Privacy Notice

Last updated: March 23, 2026

This privacy notice for Code Pebble, Inc ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") each user's ("you" or "your") information when you use our roo.money website ("website") or mobile application ("app") services (collectively the "Services"), such as when you:

The Services are operated and managed within the United States. By using and accessing the Services, you agree and consent to the transfer and processing of personal information on servers located in the United States, even if you are a resident or citizen of a country or jurisdiction outside of the United States, and that our protection of your information may be different than required under the laws of your location.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@roo.money. If you make a request, please provide us with your full name, your username, and email address used to create your account. We will respond to you within forty-five (45) days.

Table of Contents

  1. What Information Do We Collect?
  2. How Do We Collect Your Data?
  3. How Do We Process Your Information?
  4. When and With Whom Do We Share Your Personal Information?
  5. How Long Do We Keep Your Information?
  6. How Do We Keep Your Information Safe?
  7. Do We Collect Information From Minors?
  8. Marketing
  9. What Are Your Data Protection Rights?
  10. Specific Rights
  11. Your Privacy Choices (California)
  12. Controls for Do-Not-Track Features
  13. Cookies
  14. How Do We Use Cookies?
  15. What Types of Cookies Do We Use?
  16. How to Manage Cookies
  17. Privacy Policies of Other Websites
  18. Do We Make Updates to This Notice?
  19. Governing Law
  20. How Can You Contact Us About This Notice?

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Sensitive Information. We do process sensitive information in connection with third parties such as your financial account balances, last 4 digits of your financial accounts. We may also infer sensitive information such as your income, employment, and loan information regarding balances, payments, interest rates, etc.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, location, information about how and when you use our Services, statistical information, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Our Services are not designed to appeal or cater to those under the age of 18 and you are required to be 18 years of age or older in order to use the Services or to provide information to us.

2. How Do We Collect Your Data?

In Short: We collect data that you provide to us.

You directly provide us with most of the data we collect. We collect data and process data when you:

3. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

5. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

Code Pebble, Inc will keep your data until you delete your account. We store your data for up to 180 days after you delete your account for backup and disaster recovery purposes. These backups are automatically deleted after one year.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your financial data is stored by Plaid, Stripe, MX, and Finicity. Please review their privacy policies for more details on how they store your financial data.

6. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

Your financial data is stored with Plaid, Stripe, MX, and Finicity and the remainder of your collected data is stored with Amazon Web Services. We take the following security precautions by:

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@roo.money.

8. Marketing

We will not sell or give others your information for the purpose of direct or indirect mass email marketing.

9. What Are Your Data Protection Rights?

In Short: You may review, change, or terminate your account at any time, depending on your location.

Based on the applicable laws of your state or country, you may have the following rights. To enact your rights, please use the request form below or email us at support@roo.money.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "How Can You Contact Us About This Notice?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at support@roo.money.

10. Specific Rights

California Rights

In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Personal information categories listed in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristics under California or federal lawGender and date of birthYES
D. Commercial informationTransaction information, purchase history, financial details, and payment informationNO
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsNO
G. Geolocation dataDevice locationNO
H. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNO
I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNO
J. Education InformationStudent records and directory informationNO
K. Inferences drawn from other personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsNO
L. Sensitive Personal InformationNO

We will use and retain the collected personal information as needed to provide the Services or for:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

Code Pebble, Inc has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Code Pebble, Inc will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

To exercise these rights, you can contact us or by referring to the contact details at the bottom of this Privacy Notice. If you have a complaint about how we handle your data, we would like to hear from you.

To prevent us from storing your data, or to review your stored data, please include your full name, address, username and email address for your account, and statement that you do not want us to store your information or that you want to review your information that we have stored. You may also specify what information you do not want us to store or what information you want to review. Please allow up to forty-five (45) days to process your request from the date of receipt.

Colorado Rights

In Short: If you are a resident of Colorado, you are granted specific rights regarding access to and use of your personal information.

Under the Colorado Privacy Act (CPA), Colorado residents have the following rights:

To exercise these rights, you can contact us or by referring to the contact details at the bottom of this Privacy Notice. If you have a complaint about how we handle your data, we would like to hear from you.

Connecticut Rights

In Short: If you are a resident of Connecticut, you are granted specific rights regarding access to and use of your personal information.

Under the Connecticut Personal Data Privacy and Online Monitoring Act (CTDPA), Connecticut residents have the following rights:

To exercise these rights, you may contact us by email at support@roo.money or by referring to the contact details at the bottom of this Privacy Notice.

Nevada Rights

In Short: If you are a resident of Nevada, you may be granted specific rights regarding the use of your personal information.

Nevada Privacy of Information Collected on the Internet from Consumers Act (NPICICA) allows Nevada residents the option to opt-out of the sale of certain "covered information" that is collected by websites and online services. Code Pebble, Inc does not sell covered information, as defined by the NPICICA.

