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HOMEOUR SOLUTIONSCONTACT


A PRODUCT OF INNOVATION


ABOUT

At Innovation Bank, client challenges fuel our product innovation strategy.

We pride ourselves in bringing innovative products that give our clients access
to a comprehensive view of fiat and digital assets within a single portal. A
portal that meets the rigorous standards of the US banking system, enabling them
to monitor their total position and transact with confidence using our Digital
Banking solutions.


INNOVATION

That provides small and medium-sized businesses with tools to improve their
ability to access credit

That supports private lenders by reimagining funding programs

That allows for securely accessing digital transactions between parties


INNOVATION BANK

Bringing new ideas to our clients and to the financial services industry.
*Innovation Trust Bank International is one of the first IFEs in Puerto Rico to
receive a digital banking license.

Note: Some private credit products and services may not yet be available. To
find out more about our approach and future availability, please contact
info@innovationtrustbank.com for more details.

Privacy Policy


OUR LEADERSHIP TEAM

Nathan Pierce
Founder & CEO
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Luis Torres
Head of Internal Operations
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Luis Castro
Chief Compliance Officer
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Carla Torres 
Chief Compliance Officer
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Christopher Rodrigues
Risk Manager
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Philip Barr
Director of Technology
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PRIVACY POLICY

Innovation Trust Bank (“ITBI”) is committed to your privacy.  Our goal is to
maintain your trust and confidence when handling personal and financial
information about you.

 This ITBI Online Privacy Policy (“PrivacyPolicy”) describes how we collect
information when you visit or use our website and other online services (“Online
Services”). It also describes how we use and share such information. ITBI does
not sell your personally identifiable information.

 The terms “Innovation Trust Bank”, “ITBI”,“we,” “us,” or “our” mean Innovation
Trust Bank International Holdings, Inc., together with its subsidiary Innovation
Trust Bank International, Inc., and its affiliates. “You” means an individual
who visits our Online Services and doesnot refer to a business or other entity.

 

How does ITBI collect information online?

 We collect information in a variety of contexts. For example, we may collect
information:

•  Directly from you. We collect information directly from you, such as when you
register for an account, applyfor or obtain a product or service, or communicate
with us.

•  Automatically when you use ourOnline Services. We and others on our behalf
may collect Device Data,Online/Mobile Activity Data, and other information
automatically when youinteract with us online.

•  Other financial institutions.We may collect information from other financial
institutions with whom you haveaccounts, if you elect to have an account
aggregation service.

 

This Policy applies to information we collectwhen you use our Online Services,
We may combine that information withinformation we collect in other contexts,
such as from phone calls and emailswith you, from third-party data sources for
fraud prevention, identityverification, and from publicly available data
sources. We will treat suchcombined information in accordance with this Privacy
Policy.

 

What Information does ITBI collect?

 

Depending on how you interact online with us,we may collect various types of
information. For example, when you register foran account, we may collect:

•  Contact or identity data, suchas your name, mailing address, email address,
phone number, date of birth,government-issued identifier (e.g., tax ID number,
Social Security number,driver’s license, or other government ID), citizenship,
username and password,and other information that directly identifies you.

•  Account-related data, such asaccount number, account balances,
business-related information, and otherinformation related to your ITBI
accounts.

•  Transaction data, such astransaction history and transaction details when you
transfer funds to or fromyour ITBI accounts.

•  Demographic data, such asgender, marital status, age, household
size/composition, education level,income, occupation, and employment status.

 

When you browse our website, we may alsocollect:

•  Device data, such as yourdevice type, web browser type and version, operating
system type and version,display/screen settings, language preferences, internet
protocol address,mobile network information, general location, cookie IDs,
device IDs, mobileadvertising IDs, and likely connections among different
browsers and devicesthat you use (collectively, “Device Data”).

•  Online/mobile activity data,such as login data, information about how you use
and interact with our OnlineServices, when and how often you use our Online
Services, the webpage fromwhich you clocked a link to come to our Online
Services, and crash reports(collectively, “Online/Mobile Activity Data”).

•  Communications data, such asyour communication preferences and details or the
content of yourcommunications with us.

 

If you disclose any information relating toother people to us or our service
providers when you visit or use the OnlineServices, you represent that you have
the authority to do so and to permit usto use the information in accordance with
this Privacy Policy.

 

How does ITBI use this information?

