Privacy Policy - Aaim Institutional

1. Introduction

Aaim, Inc. ("Aaim," "we," "our," or "us") operates as a privacy-focused provider of asset verification services. This Privacy Policy describes how we collect, use, share, and protect personal information in connection with our asset verification, valuation, and monitoring services. Our services are primarily provided to financial institutions ("Partner Institutions"), and these guidelines apply when you access our services through partner banks or credit unions.

2. Definitions

Personal Information: Data identifying or reasonably linkable to an individual or household
Financial Information: Account details, balances, transaction histories, and investment portfolios
Partner Institutions: Banks and credit unions utilizing our services
Service Providers: Third-party vendors assisting with service delivery

3. Information We Collect

3.1 User-Provided Information

When you authorize our services, we collect: name, email address, phone number, and other contact information. With your authorization, we also gather financial account details including account numbers, balances, transaction history, investment holdings, and portfolio composition.

3.2 Automatically Collected Data

We collect usage patterns, device specifications, and implement cookies and similar technologies to collect information about your interaction with our Services.

3.3 Third-Party Sources

Information flows from financial institutions, data aggregators (including Plaid, MX, Finicity, and Quiltt), and fraud prevention service providers.

4. How We Use Your Information

4.1 Service Provision

Uses include asset verification for lending, risk assessment development, transaction processing, and service improvement.

4.2 Security Measures

We employ information to verify your identity and protect against fraudulent or unauthorized transactions.

4.3 Communications

We send support responses, technical notices, and security alerts.

4.4 Legal Compliance

Information supports regulatory adherence and rights protection.

5. How We Share Your Information

5.1 Partner Institution Sharing

Data transfers occur as necessary to provide your chosen and specifically-authorized Services, including asset verification, valuation, and monitoring for lending purposes.

5.2 Authorized Service Providers

Sharing extends to vendors performing: data processing, analytics, fraud prevention, customer service, and advisory assistance.

5.3 Legal Requirements

We may share information to comply with applicable laws, regulations, and legal processes.

5.4 Business Transitions

During mergers or acquisitions, information may transfer with adequate, proper prior notice and rationale.

5.5 Consent-Based Sharing

Third-party sharing occurs when you explicitly authorize it.

6. Data Security

We implement encryption of sensitive information in transit and at rest, access controls and authentication requirements, and maintain security controls aligned with SOC 2 and FFIEC guidelines. No security system is impenetrable, and we cannot guarantee the security of your information.

7. Your Rights and Choices

7.1 Access and Portability

You may request personal data in a structured, commonly used, and machine-readable format.

7.2 Correction

You can correct inaccurate information.

7.3 Deletion

You may request deletion of your personal information.

7.4 Restriction

You may restrict processing in certain circumstances.

7.5 Consent Withdrawal

You retain the right to withdraw consent for information processing.

7.6 Exercise of Rights

Requests should be directed to privacy@aaim.com. Some of these rights may be limited where we have compelling reasons to continue processing your information.

8. Children's Privacy

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18.

9. International Data Transfers

Information collected through the Services may be transferred to, processed, stored, and used in the United States and other jurisdictions.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

11. Contact Us

If you have questions about this Privacy Policy, please contact us.

Email: privacy@aaim.com

Address: 99 Wall Street, Suite 1610, New York, NY 10005

Phone: (212) 931-6500

For European, UK, and Swiss residents, Aaim functions as a data processor on behalf of Partner Institutions.