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Privacy Policy

Last Updated: Mar 20, 2024

CElegans Labs, Inc. (doing business as “AtoB”) provides financial products and services togrowing companies. We understand that by using AtoB, your Company places trust in us tohandle your Company Data and Personal Data appropriately, including the Personal Data ofindividuals affiliated with your Company, such as your Company’s Administrators, ControlPersons, Beneficial Owners and Users. We want to make sure that you have all the information necessary about how we process—thatis, how we use, collect, transmit, store, share, and erase—Personal Data, which does notinclude De-Identified or aggregated data, so you can make an informed decision about how youwant to interact with our products and services. We know that you may have questions about how we process your Personal Data, so we havelaid out how we process Personal Data about you. We’re always open to inquiries andsuggestions on how we can improve and are available 24 hours a day, 7 days a week; pleasereach out to our Privacy Team at support@atob.us Capitalized Terms not defined in this Privacy Policy have the meaning described in Section 17of the Platform Agreement. 1. Personal Data we process and how we process it
The Personal Data we process depends on the AtoB, Financial Partner, and Third-Party ServiceProvider products you use and how you access them. We process Personal Data when youdirectly interact with the AtoB Services in the following ways: • Browsing atob.us or using app.atob.us.
• Filling out an application and creating an AtoB Account
• Making a purchase using your AtoB Card
• Using our iOS or Android mobile apps
• Connecting Linked Accounts to your AtoB Account
• Calling, chatting, or interacting with AtoB (such as with our Customer Support or Sales)• Interacting with us at a conference, webinar, or event Personal Data automatically processed when you visit our websites or use our mobile app
We process Personal Data automatically when you visit our website or use our mobile app tomake our services work, to prevent fraud and enhance security, to understand your preferences,and to tailor services to you for the best possible experience. We may process: Browser and device information
• IP address
• Mobile and other hardware or device identifiers• Operating system • Browser information, such as type and version
• Referring and exit pages, including landing pages and pages viewed
• Device event information, including crash reports, request and referral URLs and systemactivity details Information about your use of our website or mobile app
• Your location
• What you click on and what you type, time you spend on our websites, and other userexperience information Cookies and trackers
We also use cookies and other activity tracking tools to help our website function effectively.These tools allow us to:
• Provide you services such as those that allow you to chat with our Customer Experience team• Perform website and mobile analytics
• Improve the advertisements you see
• Help prevent fraud and prevent attacks against our websites and services
• Advertise and promote AtoB products and services, and additional products and services fromour partner companies We use cookies and trackers to assign you a unique identifier so we can record:• Websites you visit
• Length of time the advertisement was visible
• IP Address You can block these at any time using your web browser settings, but doing so may limitbrowsing experience and your ability to use certain features of our services. Company Data and Personal Data needed to apply for and create an AtoB Account
If you are submitting an application to open an AtoB Account, we need to process a certainamount of preliminary information about you, your Company, Administrators, Control Persons,Beneficial Owners, and Users to comply with our legal and regulatory obligations. When youapply for an AtoB Account, we may process:
• Your name
• Your title or role on your team
• Your email
• Your phone number
• Your address
• Your date of birth
• Your password (hashed) — unique, long, and strong, please
• Information related to your Company, including the Company’s legal name, address, copies ofyour Company’s corporate documents, and Employer Identification Number (EIN)
• Information about individuals on your leadership team or individuals who have an ownershipinterest in your Company
• Your Company’s Linked Account information • Other information pertaining to your identity such as copies of a passport, driver’s license, orother national ID
• Your Tax Identification Number (TIN) or your Social Security Number (SSN)
• Revenue information (such as information related to Shopify, Amazon, or other ecommercerevenue platforms or freight platforms) • Personal Data provided to us from third-party companies we partner with to offer services toyou (see below). Personal Data needed to use our products and services
We need to process Personal Data when your Company assigns you an AtoB card or otherwiseallows you to use our products and services (for example as an employee or authorizedrepresentative).
