Privacy Policy

Juno’s top priority is building trust. As a fintech, one of the ways we earn your trust is by being transparent and protecting your privacy. This drives all product decisions and information we collect from you. This Privacy Policy should help you understand how we gather and use your banking and personal information.

CAPITALJ, Inc., d/b/a Juno (referred to as "Juno," "us," "our," or “we”) values your privacy. This Privacy Policy ("Policy") explains Juno’s privacy practices for visitors to Juno’s website and users of Juno’s mobile app (“you” or “your”) about the personal information we collect, and how we source, use, disclose, and protect your information when you access or use (1) our website located at https://www.juno.finance/, and all of our other websites to which this Privacy Policy is posted (collectively, the “Site”); (2) our mobile application(s) to which this Privacy Policy is posted (collectively, the “App”); and (3) any services, content, communications, and product features relating to the Site and App (together with the Site and the App, the “Services”). It also contains a Privacy Notice as required under the Gramm-Leach-Bliley Act (“GLBA”).

This Privacy Policy covers the privacy practices of Juno only. It does not apply to the practices of third-party websites, services, or applications (collectively, “Third-Party Services”), including third party banking providers with which we partner (“Banking Providers”). These Third-Party Services are governed by each such third party’s privacy policy, which you should review before using such Third-Party Services. We are not responsible for the privacy policies and practices of Third-Party Services or their failure to follow their own privacy policies and practices, or applicable law.

This Policy is effective as of the date that it is last updated. Unless otherwise stated, any modifications to this Policy will go into immediate effect after they have been posted to the App or SIte, as indicated by the Last Updated date located at the top of every page in this Policy.

BY ACCESSING THIS SITE OR USING SERVICES OFFERED THROUGH JUNO, YOU GIVE YOUR CONSENT THAT ALL PERSONAL INFORMATION MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW, AND YOU AGREE TO THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, DO NOT ACCESS THE SITE OR USE THE SERVICES.

If you use our App and Services, you certify that you have reached the age of majority in the state of your residence, that you are a U.S. resident or citizen, and that you are not using the App or Services for your or your employer’s commercial purposes, and you agree to this Policy. Our App and Services are not presently permitted for use by a person that is not a U.S. resident or citizen.

Our Site is intended for residents of the U.S., but if you are accessing the Site from outside the U.S. you agree that your personal information may be transferred to the U.S., which may have less protection for your personal information than your jurisdiction of residence.

We reserve the right to change this Policy from time to time with or without notice to you. We will post any such changes on the Site and on any privacy policy link in the App. You acknowledge and agree that it is your responsibility to review the Policy. Your continued use of this Site and App, and any offerings made available on the Site after a change is posted, including but not limited to the use of the Services, will constitute acknowledgment and acceptance of the then-published Policy.

This Policy is subject to and incorporated into our Terms of Use, including its provisions on dispute resolution and limitation of liability, to the extent permitted by law.

This Policy generally applies to personal information that identifies you or that is considered personal information or personal data under laws that apply to us. Some information may not be considered personal information, such as publicly available information from federal, state or local records or information that is aggregated or de-identified, such that it cannot reasonably be linked to an individual.

For our Privacy Notice under GLBA, click this link.

We collect any information that you provide to us on the Site or Services or through your access to or use of the Site or Services. This includes, but is not limited, to:

• Information you provide to join a waitlist, such as your name and e-mail address; financial data such as balances and transactions on bank accounts, credit cards, savings, and deposits;
• Information you provide when you sign up for priority access, including first name, last name, email address, and password.
• Information when you download the App, including first name, last name, email address, password, and country.
• Information you provide when apply for a job with us through the Site, such as your name, email address, employment, professional and employment background and credentials and other information you may provide in your CV or resume.

We also collect and track certain information automatically regarding (a) devices used to access our Site and Services through our third-party service providers including, IP address, device ID, mail ID, mobile phone number, geographical location of such devices such as country and city, operating system, and browser engine and (b) usage of our Site and Services, including pages first seen and last seen, time spend on the Site or Service, the last opened email, and last clicked link, and the referring URL, or the webpage that led you to our Site. For what technologies we use to collect this information, please see the section entitled “How We Use Your Information.”

