- Mobile Device
Data. We automatically collect device
information (such as your mobile device ID, model and
manufacturer), operating system, version information and
system configuration information, device and application
identification numbers, browser type and version, hardware
model, Internet service provider and/or mobile carrier, and
Internet Protocol (IP) address (or proxy server). If you are
using our App, we may also collect information about the
phone network associated with your mobile device, your
mobile device’s operating system or platform, the type of
mobile device you use, your mobile device’s unique device ID
and information about the features of our App you
accessed.
- Push
Notifications. We may request to send you push
notifications regarding your account or certain features of
the App. If you wish to opt-out from receiving these types
of communications, you may turn them off in your device’s
settings.
- Facebook
Permissions. We by default access your Facebook basic account
information, including your name, email, gender, birthday,
current city, and profile picture URL, as well as other
information that you choose to make public. We may also
request access to other permissions related to your account,
such as friends, checkins, and likes, and you may choose to
grant or deny us access to each individual permission. For
more information regarding Facebook permissions, refer to
the Facebook Permissions
Reference page.
This information is primarily
needed to maintain the security and operation of our App, for
troubleshooting and for our internal analytics and reporting
purposes.
2. HOW DO WE USE YOUR
INFORMATION?
In Short:
We process your information
for purposes based on legitimate business interests, the
fulfillment of our contract with you, compliance with
our legal obligations, and/or your consent.
We use personal information
collected via our Services for a variety of business
purposes described below. We process your personal information
for these purposes in reliance on our legitimate business
interests, in order to enter into or perform a contract with
you, with your consent, and/or for compliance with our legal
obligations. We indicate the specific processing grounds we rely
on next to each purpose listed below.
We use the information we
collect or receive:
- To facilitate
account creation and logon process. If you
choose to link your account with us to a third-party account
(such as your Google or Facebook account), we use the
information you allowed us to collect from those third
parties to facilitate account creation and logon process for
the performance of the contract.
- To post
testimonials. We post testimonials on
our Services that may contain personal
information. Prior to posting a testimonial, we will obtain
your consent to use your name and the content of the
testimonial. If you wish to update, or delete your
testimonial, please contact us
at [email protected] and be sure to
include
your name, testimonial location, and contact
information.
- Request
feedback. We may use your information to
request feedback and to contact you about your use of
our Services.
- To enable
user-to-user communications. We may use
your information in order to enable user-to-user
communications with each user’s consent.
- To manage user
accounts. We may use your information for
the purposes of managing our account and keeping it in
working order.
- To send
administrative information to you. We may
use your personal information to send you product, service
and new feature information and/or information about changes
to our terms, conditions, and policies.
- To protect our
Services. We may use your information as
part of our efforts to keep our Services safe and
secure (for example, for fraud monitoring and
prevention).
- To enforce our
terms, conditions and policies for business purposes, to
comply with legal and regulatory requirements or in
connection with our contract.
- To respond to legal
requests and prevent harm. If we receive a
subpoena or other legal request, we may need to inspect the
data we hold to determine how to respond.
- Fulfill and manage
your orders. We may use your information
to fulfill and manage your orders, payments, returns, and
exchanges made through the Services.
- Administer prize
draws and competitions. We may use your
information to administer prize draws and competitions when
you elect to participate in our competitions.
- To deliver and
facilitate delivery of services to the
user. We may use your information to
provide you with the requested service.
- To respond to user
inquiries/offer support to users. We may
use your information to respond to your inquiries and solve
any potential issues you might have with the use of our
Services.
- To send you
marketing and promotional
communications. We and/or our third-party
marketing partners may use the personal information you send
to us for our marketing purposes, if this is in accordance
with your marketing preferences. For example, when
expressing an interest in obtaining information about us or
our Services, subscribing to marketing or otherwise
contacting us, we will collect personal information from
you. You can opt-out of our marketing emails at any time
(see the “WHAT ARE YOUR PRIVACY
RIGHTS?” below).
- Deliver targeted
advertising to you. We may use your
information to develop and display personalized content and
advertising (and work with third parties who do so) tailored
to your interests and/or location and to measure its
effectiveness.
3. WILL
YOUR
INFORMATION BE SHARED WITH
ANYONE?
In
Short: We only share
information with your consent, to comply with laws, to
provide you with services, to protect your rights, or to
fulfill business obligations.
We may process or share
your data that we hold based on the following legal
basis:
- Consent: We
may process your data if you have given us specific
consent to use your personal information for a specific
purpose.
- Legitimate
Interests: We may process your data
when it is reasonably necessary to achieve our
legitimate business interests.
- Performance of a
Contract: Where we have entered into a
contract with you, we may process your personal
information to fulfill the terms of our contract.