To use these services, we may process: Your name Your email
• Your phone number Personal Data processed when you make a transaction
Each time you make a payment using an AtoB card, we receive information about yourtransaction. We may receive this information directly from you or from our Issuers and ProgramPartners or the card networks (Mastercard or Visa). We may process:
• Payment method information (card number, card type, PIN)
• Purchase amount
• Purchase date
• Purchase location
• Whether you made the purchase online or in a store
• Receipt information
• Information provided to us by the Card Network associated with transactions, merchants, orcardholders Personal Data processed when you interact with AtoB teams
We may process Personal Data about you when you call, chat, email, or interact with membersof AtoB teams (such as Customer Support, Sales, or Marketing), including:
• Your name
• Your email, phone number, or other contact information
• Content of your communications, including, in some cases recorded calls, and surveyresponses Personal Data processed when you join a webinar or event
We may process Personal Data about you when you join AtoB at an event in person or onlinevia a webinar. We may collect this information directly or obtain it from a third-party serviceprovider. We may process:
• Your name
• Your email or other contact information • Registration date and time
• Webinar attendance information, when you joined a webinar, when you left, if you were payingattention, and what country you joined from Personal Data processed when you make a payment to AtoB
When you submit a payment to AtoB, we collect information to verify the legitimacy of thepayment. We may process:
Information related to an ACH payment
• Recipient name or Company
• Sender name or Company
• Amount sent
• Amount received
• Routing and account numbers
• Recipient bank and account name
• Account type
• Other information generated when a payment is made through the ACH Network Information related to a wire transfer• Recipient name or Company
• Sender name or Company
• Amount sent • Amount received
• Routing and account numbers, including IBAN & SWIFT code
• Recipient bank and account name
• Recipient address and country
• Wire instructions or purpose of payment
• Other information generated when a payment is made through an electronic payment transfernetwork Information related to a debit card or credit card• Cardholder name
• Company name
• Card account number • PIN or security code Information related to the processing of a check• Recipient name or Company
• Sender name or Company
• Amount sent • Amount received
• Memo
• Recipient address and country• Recipient email • Pictures of a check and related information (routing and account numbers, address of sender,telephone of sender, signatures of sender and endorser). Personal Data processed from our Third-Party Service Providers
We process Personal Data we receive from Issuers, identity verification services, and otherThird-Party Service Providers, and information you share with us about your use of theirproducts and services:
• To comply with regulatory and reporting obligations
• To facilitate your use of our products or services, or other products and services
• To underwrite your account
• To conduct fraud monitoring, prevention, and detection
• To fulfill commitments to our Financial Partners and Third-Party Service Providers
• To fulfill requests made by you Personal Data necessary to comply with regulatory and legal requirements
When you open an AtoB Account as a Company owner or an administrator on behalf of aCompany, or you provide information of an individual with an ownership interest in a Company,we process Personal Data we receive from identity verification services and other Third-PartyService Providers that we must keep to comply with the law, including:
• Your name
• Your phone number
• Your SSN
• Your current or previous addresses
• Your date of birth Personal Data processed to integrate third-party products and services with your AtoB AccountWhen you choose to link your AtoB Account with products and services provided by ourFinancial Partners and Third-Party Service Providers, we process Personal Data we receivefrom them to ensure our products and services work properly together. We also process information provided by your Linked Accounts. To underwrite your AtoBAccount, provide you with the highest credit limits possible, and determine your eligibility forAtoB rewards, we require you to give us information about your Company’s finances and accessto your Company’s Linked Accounts. We use Third-Party Service Providers to processinformation about your Company’s Linked Account activity. When you link a Linked Account, wemay process the Linked Account credentials and all information associated with the LinkedAccount associated with those credentials, including:
• Unique identifiers associated with your bank
• Account names
• Bank account type
• Transaction history and related information
• Account balances
• Bank routing and account numbers If you do not link your bank directly, we process information you provide with copies of yourbank statements and other financial information about your Company .
To link your bank account with your AtoB Account, a Financial Partner or Third-Party ServiceProvider may use and store your Linked Account credentials. We do not store your LinkedAccount credentials on AtoB systems. AtoB Account connections
We offer the ability to connect your AtoB Account with accounting services (such as QuickBooksOnline, Xero, and Netsuite), travel services, and other products and services. We both providePersonal Data to and receive Personal Data from these services on your behalf.
