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How We Use Your Information
We use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Platform, to provide to you the services offered by the Platform; resolve service disputes; troubleshoot problems; measure consumer interest in our products and services; inform you about online and offline offers, products, services, events and updates; deliver information to you that, in some cases, is relevant to your interests, such as product news; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms of Service; provide you with system or administrative messages, and as otherwise described to you at the time of collection.
We may also use personal information about you to improve our marketing and promotional efforts, to analyze Platform usage, to improve our content and product offerings, and to customize the Platform’s content, layout, and services. These uses improve the Platform and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Platform.
Please see below under “How we Retain your Personal Information” for information on what we do to account information when you terminate your account with us.
What Information Do We Collect?
Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.
In general, you can browse the Platform without telling us who you are or revealing any personal information about yourself. Once you become a User or a Member, we require you to provide various contact and identity information and other personal information as indicated on the relevant forms on the Platform, and you are no longer anonymous to us. Where possible, on these forms we indicate which fields are required and which fields are optional. In addition, as you use the Platform, you can from time to time enter or send to us personal information.
You always have the option to not provide information by choosing not to become a User or by not using the particular feature of the Platform for which the information is being collected.
We also automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on our Platform or not), which URL you next go to (whether this URL is on our Platform or not), your computer browser information, your IP address and your location.
If you are anMembers of our Users’ Portfolios, we also get information about your interactions with their Portfolios, though we use this in anonymous, aggregated or form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services).
Some of this information is collected automatically using cookies and similar technologies when you use our Services and our Users’ Portfolios. We let our Users control what cookies and similar technologies are used through their Portfolios (except those we need to use to provide the Services properly, such as for performance or security related reasons).. Some of this information is similarly collected automatically through your browser or from your device.
If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.
Following your registration on the Platform, you can review and change your information in your account area. If you disclose personal information on the Platform and wish to have it removed, please contact us at the contact information posted on the Platform.
Our Disclosure of Your Information
We will not sell or rent your personally identifiable information to third parties without your explicit consent. The following describes some of the ways that your information may be disclosed in the normal scope of business to provide our services:
Aggregated Data. We aggregate data and use and disclose such information for a variety of purposes. However, in these situations, we do not disclose any information that could be used to identify you personally.
Members. We may share with our Users data regarding usage by Members of their Portfolios. For example, we may provide a User with information about what web page the Member/s visited before coming to their Portfolios and how their Members interacted with their Portfolios. This is so Users can analyze the usage of their Portfolios and improve their services.
Public Areas of the Platform. All of your activities in the public areas of the Platform will be identifiable to your User ID, and other people can see your published content.
Subsidiaries and Affiliates; Service Providers. We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Platform, and may disclose personal information to them in the course of our use of their services. For example, we may use the services of third-party hosting companies to host the operation of the Platform. This may involve the hosting of data, including personal information, on servers operated by those hosting companies.
Legal Requests; Emergencies; Jurisdictions. We cooperate with law enforcement inquiries and demands for information that are made under force of law. We are also cognizant of the need to address emergencies. Therefore, we may disclose User and End User personal information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, (c) as otherwise required under any applicable law, rule, or regulation, and (d) in good faith, to protect or defend our rights or property or those of other users or Members.
We may also disclose personal information to the acquirer or its agents in the course of the sale of our business. If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.
How We Retain Your Personal Information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.
As Users may come back to us after an Account becomes inactive, we don’t immediately delete your personal information when a trial period expires or you cancel all paid Services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back.
Please note that in the course of providing the Services, we collect and maintain aggregated or de-personalized information which we may retain indefinitely.
Other Information Collectors
Members’ Personal Information
Users who have created a Portfolio using the Services are responsible for what they do with the personal information they collect, directly or through our Services, about their Members. This section is directed to our Users concerning their Members.
A. Your Relationship with Members
You’re solely responsible for complying with any laws and regulations that apply to your collection and use of your Members’ information, including personal information you collect about them from us or using our functionality or cookies or similar technologies.
We’re not liable for your relationship with your Members or how you collect and use personal information about them (even if you collect it from us or using our functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters.
B. Member Payment Information
Your Members’ payment information may be processed via third party e-Commerce Payment Processors with which you integrate your Account, in accordance with such e-Commerce Payment Processors’ terms and policies. We transmit your Members’ complete payment information when they initially provide or update it only so that we can pass it along to the e-Commerce Payment Processors you agree to use. We don’t collect or store your Members’ payment information except as described above.
Your Rights and Choices
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information (or that of your Members) either directly in your Account through the Platform. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.
You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please reach us at email@example.com.
Updated November 10, 2020