Effective as of February 11, 2022
Section 1. Children Under the Age of 18
Our Services are intended to be accessed and used only by adults and are not directed to minors. If you are below the age of 18, you may not access or otherwise use our Services.
We do not knowingly collect personally identifiable information by anyone under the age of 13 and you should not provide us with any information regarding any individual under the age of 16. If we learn that we have inadvertently gathered information from anyone under the age of 13, we will take reasonable measures to promptly remove that information from our records.
Section 2. What Information We Collect and How We Collect It
We receive and collect several types of information about you, such as the information described below.
Information you provide to us: From time to time, you may provide us with certain information, including Your Information, such as your name, email address and certain financial account information, such as records of personal and investment assets. Instances where you may provide this information include when you sign up for an account on our Services, fill out forms or fields on or through our Services, or sign up for any promotions or to receive newsletters or other materials from or about us.
Information we receive from third parties: We may obtain information about you from sources other than you, such as from our payment processing Third-Party Service Provider (currently Stripe, Inc.) when you make payments for a subscription to our Services or from our Third-Party Service Providers who provide us with API connections with or to those of Your financial accounts that You have directed us to. Any content or information submitted by you to third parties will be used and disclosed by such third parties in accordance with their respective privacy policies. You should review the privacy policies and practices of such third parties prior to disclosing information to them.
We may also collect information on third party platforms such as HubSpot, Google AdWords, Google Analytics, etc. Additionally, some information we collect is publicly available. For example, we may collect information you submit to a blog, a chat room, or a social network like Facebook, Twitter or Google+.
Information we collect automatically: As you navigate through and interact with our Services, we and third parties acting on our behalf may use automatic data collection technologies to collect certain information. See Section 3 “Cookies and Other Automatic Tracking Technologies” for more information.
Our Collection Practices with Respect to Certain Specific Information:
Device Information. When you access or use our Services through your computer, mobile phone or other device, we may collect information
regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events, such as crashes, and associate that temporarily with your account (if any) to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
Location Information. If you submit your zip code or other geographic information to us, you may provide us with your location information.
Furthermore, if you enable the collection of location information on your device, then we may collect information about your actual location, such as your mobile device’s GPS coordinates. We may also use other technologies to determine your location (such as through the location of nearby Wi-Fi access points or cell towers) or obtain your location information from third parties.
Communications with Us. We may collect information about your communications with us, including relating to support questions, your account, and other inquiries.
Third-party content providers may collect information: Some content or applications, including advertisements, on our Services may be served by third parties, including our Third-Party Providers, ad networks and servers, content providers and other application providers. These third parties may collect information about you when you use our Services using cookies alone or in conjunction with web beacons or other tracking technologies. We do not control these third parties’ tracking technologies 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. Please note that the information collected by these third parties may be associated with Your Information and that these third parties may collect information, including Your Information, about your online activities over time and across different websites and other online services.
Section 3. Cookies and Other Automatic Tracking Technologies
Description of the Technologies Utilized on our Services: We may use various technologies to collect and store information when you our Services, including sending cookies, embedded scripts, web beacons, pixel tags or other anonymous identifiers to your device, or otherwise tracking your activities on our Services over time. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (a practice known as behavioral tracking). If you sign up for our text messaging program, cookies may be used to personalize your experience (e.g. send you personalized text messages such as shopping cart reminders).
• “Cookies” are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted. A “web beacon” is a type of technology that lets us know if you visited a certain page or whether you opened an email. A “pixel tag” is a type of technology placed within a website or e-mail for the purpose of tracking activity, which is often used in combination with cookies. Other “anonymous identifiers” include random strings of characters used for the same purposes as cookies, such as with mobile devices where cookie technology may not be available. These technologies help us know that you are logged on to or using our Services, provide you with features based on your preferences, help us understand when and how you are interacting with our Services and compile other information regarding your use of our Services.
• With respect to Cookies, we use first-party and third-party cookies to: make our Services function properly; improve our Services; make access to our Services easier; recognize you when you return to our Services; track your interaction with our Services; enhance your experience with our Services; remember information you have already provided; collect information about your activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Services. The categories of cookies used or that may be used on our Services include:
- Strictly Necessary Cookies, which are needed for the Platform to operate as you reasonably expect.
- Functional or Preference Cookies, which are used to remember your name or choices.
