Platform Services Privacy Policy

Last updated: August 7, 2020

This Privacy Policy describes how your personal information is collected, used, and shared when you utilize the Custodia (“Custodia, “Our”, “We”) platform services at any of the following channels (collectively “Services”):

Personal Information We Collect

When you utilize our Services, we automatically collect certain information about your device, which includes:

  • IP address
  • Time zone
  • Web browser
  • Device type
  • Cookies

Additionally, we collect information about the individual web pages or screens that you view, what websites or search terms referred you and information about how you interact with our Services. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. We leverage cookies to create a login session for you to utilize our Services.

“Log files” track actions occurring with our Services, and collect data including your IP address, browser type, device type, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse our Services.

Additionally, in order to utilize the Services we require certain information from you, which includes:

  • Your name
  • Your email address
  • Your phone number

We refer to this as “Required Service Information.” Separately, the Services can be optimized by providing additional information, including:

  • Your location
  • Your calendar
  • Your contacts
  • Your bank account information

We refer to this as “Requested Service Information.” When we talk about “Personal Information” in this Privacy Policy, we are talking about Device Information, Required Service Information and Requested Service Information..

How Do We Use Your Personal Information?

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Services (for example, by generating analytics about how our customers browse and interact with our Services).

We use Required Service Information to provide you with access to our Services, including multi-factor authentication, and to send you notifications of events related to your login on our platform.

We use Requested Service Information to provide you with the best experience with our Services, by providing tailored data enhancements based on your location, calendar and contact information.

Sharing Your Personal Information

We share your Required Service Information and Requested Service with third parties in order to provide you with access to certain elements of our Services. 

  • We may provide your name to Marqeta if a corporate card is requested on your behalf (your name is required to be printed on the corporate card. You can read more about Marqeta’s privacy policy at
  • We may provide your banking information to Dwolla if you desire to enable ACH payments. You can read more about Dwolla’s privacy policy at
  • We may provide your physical address and location data to Google for the purposes of enhancing search requests for flights, meals and taxis. You can read more about Google’s privacy policy at

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to subpoenas, search warrants or other lawful requests for information we receive, or to otherwise protect our rights.

Behavioral Advertising

We do not use any Personal Information for the purposes of Behavioral Advertising.

Do Not Track

Please note that we do not alter our Services data collection and use practices when we see a Do Not Track signal from your browser.

Your Rights

You have the right to access the personal information we hold about you and to ask that your personal information is corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Data Retention

Any information you enter and submit to us via our Services may be maintained unless and until you ask us to delete this information.

Privacy Shield

We have certified to the U.S. Department of Commerce that we adhere to the Privacy Shield Principles.  If there is any conflict between these terms and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit and to view our Privacy Shield Policy, please visit


We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at