However, if you would like to be notified if we decide in the future to sell personal information covered by NPICICA, please send us an email to support@roo.money and provide your full name, your Roo Money username, and email address. You are responsible for updating your email address for this purpose and we are not obligated to cross-reference other email addresses you have provided for other purposes. We will contact you only at the email address provided under this section if our plans change.

Virginia Rights

In Short: If you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Code Pebble, Inc and our Services. To find out more, please visit the following links:

Your rights with respect to your personal data:

Code Pebble, Inc has not sold any personal data to third parties for business or commercial purposes. Code Pebble, Inc will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at support@roo.money or by referring to the contact details at the bottom of this Privacy Notice.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Canada Rights

In Short: If you are a resident of Canada, you are granted specific rights regarding access to and use of your personal information.

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), Canadian residents have the following rights:

Your information is stored and processed within the United States.

Wherever possible, we seek a person's consent before we collect their personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied, and can be provided directly by the individual or by an authorized representative.

During our investigations, it may not always be possible to obtain a person's consent to collect, use, or disclose their personal information. PIPEDA allows for the disclosure of personal information during the course of an investigation if it is necessary to carry out that investigation.

We will not use your personal information without your consent unless it is either:

Any questions, comments, concerns or complaints you may have about the administration of this Privacy Notice may be directed to our Chief Privacy Officer, Kevin Ashton, by emailing support@roo.money or by referring to the contact details at the bottom of this Privacy Notice.

Upon receiving your request, we will respond without undue delay, but in all cases, within thirty (30) days of receipt. The response period may be extended once by thirty (30) additional days when reasonably necessary. We will inform you of any such extension within the initial 30-day response period, together with the reason for the extension.

Verification Process

We may request that you provide additional information reasonably necessary to verify you and your request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in most cases, within forty-five (45) days of receipt, unless required earlier by law. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to Appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@roo.money. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

Your Privacy Choices

Code Pebble, Inc does not sell or share your personal information, and we do not use it for cross-context behavioral advertising. If you are a California resident (or a resident of another state with similar laws), you can still submit a request to exercise the rights described above.

To exercise any of these rights, you can either email support@roo.money directly or use the request form below. We will verify your request and respond within 45 days as required by law. You may also designate an authorized agent to submit a request on your behalf.

Submit a privacy request

Fill out the form below and we'll open your email client with the request pre-formatted. Send the email to complete your request.

Which right would you like to exercise?

Your email client will open with the request pre-filled and addressed to support@roo.money.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. Cookies

Cookies are small text files stored on your computer that store and sometimes track information about your use of our Services. We may automatically collect non-personally identifiable information and data through the use of cookies. We use some cookies that last until you end the use of the browser and some cookies that remain on your hard drive for an extended period of time. You may also get cookies from our advertisers or other third parties with links in the Services; we do not directly control these cookies.

For further information on cookies, please visit www.allaboutcookies.org.

13. How Do We Use Cookies?

In order to make your interaction with the Services simple and productive we send cookies to your computer or mobile device, including for:

There are several different types of cookies. The Services use the following types of cookies:

15. How to Manage Cookies

You can change settings in your internet browser so that it does not accept cookies. Please see www.allaboutcookies.org for instructions on how to remove cookies from your specific internet browser. However, if you remove cookies, some of our features may not function as intended.

16. Privacy Policies of Other Websites

The Services contain links to other websites that are operated by third parties. This Privacy Policy applies only to our website and app, so if you click a link to another website, please be sure to read their privacy policy. We do not control such other third-party websites and are not responsible for their content, their privacy policies, or their use of your personal information. Our inclusion of third-party links does not, by itself, imply any endorsement of the content on third-party websites or of their owners or operators, except as disclosed on our website or app. We provide a platform to encourage good business interactions but we cannot guarantee any outcome or satisfaction. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

Your use of third-party links is at your own risk. While we support the protection of our customer's privacy on the internet, we expressly disclaim any and all liability for the actions of third parties, including, but not limited to, actions related to the use and/or disclosure of personal information by third parties.

17. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We reserve the right to revise, amend, or update this Privacy Policy at any time and will upload the new version to this web page which will immediately be effective and replace all previous versions. It is your responsibility to review the Privacy Policy for any changes each time that you use the Services. Your use of the Services following us posting a revised, amended, or updated privacy policy on our website signifies that you agree to and accept the privacy policy as modified. The date of the most recent update can be found at the top of our Privacy Policy.

18. Governing Law

This Privacy Policy, your use of the Services, the privacy practices of Code Pebble, Inc, your rights and obligations, and all actions contemplated by, arising out of or related to this Privacy Policy shall be governed exclusively by the laws of the State of Utah, as if this Privacy Policy is a contract wholly entered into and wholly performed within the State of Utah.

19. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, the data we collect on you, or you would like to exercise your data protection rights (listed above), you may email us at support@roo.money.

When contacting us, please provide your full name and email address used to create your Roo Money account. We will respond to you within forty-five (45) days.

If you would like to report a complaint or if you feel that we have not addressed your concerns, you may contact the Utah Consumer Protection Division at https://consumerprotection.utah.gov/.

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