Accounting and expenses services. When you direct us to connect your AtoB Account to theseservices, we collect certain information to make those integrations work, including: • Unique identifiers associated with the third-party connected account• Information associated with your general ledger account
• General ledger account codes
• Locations • Classes
• Departments
• Email addresses The information we collect may differ based on the accounting service and the choices youmake relating to that service. Personal Data from Financial Partners and Third-Party Service Providers
We get Personal Data from our Financial Partners, , the Card Networks, and other Third-PartyService Providers that process payments on our behalf to make the AtoB Services work. Theinformation we get includes Personal Data related to your Transactions using a virtual orphysical AtoB card as described above. Personal Data processed to underwrite your AtoB Account or to determine whether to extendcredit to your Company
We process Personal Data to obtain business credit information and consumer creditinformation from business credit and consumer credit agencies to decide whether to offer, andwhich types of of credit products to offer your Company, and to manage our financial risk Personal Data processed to conduct fraud monitoring, prevention, and detection
We process Personal Data from our Financial Partners, Third-Party Service Providers, creditreporting agencies, identity verification services, public sources, and other third parties toprevent fraud. Personal Data processed as a result of a partnership, referral, or agreement
We enter into agreements with Financial Partners, and Third-Party Service Providers thatprovide products and services related to ours, and as a result of these partnerships, AtoB may receive Personal Data related to that particular relationship or partnership. We may processinformation about: • You and your relationship with the Financial Partner or Third-Party Service Provider
• Your email or other contact information
• Your membership or relationship status with the Financial Partner or Third-Party ServiceProvider 2. How we use Personal Data
We process your Personal Data for the reasons stated specifically in this policy, but we mayalso process Personal Data about you to:
Operate our business and provide tailored services to you, i.e.,
• Communicate with you about the products and services by phone, text, email, or chat
• Monitor, prevent, and detect fraud or unauthorized activity
• Secure our systems and products
• Determine eligibility for and underwrite your AtoB Account application and decide whether toapprove your application for certain AtoB Services
• Mitigate financial loss, claims, liability, and other harm to our users, AtoB, our partners, or thirdparties
• Manage, operate, and improve the performance of our products and services
• Determine eligibility for AtoB products or services
• Help you make or receive a payment via ACH, wire, or check
• Provide you with tailored recommendations
• Identify, fix, and troubleshoot bugs and errors
• Facilitate reporting, analyze performance, and auditing
• Understand how you use our services so we can make enhancements or improvements
• Facilitate business relationships or comply with contractual obligations
• Comply with our regulatory, legal, and other compliance obligations
• Advertise or market services and products to you
• Determine eligibility for, calculate, and provide AtoB Rewards
• Compare information for accuracy and verify it with third parties
• If you elect to share information about your geolocation, we will use this information toenhance the security of our products and services and to prevent fraud Provide you with support, i.e.,
• Help identify and troubleshoot problems with your account
• Survey your opinions through surveys or questionnaires
• Communicate with you and respond to your specific requests or questions
• Manage and send you notifications, confirmations and important information about youraccount and our products and services De-Identified and aggregated data
To better target advertisements, improve, and market our products and services, and for otherpromotional purposes, we may reasonably transform Personal Data into de-identified information removing or masking information that could be used to identify you and byaggregating or combining De-identified Data with other information. If you don’t want us to useyour data in de-identified or aggregate form for promotional purposes, contact us atsupport@atob.com. 3. How we share Personal Data
AtoB may provide Personal Data to third parties to improve our products and services, tooperate our business, and to help AtoB market to potential customers. We may share all of thecategories of information listed in this Privacy Policy with other companies: • to determine whether to provide an AtoB Account to you
• to determine your eligibility for AtoB’s current and future products and services, including creditproducts provided by our Financial Partners and Third-Party Service Providers
• to obtain business credit reports and consumer credit reports, and to report Company Dataand Consumer Report Data to business credit agencies and consumer credit agencies
• to allow third parties to obtain business credit reports and consumer credit reports to offersuitable financial products to you
• to operate AtoB’s products and services or support general operations of AtoB’s business;
• to integrate the products and services of our Financial Partners and Third-Party ServiceProviders with your AtoB Account;
• to use third-party cloud services to host our website and store the information we processabout you;
• for any other legitimate business purpose. No sale of Personal Data
We do not and will not sell or allow our Financial Partners or Third-Party Service Providers toprocess your Personal Data for their own use without your express consent, unless theprocessing of that information is either required by law or we determine that disclosure isreasonably necessary to enforce our rights, protect our property or operations, or enforce therights and protect the property or operations of our Financial Partners and Third-Party ServiceProviders. Payment-related information