If you use Plaid, Inc. (“Plaid”) through the Services to connect your personal and financial information, you understand and acknowledge that:

Juno uses Plaid Inc. ("Plaid") to gather your data from financial institutions, including your banking institution name, account types, account balance snapshot, available transactions for past 12 months, and identity data, including full name and address.

By using our Services, you grant Juno and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

If you have provided permission through your mobile device to allow us to collect location information through the App, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device's location services, we recommend you contact your mobile device service provider or the mobile device manufacturer. Your information collected through the Site or Services as described above may be combined with other information we collect about you from third- party sources.

We collect information when you voluntarily provide it to us. For example, if you elect to provide your name or e-mail address or both to join a Juno waitlist or be notified of an upcoming product launch, we will collect that information. We also collect information when we process your application or service your account in connection with Services offered through Juno, including for example, when you download our App. Further, we collect information provided by third parties, including third parties that provide services for us, such as credit reporting agencies, data providers, and identity verification and fraud detection service providers.

Information may be collected using tools such as cookies. A cookie is a small data text file that is stored on your computer that uniquely identifies your browser. Cookies may include personalized information, such as your IP address, browser type, the server your computer is connected to, or the area code and ZIP code associated with your server. Most browsers are initially set up to accept cookies, but many browsers allow you to refuse some or all cookies or to indicate when a cookie is being sent. Some aspects of the Site may not function properly if you elect to disable cookies.

You can login into our Service through your Google account. You agree to share with us your Google credentials solely to authenticate you to access the Services. Your use of Google, and other social media and third-party websites, and the information shared with us by such websites, are subject to those websites' privacy policies, terms of use, and settings for privacy and advertising.

WE WILL NEVER REQUEST ANY OF YOUR PERSONAL FINANCIAL INFORMATION ON ANY SOCIAL MEDIA WEBSITE. If you are asked for personal financial information on a third-party website, such as bank account information or your Social Security number, we recommend that you DO NOT provide it.

You understand and agree that Juno may record and monitor any telephone or electronic communications with you for quality and testing purposes. Unless otherwise agreed in writing in advance, Juno does not consent to the recording of telephone conversations by any third-party or you.

We will primarily use the information we collect to provide the Services and other product or service offerings to you as they become available. We may also use the information we collect for the following purposes:

• To respond to your requests or questions;
• To provide you with the Services that you request;
• To inform you of Services that we think may be of interest to you;
• To enhance Site or Services operations;
• To improve marketing or promotional efforts;
• To better understand the interests of Site visitors and users of our Services to design products or services;
• To analyse use of the Site and Services and observe your behavior and browsing activities over multiple websites and platforms;
• To process and evaluate job applicants, and for general employment purposes if an applicant that has applied through our Site is hired;
• To customise Site content, layout, and services;
• To authenticate users and recognize authorised devices;
• To prevent fraud;
• To enforce our agreements;
• For any other purpose for which you provide consent; or
• As otherwise permitted or required by law.
• Aggregate or anonymous data may be used for any legitimate business purpose at any time.

Juno has contracted with Jiko Group, Inc.(“JGI”) a bank holding company regulated by the Federal Reserve. JGI has three primary operating subsidiaries: Jiko Technologies, Inc.; Jiko Bank, which is a division of Mid-Central National Bank (“MCNB”; MCNB is a wholly owned subsidiary of JGI); and Jiko Securities, Inc., a registered broker-dealer (together referred to as “Jiko and its affiliates”). All brokerage services, US Treasury investments, and investment advisory services provided by Jiko Securities, Inc. a registered broker-dealer, member FINRA and SIPC.

Jiko conducts “Know Your Customer” checks in order to provide you access to services. For purposes of satisfying “Know Your Customer” requirements, Juno asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, videos, and photographs including your driver’s license or government-issued identification number or card. Juno will also collect information pertaining to your account transactions. Your personal information will be shared with Jiko and will be subject to the Jiko Privacy Policy. Jiko will share your information as necessary with its affiliates in connection with providing their services to you

We also share the information we collect about you with third parties for BSA/AML purposes generally consistent with the purposes described in the section How We Use Your Information. The following are the situations in which and the third parties with which we may share your information:

