Privacy Policy

Last Updated: March 16, 2025

1. INTRODUCTION

Noble ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our financial education platform, website, and services (collectively, the "Service").

We designed this Privacy Policy to help you understand our practices regarding personal information of both Parent Users and Teen Users, with special attention to the enhanced protections we provide for teens aged 13-17. Please read this Privacy Policy carefully. By using our Service, you agree to the practices described in this Privacy Policy.

If you are a Parent User registering a Teen User, you represent that you have authority to consent on behalf of your teen and understand the special provisions that apply to users under 18 years of age.

2. INFORMATION WE COLLECT

2.1 Personal Information

We may collect the following types of personal information:

  • Account Information: When you register, we collect your name, email address, and create login credentials.
  • Profile Information: Information you provide in your user profile, including but not limited to your name and contact information.
  • Financial Information: We receive read-only access to transaction data from connected accounts. We do not store your bank credentials or have the ability to initiate transactions.
  • Usage Data: Information about how you use our Service, including interaction with features, content preferences, and app settings.
  • Device Information: Information about your device, including IP address, browser type, operating system, and device identifiers.

2.2 Information About Teen Users

We collect information about Teen Users (ages 13-17) only with verifiable parental consent. The information we collect about teens is limited to what is reasonably necessary to provide our Service and includes:

  • Name and age
  • Email address (for account authentication)
  • Financial transaction data (from connected accounts)
  • Financial goals and preferences
  • Educational progress within the Noble platform

We implement special safeguards for teen data as described in Section 8 of this Privacy Policy.

3. HOW WE COLLECT INFORMATION

3.1 Direct Collection

We collect information directly from you when you:

  • Create an account or complete your profile
  • Connect your bank account using secure third-party services
  • Set financial goals and preferences
  • Complete educational activities in the app
  • Communicate with us through the app, email, or other channels

3.2 Automatic Collection

When you use our Service, we may automatically collect certain information through:

  • Cookies & Similar Technologies: Small data files stored on your device that help us improve our Service and your experience, understand usage patterns, and remember your preferences.
  • Log Files: Record of your activities within our Service, including pages visited, time spent, and other usage statistics.
  • Device Information: Technical data about your device, connection, and browsing behavior.

You can adjust your browser settings to refuse cookies, but this may limit some functionality of our Service.

3.3 Third-Party Sources

We receive information from third-party services that help us provide our Service, including:

  • Bank Account Connection: When you connect your bank account, we use secure third-party services (like Plaid) to access your transaction data. These services provide us with read-only access to your financial information.
  • Analytics Providers: Companies that help us understand how users interact with our Service.

4. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

  • Provide and Maintain the Service: To deliver the features of our platform, including tracking financial behavior, setting goals, and providing educational content.
  • Personalization: To customize your experience, recommend content, and provide relevant financial insights.
  • Communication: To respond to your inquiries, send service-related notifications, and communicate administrative information.
  • Account Management: To create and maintain your account, verify your identity, and process your transactions.
  • Parent-Teen Connection: To facilitate appropriate oversight by parents while respecting teen autonomy and privacy.
  • Improve Our Service: To analyze usage patterns, troubleshoot issues, and enhance our platform.
  • Security: To protect our Service, prevent fraud, and ensure the safety of user data.
  • Legal Compliance: To comply with applicable laws, regulations, and legal processes.

For Teen Users, we limit our use of personal information to what is necessary to provide the Service and comply with legal requirements.