We share some Personal Data about you, such as your name and information about thepayment method, with the person or merchant you are paying. Anonymizing or aggregating Personal Data
We may share anonymized or aggregated information, or other data that does not directlyidentify you or your Company, with third parties. Affiliate sharing
AtoB may share Personal Data we process about you with other AtoB companies to provideadditional services to you, determine eligibility for new products and offers, and for otherlegitimate business interests. Sharing with Third-Party Service Providers
We share your Personal Data with our Third-Party Service Providers that operate and provideservices on our behalf. Third-Party Service Providers need access to your Personal Data toperform information processing, manage or enhance our customer information, tailor services toyou and your preferences, and perform other services related to our business. We work with ourThird-Party Service Providers to make surethat they do not sell the Personal Data that we sharewith them. Advertising
We may use third parties to send advertisements on our behalf. We may only share a verylimited set of Personal Data required to deliver our advertisements to you (such as an emailaddress to deliver the message to you), and we do not permit these third parties to use or shareyour Personal Data to advertise unaffiliated products or services to you. These third parties mayalso use cookies or similar tracking tools to identify you through your browser usage. While youmay disable these tools in your browser settings, you may still receive non-targetedadvertisements we sent as part of a general marketing campaign. Sharing with our Financial Partners
We share Personal Data to facilitate the services we provide to you with our business andFinancial Partners. Sharing with Financial Partners AtoB partners with banks and their third-party service providersto issue Cards to you. AtoB owns and controls the Transaction data and other Personal Data weshare with our Financial Partners. We share the Personal Data you provide in your applicationfor an AtoB Account to comply with our contractual obligations and to facilitate compliance withtheir and our regulatory obligations. Our Financial Partners do not sell or use your PersonalData or use any related data to market or to develop products and services, or for any otherpurpose not authorized by us. Sharing with credit reporting agencies
We share information about you and your account with business credit reporting agencies andconsumer credit reporting agencies to verify information about your business, to report on yourbusiness’s performance, and to report late payments, missed payments, or other defaults, whichin some cases may contain Personal Data. Sharing with Card Networks
Mastercard or Visa separately processes information related to your use of your AtoB Cards.For more information on how Mastercard and Visa handle your Personal Data, please visitMastercard’s Global Privacy Notice or Visa’s Global Privacy Notice, respectively. Sharing with Third-Party Services ProvidersSharing for partnerships and referrals We share Personal Data to facilitate referral partnerships. For example, if you were referred tous through an organization we may provide confirmation to that organization that your Companyopened an AtoB Account with us, and information relating to your
AtoB Account activity solely for the purpose of calculating any referral fees we owe related tothe referral. Sharing authorized by you, your users, or authorized representatives
We continually enhance our products and services by integrating with products and servicesprovided by other companies. For these integrations to work and with your explicit consent, wemay need to share your Personal Data with them. Information we share with these companieswill be used and disclosed according to that Company’s privacy policy. You should review theprivacy policy of any Company that has access to your Personal Data related to the integrationwith your AtoB Account. Sharing with accounting and expenses services
We offer integrations with many popular accounting services (such as QuickBooks Online, Xero,and Netsuite). We share information with those services solely as directed by you, your users,or authorized representatives. Sharing as part of a corporate transaction
In the event of a corporate sale, merger, reorganization, dissolution or similar event, PersonalData and data we process from you may become part of the assets we transfer or share inpreparation for any such transaction. Any acquirer or successor of AtoB may continue toprocess Personal Data consistent with this Privacy Policy. Compliance and compelled disclosureWe may share Personal Data: • to comply with applicable law, regulation or Card Network rules;
• to enforce our contractual rights or comply with contractual obligations;
• to protect the rights, privacy, safety and property of AtoB, you, our customers, our ProgramPartners, or others;
• to respond to requests from auditors, courts, law enforcement agencies, regulators, and otherpublic and government authorities, which may include authorities outside your country ofresidence. When complying with court orders and other similar legal processes, AtoB strives fortransparency. We will make reasonable efforts to notify our customers and users of anydisclosure of their Personal Data, unless we are prohibited by law, court order, or exigentcircumstances prevent us from doing so. 4. Where we store Personal Data
