Revised: January 24, 2019
1. Managing Your Information Preferences
2. Information We Collect
We may collect information that personally identifies you, such as your name, address, phone number, mobile phone number, e-mail, bank account information (such as balance information and transaction information), and other personally identifiable information that you choose to provide us with or that you choose to include in your account (“Personal Information”). You may be asked to provide us with Personal Information when you register with the Site or use any of our Services, and at other times.
Usage Data and Site Activity
We automatically collect information regarding the actions you take on the Site (“Usage Data”). We monitor and analyze trends, usage and activities in connection with the services, For example, each time you use the Site we automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the type of device used to access the Site, the pages you view, and the time and duration of your visits to the Site. We also collect information in connection with each Funds transaction you engage in via the Services, including transaction time, amount of Funds transferred in or out of the pooled account, and other transaction details. We use this information to help us understand how people use the Site and Services, and to enhance the services we offer. In some instances, we may also share your Usage Data aggregated with the Usage Data of others, but would not identify you individually.
Cookies and Anonymous Identifiers
We use Google Analytics on the Site and Services to collect Usage Data, to analyze how users use the Site and Services, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
3. How We Use Information and When We May Share and Disclose Information Generally
4. Service Providers
From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
5. Other Transfers
6. Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
7. Be Careful When You Share Information with Others
Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
10. Children’s Privacy
The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records. Please note that most of the user content that appears on our Site or Services is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.
11. Processing in the United States
Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.