Last Updated: April 25, 2019
TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user or visitor (each, an “Individual”) and the requirements of applicable law. Some of the ways that we may collect Personal Information include:
- You may provide Personal Information directly to us through interacting with the Services; and
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
TYPES OF PERSONAL INFORMATION WE COLLECT
- Information You Provide Directly to Us:
- Communications with Us. We may collect Personal Information from you such as name, phone number, email address, and date of birth when you create an Account with the Services, choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us.
- Know Your Customer (“KYC”) Verification Procedure. We may also collect additional Personal Information from you, such as your government-issued ID, mailing address and social security number, in order to complete our internal KYC verification procedure.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- Information from Other Sources. We may receive information about you from other sources. For example, if you access our Services through a Third Party application, such as through an App Provider, we may collect information about you from that Third Party application that you have made public via your privacy settings or other information that your privacy settings may permit us to collect. Information we collect through App Providers may include user name, location and email. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
HOW WE USE YOUR INFORMATION
We Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Services or Information Requested. We may use Personal Information about you to:
- Generally manage your Account;
- Respond to your questions, comments, and other requests, including requests for technical support;
- Provide access to certain functionalities, and features of the Services.
- Administrative Purposes. We may use Personal Information about you to:
- Measure interest in our Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity, including through our KYC procedure;
- Communicate with you about your Accounts, activities on the Services, and, changes to any Company’s policy;
- Verify your Account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
- Marketing Company Products and Services. We may use Personal Information about you to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and Services that may be of interest to you;
- To provide Services to you;
- Other purposes you consent to or are disclosed when you provide Personal Information.
You may contact us at any time to opt out of the use of your Personal Information for marketing
purposes, as further described below.
- Research and Development. We may use Personal Information about you to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.
- Email Communications. You may receive periodic emails or newsletters from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to you by following the instructions in Section 5 below.
- Services via Mobile Devices. We may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device.
- Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information with Third Parties for our or their purposes in an anonymized or aggregated form designed to prevent anyone from identifying you.
- Referring Friends or Colleagues to Use the Services. Our Services offer tools or functionalities that allow you to refer friends or colleagues to use the Services by providing their phone numbers. Phone numbers that you may provide for a friend or colleague when using such tools or functionalities will be used to send your referral to your friend or colleague, but will not be used by us or any other Third Party for any other purpose.
- Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
- Cookies. Cookies are small text files placed in visitors’ devices to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, some features of the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on the Site. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Google Analytics, Google Analytics Demographics and Interest Reporting and Amplitude to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. For more information about Amplitude, please visit https://amplitude.com/privacy. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or Third Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site or on third party websites. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
THIRD PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SOFTWARE DEVELOPMENT KITS
Our Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about Third Party websites or social media platforms. We encourage you to read the privacy policies of each and every website and application with which you interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. Our Services may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using Services. We are unable to control the use of your information on social media platforms, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We may use Third Party APIs as part of the functionality of our Services. Third Party APIs may allow Third Parties, including advertisers, to collect your Personal Information to provide content that is more relevant to you. You may opt out of tracking by following the instructions below.
ONWARD TRANSFER – HOW WE MAY DISCLOSE YOUR INFORMATION
4.1 INFORMATION WE SHARE
- We Use Vendors and Service Providers. We may share any information we receive with our vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) IT and related services; (ii) information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Services. These vendors and service providers have access to your Personal Information only for purposes of performing services on our behalf.
- Business Partners. We may share Personal Information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Company. We require our affiliates and business partners not to use Personal Information for any other purpose other than the purpose for which we provided the information to them.
- Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, we may allow Third Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit Third Party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with Third Party advertising partners, you may opt out by following the instructions below.
- Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) enforce our policies or contracts; (v) collect amounts owed to us; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
4.2 INTERNATIONAL DATA TRANSFERS
You agree that all Personal Information collected via the Services or by us may be transferred, Processed, and stored anywhere in the world, including but not limited to the United States. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you explicitly consent to the storage of your Personal Information in these locations.
YOUR CHOICES: RIGHT TO OBJECT TO PROCESSING
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to our Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Services and/or information from the advertisements on Third-Party websites for other legal purposes as described above.
5.2 EMAIL COMMUNICATIONS
We may occasionally send you push notifications through our Services (including mobile applications) with notices or alerts that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.
5.4 “DO NOT TRACK”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.5 COOKIES AND INTEREST-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our Third Party advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, http://youradchoices.ca/choices/ and www.aboutads.info/choices/.
RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
You may inquire as to whether we are Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may contact us at firstname.lastname@example.org to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by us. Please include your full name, email address or phone number associated with your account, and a detailed description of your data request, or follow the information provided on the Services. Such requests will be processed in line with local laws.
Although we make good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
SECURITY OF YOUR INFORMATION
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by making a notice available to you through the Services or sending an e-mail to you.
Our Services are not directed to children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected Personal Information of a child under 13 (or under 16 in certain jurisdictions, such as EU member countries) we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.
REDRESS/COMPLIANCE AND ACCOUNTABILITY
OTHER RIGHTS AND IMPORTANT INFORMATION
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and your choices as required by law.
12.2 CALIFORNIA PRIVACY RIGHTS
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Company or to which Company discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Company or Company’s Agents.