 We use information for various purposesdepending on how you interact with us.
For example, we may use your informationfor the purposes described below:



•  Providing, maintaining, andservicing your account, such as enabling you to
apply for and obtain ITBIproducts or services, communication with you, and
providing online tools andfeatures.

•  Verifying your identity, suchas conducting identity verification when you
apply for our products orservices, authenticating your login credentials, and
verifying your location toallow access.

•  Detecting and preventing fraud,such as determining fraud risk.

•  Protecting against securityrisks, such as monitoring network activity logs,
detecting security incidents,conducting data security investigations, and
otherwise protecting againstmalicious, deceptive, fraudulent, or illegal
activity.

•  Advertising and marketing, suchas sending you offers for products and
services via mail, email, or textmessage, displaying online advertising,
targeting our offers, and evaluatingand improving the effectiveness of our
marketing efforts.

•  Conducting analytics and research,such as examining which parts of our
website you visit, performing debuggingand error repair, and analyzing use of
our Online Services.

•  Improving our products andservices, such as personalizing and optimizing your
website experience,improving existing products and services, and developing new
products andservices.

•  Carrying out legal and businesspurposes, such as complying with applicable
laws, responding to lawsuits,subpoenas, or investigations, exercising our rights
or defending against legalclaims, resolving complaints, performing compliance
activities, regulatoryreporting, performing institutional risk control, and
otherwise operating,managing, and maintaining our business.

•  Using aggregated andde-identified information, such as using or modifying the
information describedin this Privacy Policy in a manner that does not allow us
to reasonablyidentify you. For example, we may compile aggregated statistics to
understandtrends. Information that has been aggregated and de-identified is no
longersubject to this Privacy Policy.

 

How does ITBI share this information?

 We share information in a variety of contacts.For example, we may share your
information with:

•  Affiliates. We may share yourinformation with our affiliates as permitted by
applicable law.

•  Service providers. We use othercompanies to provide services on our behalf
and to help us run our business. Wemay share information with these service
providers, or they may collectinformation on our behalf, for various business
purposes. For example, we useservice providers for hosting and securing our
information systems.

•  Government entities and otherswith whom we share information for legal or
necessary purposes. We shareinformation with government entities and others for
legal and necessarypurposes, such as:

•  To respond to requests from ourregulators or to respond to a warrant,
subpoena, governmental audit orinvestigation, law enforcement request, legal
order, or other legal process.

•  To facilitate a merger,acquisition, sale bankruptcy, or other disposition of
some or all of ourassets, in which case we may transfer your information to the
relevant thirdparty.

•  For other legal purposes, suchas to enforce our terms and conditions,
exercise or defend legal claims, or ifwe determine that disclosure is necessary
and appropriate to protect the life,safety, or property of ourselves or others.

•  Recipients of aggregated andde-identified information. We may share
aggregated and de-identifiedinformation with third parties for any purpose.

 

What online tracking technology does ITBIuse?

 We and third-party providers acting on ourbehalf use a variety of online tools
and technologies to collect informationwhen you visit or use the Online
Services, including Device Data and Mobile/OnlineActivity Data. We may associate
this tracking data with your ITBI account ifyou have one.  These tools include
serverlogs, cookies and pixel tags.

 

INFORMATION SECURITY

 At ITBI, we prioritize your safety andsecurity. We have information security
practices in place that includeadministrative, technical and physical measures
to protect information withinour company. While we use industry-standard
practices to protect yourinformation, no method of data transmission or storage
is 100% secure, and wecannot ensure or warrant the security of your information.
Your use of ourservices is an acknowledgement that ITBI is not liable or
responsible for anyinformation security breach despite our commercially
reasonable informationsecurity practices and you hereby waive and release ITBI
from any and allclaims related to an information security breach. If you suspect
yourinteraction with us is no longer secure, please contact us at
info@innovationtrustbank.com.

 

OPT OUT

 You can unsubscribe from marketing andinformational emails from ITBI and its
affiliates utilizing your personalinformation on by contacting ITBI at
info@innovationtrustbank.com.

 

CHILDREN’S PRIVACY

 Our Online Services are not directed tochildren under 18. We do not knowingly
collect personal information fromchildren through out Online Services. We kindly
request that children do notprovide information to us through our Online
Services.

 

UPDATES

 We may change this Privacy Policy in thefuture. When we do, we will post the
revised Privacy Policy on our website.Your use of the Online Services
constitutes your agreement with the Policyterms.

 

CONTACT

 Please direct questions to info@innovationtrustbank.com.