- Performance or Analytic Cookies, which collect passive information about your use of the Platform.
- Advertising or Targeting Cookies, which are used to make advertising messages more relevant and personalized to you based on your inferred interests.
• We may use Third-Party Service Providers to monitor and analyze the use of our Services. For example, we may use Google Analytics as one of our analytics service providers that tracks and reports Platform (including website) traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page. To learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.
The information collected through these technologies, standing alone, cannot be used to determine your identity. Such information may, however, be combined in a way that makes it become personally identifiable information (i.e., information that can identify you). For example, we may tie this information to personal information about you that we collect from other sources or that you provide to us. If this happens, we will treat the combined information as personally identifiable information.
Choices as to Cookies and Other Automatic Tracking Technologies: It may be possible to disable some (but not all) Cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of all or a portion of our Services. The method for disabling Cookies or other automatic collection technologies may vary by device and browser but can usually be found in preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. See Section 7 “Choices About How We Use and Disclose Your Information” for more information.
Do Not Track Requests: Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Services do not currently process or respond to “DNT” signals.
Section 4. How We Use Your Information
We may use the information we collect for various lawful business purposes. Among others, these purposes may include using this information, including Your Information, to:
- Present our Services and related content to you. For example, to provide our Services, including its features and services to account owners, and to customize Services features and recommendations for accounts users. We may also use Your Information to manage our relationship and contracts with account owners, including billing, compliance with contractual obligations, and related administration.
- Contact you and provide you with information. For example, if you complete the “contact us” form on our website, we might contact you via e-mail or other communications to provide you with information regarding our Services, promotions, offers, personalized information and other information from us or our Third-Party Providers or business partners or to respond to comments, inquiries, and other information submitted by you.
- Provide you with customer support. For example, if you request us to contact you in connection with any customer support matters, we may collect certain information from you in order to assist you as requested.
- Analyze, improve and manage our Services, products, service offerings and operations. For example, we might obtain feedback regarding our Services, products, and service offerings, understand and anticipate your needs and preferences, better understand your use of our Services or products or service offerings, customize and tailor Platform content and advertising, improve our marketing and promotional efforts, engage in statistical analysis and provide feedback or information to our business partners, vendors, advertisers and other third parties.
- Display advertisements to our advertisers’ target audiences. For example, we may use your device information for direct advertising and retargeting ads, such as providing you with information or advertising relating to our products and services based on your precise geolocation, when in line with the preferences you have shared with us. Additionally, even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Note also that our third-party content providers may use information they collect via our Services to provide you with interest-based (aka behavioral) advertising or other targeted content.
- Comply with a request from you in connection with the exercise of your rights. For example, where you have asked us not to contact you for marketing purposes, we or our service providers will keep a record of this on our suppression lists to be able to comply with your request.
- Other Purposes. We may also use your information in other ways. To the extent required by applicable law, we will provide notice at the time of collection and obtain your consent.
Section 5. How We Disclose Your Information
General Disclosure of Your Information: We may disclose the information we collect, including Your Information:
- to our third-party vendors or suppliers (including our payment processing Third-Party Provider and our hosting provider) so that they may provide support for our internal and business operations, including for the processing of your payments for a subscription to our Services, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials and our Services’ maintenance and security. For example, we use (and thus disclose certain of Your Information to):
- Google Analytics so that they can help us understand how our customers use our website and Platform – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- HubStop in order to effectuate our marketing campaigns — you can read more about how HubSpot uses Your Information here: https://legal.hubspot.com/privacy-policy.
- to our affiliates and their respective employees, agents and representatives involved in delivering our Services, products and other services to you;
- to fulfill the purpose for which you provide it;
- to any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
- to third parties when you engage in certain activities through our Services, such as those financial or other institutions with which you maintain accounts to which you have authorized us to access for purposes of providing our Services to you;
- as required by applicable law or ordered by a court, regulatory or administrative agency;
- as we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, restriction or regulation, or are otherwise interfering with another’s rights or property, including our rights or property;
- if requested by authorities in the event of any act instance of local, regional or national emergency;
- with your consent;
- to otherwise enforce or protect our rights; and
- in connection with a Business Transfer (see “Other Disclosures by Us” below).
Please note that the list above is not exhaustive and that we may, to the extent permitted by applicable law, disclose the information we collect to third parties at any time, for any lawful purpose, without notice or compensation to you.
