cross-device identifiers to deliver tailored ad banners. We use Customer.io for email communications and Impact for affiliate attribution tracking.
8. California Resident Rights
If you reside in California, this document is supplemented by our Privacy Notice for California Residents pursuant to the CCPA/CPRA. You have the right to request access to, deletion of, or opt-out of the sale/sharing of your personal disclosures.
9. Privacy Contacts & Requests
For any questions regarding your legal data rights or to submit a Data Subject Access Request (DSAR), reach out to our Privacy Office:
Email Privacy Team (data.privacy@upholdinvest.com)