- Legal
Obligations: We may disclose your
information where we are legally required to do so in
order to comply with applicable law, governmental
requests, a judicial proceeding, court order, or legal
process, such as in response to a court order or a
subpoena (including in response to public authorities to
meet national security or law enforcement
requirements).
- Vital
Interests: We may disclose your
information where we believe it is necessary to
investigate, prevent, or take action regarding potential
violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person
and illegal activities, or as evidence in litigation in
which we are involved.
More specifically, we may
need to process your data or share your personal information
in the following situations:
- Business
Transfers. We may share or transfer
your information in connection with, or during
negotiations of, any merger, sale of company assets,
financing, or acquisition of all or a portion of our
business to another company.
- Google Maps
Platform APIs. We may share your
information with certain Google Maps Platform APIs
(e.g., Google Maps API, Place API). To find out more about
Google’s Privacy Policy, please refer to this link.
- Vendors,
Consultants and Other Third-Party Service
Providers. We may share your data with
third-party vendors, service providers, contractors or
agents who perform services for us or on our behalf and
require access to such information to do that work.
Examples include: payment processing, data analysis,
email delivery, hosting services, customer service and
marketing efforts. We may allow selected third parties
to use tracking technology on the Services, which
will enable them to collect data on our behalf about how
you interact with our Services over time. This
information may be used to, among other things, analyze
and track data, determine the popularity of certain
content, pages or features, and better understand online
activity. Unless described in this notice, we do not
share, sell, rent or trade any of your information with
third parties for their promotional purposes.
- Third-Party
Advertisers. We may use third-party
advertising companies to serve ads when you visit or use
the Services. These companies may use information
about your visits to our Website(s) and other websites
that are contained in web cookies and other tracking
technologies in order to provide advertisements about
goods and services of interest to you.
4.
WHO
WILL YOUR INFORMATION BE SHARED
WITH?
In
Short: We
only share information with the
following categories of third
parties.
We only
share and disclose your information with the
following categories of third
parties. If we have processed your data
based on your consent and you wish to revoke
your consent, please contact us using the
contact details provided in the section
below titled “HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?“.
- Ad
Networks
- Data
Analytics Services
- User
Account Registration &
Authentication Services
- Performance
Monitoring Tools
- Data
Storage Service Providers
5.
DO
WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In
Short: We
may use cookies and other tracking
technologies to collect and store your
information.
We may use
cookies and similar tracking technologies
(like web beacons and pixels) to access or
store information. Specific information
about how we use such technologies and how
you can refuse certain cookies is set out in
our Cookie Notice.
6.
WHAT IS OUR STANCE ON
THIRD-PARTY
WEBSITES?
In
Short: We
are not responsible for the safety of
any information that you share with
third-party providers who advertise, but
are not affiliated with, our
Website.
The Services may
contain advertisements from third parties
that are not affiliated with us and which
may link to other websites, online services
or mobile applications. We cannot guarantee
the safety and privacy of data you provide
to any third parties. Any data collected by
third parties is not covered by this privacy
notice. We are not responsible for the
content or privacy and security practices
and policies of any third parties, including
other websites, services or applications
that may be linked to or from
the Services. You should review the
policies of such third parties and contact
them directly to respond to your
questions.
7.
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 twelve
(12) months past the termination of the
user’s account.
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.
8.
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.
We have
implemented appropriate 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.
9.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short: You
may review, change, or terminate your
account at any time.
If you have
questions or comments about your privacy
rights, you may email us
at [email protected].
Account
Information
If you
would at any time like to review or
change the information in your account
or terminate your account, you
can:
- Contact
us using the contact information
provided.
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
Terms of Use and/or comply with
applicable legal requirements.
Cookies
and similar
technologies: Most
Web browsers are set to accept cookies by
default. If you prefer, you can usually
choose to set your browser to remove cookies
and to reject cookies. If you choose to
remove cookies or reject cookies, this could
affect certain features or services of
our Services. To opt-out of
interest-based advertising by advertisers on
our Services visit http://www.aboutads.info/choices/.
Opting
out of email
marketing: You can
unsubscribe from our marketing email list at
any time by clicking on the unsubscribe link
in the emails that we send or by contacting
us using the details provided below. You
will then be removed from the marketing
email list — however, we may still
communicate with you, for example to send
you service-related emails that are
necessary for the administration and use of
your account, to respond to service
requests, or for other non-marketing
purposes. To otherwise opt-out, you
may:
- Contact
us using the contact information
provided.
10.
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.
11.
DO
CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY
RIGHTS?
In
Short: Yes,
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 a
Service, 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:
| Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
Contact
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
name
|
YES
|
|
B.
Personal information
categories listed in the
California Customer Records
statute
|
Name,
contact information,
education, employment,
employment history and
financial information
|
YES
|
|
C.
Protected classification
characteristics under
California or federal
law
|
Gender
and date of birth
|
NO
|
|
D.