Other Disclosures by Us:
Aggregation and De-Personalization. We may use and disclose any de-identified information for any lawful purpose, including for any
commercial purpose. De-identified Information means information that does not identify you, including any identifiable information de-identified by either by combining it with information about others, for example, by aggregating your information with information about other persons, or by removing characteristics, such as your name, that make the information personally identifiable to you.
Business Transfers. We may disclose, lease, sell, assign or transfer the information we collect (including Your Information) to third parties in
Circumvention of Security Measures: We use a certain technical, administrative and organizational security measures to keep Your Information safe. However, despite our efforts, please be aware that methods of transmission and electronic storage are not completely secure. We cannot guarantee the privacy or security of Your Information, as third parties may unlawfully intercept or access transmissions or electronic storage. Further, to the extent permitted by law, we are not responsible for circumvention of any privacy settings or security measures of our Services. Therefore, you use our Services at your own risk, you should not expect that Your Information will always remain private, and we do not guarantee the performance or adequacy of our security measures. In the event that an unauthorized third party compromises our security measures, to the extent permitted by law, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate Your Information.
Section 6. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding our collection, use and disclosure of the information that we collect. Below are some mechanisms that provide you with control over such collection, use or disclosure:
- Cookies and Other Tracking Technologies. It may be possible to disable some (but not all) Cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of our Services. The method for disabling Cookies or other automatic collection technologies may vary by device and browser, but can usually be found in preferences or security settings.
- You can exercise your preferences in relation to cookies served on our Services by taking the steps outlined below.
- First-Party Cookies. You can use the browser with which you are viewing our Services to enable, disable or delete Cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable Cookies, you may not be able to access secure areas of our Services. Also, if you disable certain Cookies, other parts of our Services may not work properly. You can find more information about how to change your browser cookie settings at allaboutcookies.org.
- Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to aboutads.info/choices .
We do not control third-parties’ collection or use of your information to serve interest-based advertising. However, these third-parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting Cookie preferences. More information may be found for the following browsers here:
- E-mail Offers. If you do not wish to receive e-mail offers or other information or communications from us, you can opt-out of receiving such e-mail offers or other information or communications from us (other than e-mails or other information or communications related to the status of your job application with us (if any), correction of user data, change of password and other similar communications essential to your transactions on or through our Services) by using the unsubscribe process at the bottom of the e-mail. Please be aware that it can take up to 10 business days to remove you from our marketing e-mail lists. If you opt-out from receiving our marketing e-mails, you may continue to receive certain status e-mails relating to your transactions on or through our Services.
- Managing Your Information. If you create an account with us, then you can review and update Your Information by logging into that portion of our Services, visiting your account profile page and making changes.
- Online Behavioral Advertising. As described above, we may use Your Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. Certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI member companies from collecting preference data about you by visiting http://www.networkadvertising.org/choices/ and following the NAI’s directions. Note that if you opt-out through the NAI, you will still receive advertising. In addition, if you opt-out through the NAI and later delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice. Additional options for opting out of target advertising include, without limitation:
- FACEBOOK – https://www.facebook.com/settings/?tab=ads
- TWITTER – https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
- GOOGLE – https://www.google.com/settings/ads/anonymous
- BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- Digital Advertising Alliance – http://optout.aboutads.info/
Section 7. Information that You Disclose to Third Parties
Our Services, including any of our newsletters or e-mail messages, may contain links or access to websites or platforms operated by third parties that are beyond our control. Links or access to third parties from our Services is not an endorsement by us of such third parties, or their respective websites, applications, products, platforms or practices. We are not responsible for the privacy policies, terms and conditions, practices or the content of such third parties. All information that you disclose to such third parties will be subject to the privacy policies and practices of such third parties. You should review the privacy policies and practices of such third parties prior to disclosing information to them. If you have any questions about how these third parties use your information, you should review their policies and contact them directly.
Section 8. Operation of our Services in the United States
Section 10. Contacting Us
If you have any questions, suggestions or complaints regarding our use or disclosure of the information we collect from you or wish to contact us to make a request regarding such information (including Your Information), please contact us at firstname.lastname@example.org
In contacting us, you must include the reference to our “Privacy Request” on the subject line and in the body of the message and include the email address or mailing address, as applicable, for us to send our response. We reserve the right not to respond to inquiries submitted other than to the address specified above.