• Business Partners: As noted above, we may offer Third-Party Services through our Site or Services, or Services that are provided jointly with a third party. In such cases, your personal information may be shared with such third parties for the purposes of providing the Third-Party Services or jointly offered Services. For example, some of the Services, such as deposit, checking and cash accounts, are provided through our Banking Providers and we may need to share your personal information with them, and they may collect personal information directly from you to provide those Services. You may have rights to opt-out of such sharing as indicated in our GLBA Privacy Notice.
• Affiliates: We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Privacy Policy.
• Service Providers: We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. For instance, we send information to CleverTap to send you emails and push notifications, Twilio to send you text messages (SMS), Sendgrid to send you emails regarding your account and Intercom for customer support in order to serve you better. Please note that this is not an exhaustive list of Service Providers
• In Response to Legal Requests: We also may disclose the information we collect from you when we believe in good faith it is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena, or at the request of governmental authorities conducting an investigation
• To protect us and others: We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, in response to law enforcement violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which we are involved. We fully cooperate with law enforcement agencies in identifying those who use our Site and Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
• Business transfers: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, personal information collected through the Services may be disclosed to such an entity as one of the transferred assets. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
• With your permission: At your direction or request, we may share your Personal Information with specified third parties.
• Aggregate and De-Identified Information: We may share aggregate or de-identified information about users and their use of the Services with third parties and publicly for marketing, advertising, research or similar purposes.

We do not sell personally identifiable information, and we will not sell personally identifiable information except as described in this Policy. If we ever decide to sell personally identifiable information, we will provide you with notice and a right to opt-out of such a sale.

Some content or applications on the Site or Services may be provided by third parties, including analytics companies and advertising providers. Our Site and Services may also include social media features, such as the Facebook "Like" button, and other widgets, such as the "Share" button or interactive mini-programs provided by third parties. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

We may also collect information about you when you interact with Juno on social media websites or third-party websites. These websites include but are not limited to, Facebook and Twitter. Your use of social media and third-party websites, and the information shared with us by such websites, are subject to those websites' privacy policies, terms of use, and settings for privacy and advertising

Juno uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics collects information such as how often you use our Services and how you use our Services. We use the information provided by Google Analytics to improve the Services. For more information regarding how Google collects, uses, and shares your information and how to opt out of certain uses please visit http://www.google.com/policies/privacy/partners/. By using the Services, you consent to the processing of information about you by Google as described here and in Google's privacy policy.

Additionally, Juno uses third parties to track user analytics, user attributions and to install and manage multiple marketing tags. Meta, Google Ads and Twitter Pixel are used for advertisement improvements and optimisations. Please note that this is not an exhaustive list of Third - Parties.By using the Services, you consent to the processing of information about you by these parties. We do not control these third parties' tracking technologies on our Site and Services or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. For example, some of these companies may be members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA"), which allow you to opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, visit http://www.networkadvertising.org/managing/opt_out.asp or http://www.aboutads.info/choices.
Our Site may provide links to other websites. Please be aware that when you click on one of these links, you are going to another website, even though the Juno banner or toolbar may still be visible. Information you enter on these other websites are being collected by those websites, not Juno. Their privacy policies may allow disclosures and uses of personal information that are not allowed by Juno. We encourage you to read the privacy policies of these linked websites as they may differ from ours.

Do Not Track Disclosure

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser and do not respond to such signals.

We may, from time to time, send you e-mails regarding new products that we feel may interest you. To update your marketing preferences to stop receiving these e-mails from us, you can "opt-out" or "unsubscribe" by following the instructions included in each e-mail. Please note that we will still provide responses to your questions, information that you request about a product or service, and e-mails for account-related purposes if you revise your marketing preferences to opt out of receiving promotional material.

Juno does not believe it is currently subject to the California Consumer Privacy Act (CCPA). If and when we become subject to the CCPA, we will update this Privacy Policy to include the notices and provide the rights specified under the CCPA.

California’s “Shine the Light” law (which is different from the CCPA) provides California residents the right to request from Juno: a list of the categories of Personal Information that we have disclosed to third parties for direct marketing purposes; and the names and addresses of all such third parties.

We do not share your Personal Identifying Information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission.

We will not discriminate against you because you exercise any of the rights as described in this section.

We strive to take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure, or destruction of your personal information. Unfortunately, no method of data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, we strive to protect your personal information. You acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed. We encourage you to be careful when using the Internet or transmitting data through a wireless network.

If you have any questions about this Policy, please feel free to contact us at [email protected]