Privacy Notice (Gramm-Leach-Bliley Act)
FACTS — What does Initio Treasury 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.
What we collect
- Social Security number and income
- Account balances and transaction history
- Credit history and credit scores
- Identification documents and government-issued IDs
- Device, IP, and usage data from our apps and website
How we share
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 Initio chooses to share, and whether you can limit this sharing.
| Reason | Do we share? | Can you limit? |
|---|---|---|
| Everyday business (process transactions, maintain accounts, respond to court orders, report to credit bureaus) | Yes | No |
| Marketing our products and services | Yes | No |
| Joint marketing with other financial companies | No | We don't share |
| Affiliates' everyday business — info about transactions and experiences | Yes | No |
| Affiliates' everyday business — info about creditworthiness | No | We don't share |
| Non-affiliates to market to you | No | We don't share |
How we protect your information
We protect your personal information using physical, electronic, and procedural safeguards that comply with federal regulations. These include data encryption in transit (TLS 1.3) and at rest (AES-256), least-privilege access controls, multi-factor authentication for all employees, third-party SOC 2 audits of our vendors, and continuous monitoring.
State-specific rights
California (CCPA/CPRA): California residents may request to know, delete, or correct personal information, and to opt out of sale or sharing for cross-context behavioral advertising — which we do not do. Submit requests at privacy@initiotreasury.com.
Vermont: We will not share information about you with non-affiliates unless you authorize us to.
Nevada: To opt out of marketing email, contact privacy@initiotreasury.com.