Privacy Policy

Safehold, Inc.

Privacy Policy

Last Updated: November 9, 2021

Safehold, Inc. (“Able,” “we,” “us,” or “our”) welcomes you. We invite you to access and use our mobile application and mobile site (collectively, the “App”), which is accessible through tablets, smart phones, connected televisions, and other devices. This privacy policy (the “Privacy Policy”) describes how we process the information we collect from or about you when you visit or use the App or the Service available through the App (collectively, the App and the Service are referred to as the “Service”). By accepting this Privacy Policy, accessing or using the Service, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy, then please do not use the Service. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

THE INFORMATION WE COLLECT AND HOW WE USE IT

In the course of providing the Service, Able collects or receives the following types of information from visitors and users of the Service, and from third-party integration partners, which may include personal information.

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Contact Information

We collect contact information through the Service; contact information typically includes your name, email address, phone number and any other information you provide in messages to us. We use such contact information for purposes such as providing you with information about the Service, responding to your inquiries, sending you email alerts (including marketing emails), verifying your identity, maintaining our waitlist of users seeking to open an Able Account, or providing you the Service.

Referrals

Users on our waitlist may choose to refer a friend to our Service by sending an invite (provided by Able) via text. If your friend accepts by entering the required code, then you will be removed from the waitlist, and you and your friend will be invited to apply for an Able Account.

Account Access Information

In connection with the creation of an account on our App (your “Able Account”), we collect account credentials such as your username, your legal name and, as applicable, the name and EIN of your operating entity, home address, social security number, date of birth, the name of your bank, credit union, or other financial institution where you have your primary accounts, and other enrollment information. We process this information to open your Able Account including verifying your identity. After completing identity verification, we delete your Social Security Number and retain only the last 4 digits. We also use this information to manage your Able Account including your transactions. We refer to users that open an Able Account as “Account Owners.”

Transaction Information

When you make, or attempt to make, a transaction as an Account Owner through our App, we may collect certain information from you, including your name, billing address, mailing address, email address, and phone number. We refer to this information as “Transaction Information.” We use the Transaction Information that we collect generally to facilitate transactions through our App (including providing you with transaction confirmations). Additionally, we use this Transaction Information to: communicate with you; screen our transactions for potential risk or fraud; and when in line with the preferences you have shared with us, provide you with information or advertising relating to our other products and/or services. Our third-party payment processing providers, including Plaid, may also collect from you, process and store your payment information including credit card information, and/or bank account information at your selected financial institution(s), and link those accounts to your Able Account, all in accordance with their respective privacy policies (links below).

Plaid: https://plaid.com/legal

CorePro: https://docs.corepro.io/docs/customer

We reserve the right to change our payment vendors at any time, or to use additional payment vendors, at our discretion, and will update this Privacy Policy from time to time accordingly.

Service

Our Service is intended to enable Account Owners to track their income, calculate estimated taxes, and save for taxes in their Able Accounts. Account Owners may choose to subscribe to other services offered by Able from time to time. We may request that you provide access to your contacts to facilitate provision of our Service, and we will only use your contacts for the Service you select.

Server Log, Device and Other Technical Information

Our servers keep log files that record data each time a device accesses those servers. The log files may contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and the pages you’ve clicked on while on our Service, and details regarding your activity on the Service such as time spent on the Service and other performance and usage data. We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience.

Geolocation Information

We may, with your consent, automatically collect geolocation information from your device via your browser’s location service. This consent may be provided by you on the device level (e.g., you have consented to location service generally through your browser’s settings) or by accepting our request for geolocation access on the Service. Please consult your browser’s documentation regarding how to turn off location service. If you disable location service, you may not be able to use the full array of features and functionalities available through our Service.

Other Data Collection

We may collect additional information regarding you and your use of our Service, your interactions with us and our advertising, as well as information regarding devices used to access our Service (collectively, the “Other Information”). Other Information may include:

From Your Activity. Information that we automatically collect when you use the Service, such as (i) information about the device from which you access the Service (i.e., the type of device, the advertising identifier (“IDFA” or “AdID”), the operating system and version (for example iOS, Android or Windows), your carrier and network type (WiFi, 3G, 4G, LTE); (ii) your IP addresses (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device); (iii) browser type and language; (iv) referring and exit pages and URLs; (v) date and time; (vi) amount of time spent on particular pages; (vii) what features of the Service you use or visit; and (viii) similar information concerning your use of the Service.

From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your device to remember information about your visit to the App. We use cookies to help us collect Other Information and to enhance your experience using the Service. Specifically, we use cookies to authenticate users, personalize your experience when using the Service, analyze which features of the Service you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. If you do not want the Service to use cookies, you may be able to turn that feature off on your device. Please consult your Internet browser’s documentation for further information. However, if you decide not to accept cookies from us, the Service may not be available or function properly.

Third-Party Analytics. We may use third-party analytics services (such as Google Analytics) to evaluate your use of the Service, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Service and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Service, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytic Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Service.

Aggregate and De-identified Data

In an ongoing effort to better understand our users and the Service, we might analyze your information in aggregate and/or de-identified form to operate, maintain, manage, and improve the Service. We may share this aggregate or de-identified data with our affiliates, agents, and business partners. We may also disclose aggregated or de-identified user statistics to describe the Service to current and prospective business partners and to other third parties for other lawful purposes.

Onward Transfer to Third Parties

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• Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: technical assistance, database management/back-up service, use analytics, email marketing, customer service, and other types of business services we may use from time to time.

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• To provide our Service and administer promotional programs, we may share your personal information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.

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• We may also disclose personal information to our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control to support the marketing and sale of our Service.

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• We may share Other Information about your activity in connection with your use of the Service with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on our App and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. By accessing and using the App, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy.

We may share your personal information with third parties that are not service providers or vendors, so that those third parties can send you information about their products and/or services. If you do not wish to have your personal information shared directly with these third parties (other than our service providers and vendors), please submit your request to our email at: support@able.com. Please allow us a reasonable time to implement your request to stop sharing your personal information for this purpose.

Business Transfers

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Able and its legal successors in interest.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Opt-Out for Direct Marketing; Email Management

You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to support@able.com or by clicking on the “Unsubscribe” link located on the bottom of any Able marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Service.

How We Protect Your Information

Able takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable security measures designed to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Children

The Service is intended for users 13 years or older; you are not permitted to access or use the Service if you are younger than 13. We do not knowingly collect personal information from children under the age of 13 through the Service. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at support@able.com, and we will endeavor to delete that information from our databases.

Important Notice to All Non-US Residents

Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Service, you do so at your own risk.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of Service or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Able via email at support@able.com. Able does not respond to “do not track” settings or other related mechanisms on our App at this time.

Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties for monetary consideration. You can exercise this right by contacting us at support@able.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. We may request additional information to verify your identity. Please allow us a reasonable amount of time to address your request.

Links to External Websites

The Service may contain links to third-party websites (“External Sites”). Able has no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting any such External Sites.

Accessing and Modifying Account Information

Account Owners may access, review, and make changes to the information in your Account by following the instructions found on the App. You should be aware, however, that it is not always possible to modify or completely remove all the information in our subscription databases. In such case, we will provide you the reason why the modification or removal was not possible.

Changes to this Privacy Policy

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Service after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at support@able.com with “Privacy Policy” in the subject line.

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