5. HOW WE SHARE YOUR INFORMATION

We may share your personal information in the following circumstances:

  • Parent-Teen Relationship: Parent Users will have access to certain information about their Teen Users' financial activities and educational progress, as described in our Service features.
  • Service Providers: We may share information with third-party vendors, consultants, and other service providers who need access to such information to perform work on our behalf.
  • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
  • Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities.
  • Protection of Rights: We may disclose information to protect and defend the rights, property, or safety of Noble, our users, or the public.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

6. DATA SECURITY

We implement appropriate technical and organizational measures to protect the security of your personal information, including:

  • Encryption of transmitted and stored data
  • Secure user authentication procedures
  • Regular security assessments and testing
  • Restricted staff access to personal information
  • Security training for our personnel

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining how long to keep your information, we consider:

  • How long we need the information to provide our Service
  • Our legal obligations
  • Whether retention is advisable in light of our legal position

When we no longer need personal information, we will securely delete or anonymize it.

8. CHILDREN'S PRIVACY

Our Service is intended for teens aged 13 and older with parental consent. We comply with the Children's Online Privacy Protection Act ("COPPA") and similar state laws regarding teen privacy.

8.1 Parental Consent

We require verifiable parental consent before collecting personal information from teens under 18. Parents provide this consent by:

  • Creating a parent account
  • Inviting their teen to join the platform
  • Confirming their relationship with the teen

8.2 Teen Privacy Protections

We provide the following additional protections for teen users:

  • Limited data collection to what is necessary to provide the Service
  • Restricted access to teen data within our organization
  • Age-appropriate privacy notices and controls
  • No third-party behavioral advertising based on teen data
  • No sale of teen data to third parties

8.3 Parental Rights

Parents can review, modify, or delete their teen's information at any time by:

  • Accessing the parental controls in their Noble account
  • Contacting our support team at [email protected]

Parents may revoke their consent and request deletion of their teen's data at any time.

9. YOUR PRIVACY RIGHTS AND CHOICES

Depending on your location, you may have certain rights regarding your personal information:

9.1 Access and Portability

You may request access to your personal information and obtain a copy of the information we maintain about you in a structured, machine-readable format.

9.2 Correction

You may request that we correct inaccurate or incomplete information about you.

9.3 Deletion

You may request that we delete your personal information in certain circumstances.

9.4 Restriction and Objection

You may request that we restrict the processing of your information or object to our processing of your information in certain circumstances.

9.5 How to Exercise Your Rights

To exercise your rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe in accordance with applicable law.

Please note that we may need to verify your identity before processing your request, and in some cases, we may need to keep certain information for recordkeeping purposes, to complete transactions, or to comply with our legal obligations.

10. STATE PRIVACY RIGHTS

Residents of certain states may have additional privacy rights under state laws. These include:

10.1 California Privacy Rights

California residents have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

  • The right to know what personal information we collect and how we use it
  • The right to delete personal information
  • The right to opt-out of the sale or sharing of personal information
  • The right to non-discrimination for exercising these rights

To exercise these rights, contact us at [email protected].

10.2 Other State Privacy Laws

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights to access, delete, correct, and opt out of certain data processing. Please contact us to exercise these rights.

11. INTERNATIONAL DATA TRANSFERS

We are based in the United States and the information we collect is governed by U.S. law. If you access our Service from outside the United States, you understand that your information may be transferred to, stored, and processed in the United States, where our servers are located.

If we transfer personal information from the European Economic Area, United Kingdom, or Switzerland to countries that have not been deemed to provide an adequate level of protection, we use appropriate safeguards such as standard contractual clauses approved by the relevant authorities.

12. THIRD-PARTY LINKS AND SERVICES

Our Service may contain links to third-party websites, services, or content that are not owned or controlled by Noble. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites or services before providing any information to them.

When you connect your bank account to our Service, you may be subject to the terms and privacy policies of the third-party service we use to establish that connection. Please review those policies carefully.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by email (if you have provided one) or by means of a notice on our Service prior to the change becoming effective.

For changes affecting Teen Users, we may require renewed parental consent.

We encourage you to review this Privacy Policy periodically to stay informed about our information practices.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Noble Inc.

1234 Financial Street

San Francisco, CA 94101

Email: [email protected]

Phone: (555) 123-4567

We will respond to your inquiry as soon as reasonably possible, typically within 30 days.