Commercial
information
|
Transaction
information, purchase
history, financial details
and payment
information
|
NO
|
|
E.
Biometric information
|
Fingerprints
and voiceprints
|
NO
|
|
F.
Internet or other similar
network activity
|
Browsing
history, search history,
online behavior, interest
data, and interactions with
our and other websites,
applications, systems and
advertisements
|
YES
|
|
G.
Geolocation data
|
Device
location
|
YES
|
|
H.
Audio, electronic, visual,
thermal, olfactory, or
similar information
|
Images
and audio, video or call
recordings created in
connection with our business
activities
|
NO
|
|
I.
Professional or
employment-related
information
|
Business
contact details in order to
provide you our services at
a business level, job title
as well as work history and
professional qualifications
if you apply for a job with
us
|
NO
|
|
J.
Education Information
|
Student
records and directory
information
|
NO
|
|
K.
Inferences drawn from other
personal information
|
Inferences
drawn from any of the
collected personal
information listed above to
create a profile or summary
about, for example, an
individual’s preferences and
characteristics
|
NO
|
We may also
collect other personal information outside
of these categories instances where you
interact with us in-person, online, or by
phone or mail in the context of:
- Receiving
help through our customer support
channels;
- Participation
in customer surveys or contests;
and
- Facilitation
in the delivery of our Services and to
respond to your inquiries.
How
do we use and share your personal
information?
FUNDSFORNGOS
LLC collects and shares your personal
information through:
- Targeting
cookies/Marketing cookies
- Social
media cookies
- Beacons/Pixels/Tags
More
information about our data
collection and sharing practices can
be found in this privacy
notice.
You
can opt out from the selling of your
personal information by disabling
cookies in Cookie Preference
Settings and clicking on the Do Not
Sell My Personal Information link on
our homepage.
You
may contact us by email
at [email protected], 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.
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 data.
FUNDSFORNGOS
LLC
has disclosed the following
categories of personal
information to third parties for
a business or commercial purpose
in the preceding twelve (12)
months:
- Category
B. Personal information, as
defined in the California
Customer Records law, such
as your name, contact
information, education,
employment, employment
history and financial
information.
FUNDSFORNGOS
LLC has
sold the
following
categories of
personal
information to
third parties in
the preceding
twelve (12)
months:
- Category
B. Personal
information,
as defined
in the
California
Customer
Records law,
such as your
name,
contact
information,
education,
employment,
employment
history and
financial
information.
The
categories of
third parties to
whom we sold
personal
information
are:
- Ad
Networks
- Data
Analytics
Services
- User
Account
Registration
&
Authentication
Services
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:
- whether
we collect
and use your
personal
information;
- the
categories
of personal
information
that we
collect;
- the
purposes for
which the
collected
personal
information
is
used;
- whether
we sell your
personal
information
to third
parties;
- the
categories
of personal
information
that we sold
or disclosed
for a
business
purpose;
- the
categories
of third
parties to
whom the
personal
information
was sold or
disclosed
for a
business
purpose;
and
- the
business or
commercial
purpose for
collecting
or selling
personal
information.
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.
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.
If, however, 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
- you
may object
to the
processing
of your
personal
data.
- you
may request
correction
of your
personal
data if it
is incorrect
or no longer
relevant, or
ask to
restrict the
processing
of the
data.
- you
can
designate an
authorized
agent to
make a
request
under the
CCPA on your
behalf. We
may deny a
request from
an
authorized
agent that
does not
submit proof
that they
have been
validly
authorized
to act on
your behalf
in
accordance
with the
CCPA.
To
exercise
these
rights, you
can contact
us by
email
at [email protected], or
by referring
to the
contact
details at
the bottom
of this
document. If
you have a
complaint
about how we
handle your
data, we
would like
to hear from
you.
12.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short: Yes,
we will
update
this
notice
as
necessary
to stay
compliant
with
relevant
laws.
We
may update
this privacy
notice from
time to
time. The
updated
version will
be indicated
by an
updated
“Revised”
date and the
updated
version will
be effective
as soon as
it is
accessible.
If we make
material
changes to
this privacy
notice, we
may notify
you either
by
prominently
posting a
notice of
such changes
or by
directly
sending you
a
notification.
We encourage
you to
review this
privacy
notice
frequently
to be
informed of
how we are
protecting
your
information.
13.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you have
questions or
comments
about this
notice, you
may email
us
at [email protected] or
by post
to:
FUNDSFORNGOS
LLC
140
Broadway
46th
Floor
New
York, NY 10005
United
States
14.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based
on the
applicable
laws of your
country, you
may have the
right to
request
access to
the personal
information
we collect
from you,
change that
information,
or delete it
in some
circumstances.
To request
to review,
update, or
delete your
personal
information,
please submit
a request
form by
clicking here.