We provide and direct our services only to companies incorporated in the United States and foruse exclusively by their employees or authorized representatives. We may process and storePersonal Data for the purposes described in this Privacy Policy in the United States or any othercountry in which AtoB, its subsidiaries, affiliates, or service providers operate. We will store this information while we continue to provide products and services to you, to operate our business,comply with contractual obligations, and for as long as required by law.If you ask us to deletespecific Personal Data (see “Your Choices About Your Personal Information” below), we willhonor your request unless deleting the information prevents us from billing for our products andservices, calculating taxes, conducting required audits, or carrying out other legitimate businessfunctions, or we are required by law or contractual obligation to keep that information. 5. Other important information about Personal Data security
We use organizational, technical, and administrative measures to protect Personal Data;however, no data security program is entirely secure. Please contact us at support@atob.comimmediately if you believe that your Personal Data or any other confidential information that youhave provided to us is no longer secure or has been lost or stolen. If we confirm that there hasbeen a breach of Personal Data or confidential data related to you, we will notify you. Use by minors
If you are under the age of 16, you may not have an AtoB Account or use our products orservices. We do not knowingly process any information from, or direct any of our products orservices to children under the age of 16. Please do not provide us with any Personal Datarelated to children under the age of 16. Personal Data related to Administrators, Beneficial Owners, Control Persons and Users
In some circumstances, we require you to provide us with Personal Data relating to anotherperson (such as providing us with Personal Data about the owners of your business during theapplication process or providing us with Personal Data about your employees). Do not provideus with any Personal Data unless you have obtained consent of these persons or you are surethe disclosure of the Personal Data is otherwise permitted by law or contract. You must informall other persons whose information you share with us how we process Personal Data and allother terms of this Privacy Policy. AtoB Account Users
Our products and services are intended for use only by companies, and you may only use anAtoB Account or Card if you are an employee or other authorized representative of a Companythat has opened an AtoB Account. The Company’s administrator is
responsible for the AtoB Account and cards associated with that Company. An administratorcan: restrict, suspend, or terminate your access to or ability to use the services, accessPersonal Data about you, access or retain information stored with us, and restrict your ability toedit, restrict, modify, or delete information associated with your use of our products andservices. 6. Your choices about your Personal Data
Electronic communications
You may choose not to receive promotional emails from us by following the unsubscribe/opt-outinstructions in those emails, but we may still send you non-promotional messages relating tomaterial or transactional information about our products and services such as updates to our platform agreement, privacy notices, security alerts, and other notices relating to your access toor use of our products and services. Deletion or closure of an AtoB Account
Closure or deletion of your Company’s AtoB Account will mean that you permanently loseaccess to the Personal Data and data associated with the AtoB Account. Certain Personal Dataor de-identified information associated with your Company’s AtoB Account may nonethelessremain on systems owned or maintained by AtoB where required to comply with the law, ourcontractual obligations, or carrying out legitimate business functions. Application rejection
To comply with legal and regulatory obligations, we retain certain Personal Data associated withrejected applications for AtoB Accounts. California rights
If you are a California resident, you have certain rights over the information that we have aboutyou. You can: • Access a copy of any Personal Data we have about you
• Delete any Personal Data we have about you when we do not have legal or contractualobligations to keep the information or a need for the information to carry out a legitimatebusiness function
• Correct any Personal Data we have about you either in your settings, by contacting your AtoBAccount administrator, or by contacting us as provided below Exercising your choices
To exercise your choices about your Personal Data, please contact our Customer Support teamat +1 (833)-947-2862; we are available 24 hours a day, 7 days a week. We will need to verifyyour relationship to the AtoB Account (for example, if you’re an administrator of an AtoBAccount) and verify your identity. Verification will require that you verify your email and phonenumber and provide a copy of a government issued ID to us. We may take additional steps toverify that you are authorized to make the request. If you are an end user of AtoB’s services andnot a direct customer of AtoB (for example, your Company uses AtoB and you’re an employeeor authorized representative of that Company), you should direct requests relating to yourPersonal Data to the administrator of your Company’s AtoB Account. We will not discriminateagainst you for exercising any of your rights. Sale of Personal Data (“Do Not Sell My Personal Information”)We do not sell your Personal Data. 7. Changes to this privacy policy
We may make minor updates to this Privacy Policy, and we encourage you to visit this site fromtime to time to be aware of and review any updates. We will notify you of material changes,changes that limit any of the rights you have related to the manner in which we process your Personal Data under this Privacy Policy, or that we are required to disclose by law, via aprominent notice on our website, login screen, your mobile app, or via email at least 30 daysprior to the changes taking effect. We also provide information about how our Privacy Policy haschanged over time in the Previous Privacy Policies section or on our Github. 8. Contacting us
If you have concerns, questions, or would just like to better understand our privacy practices atAtoB, please send an email to support@atob.us. If you prefer to contact us by mail, please writeto CElegans Labs, Inc, Four Embarcadero Center, Suite #1400, 94111.