EFFECTIVE DATE: May 29, 2020
The Information We Collect About You
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Information We Collect Directly From You. You may browse certain areas of the Site without registering with us or providing us personal information. If you complete one of our contact forms, or applications, or sign onto the Platform, then we collect your name and email address and certain additional background information. If you enter a Pooling Agreement, we may collect additional information as contemplated by that agreement, including information, historical and prospective, about your eligible income subject to such agreement, and with respect to your marital status. In addition, if you are providing personal information for third parties in connection with using our Services, you are responsible for ensuring that you have all required permissions and consents to provide such personal information to us for use in connection with the Services and that our use of such personal information to provide the Services does not violate any applicable law, rule, regulation or order.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
To provide our Site and Services to you, to communicate with you about your use of our Site and Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes, including potentially providing your information to others on the Platform or who have entered Platform Agreements or Pooling Agreements or their representatives, and are thereby bound by the confidentiality terms contained in such agreement, or potentially providing your name and that you have registered on the Platform to others who are contemplating registering on the Platform or entering into a Platform Agreement.
To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
How We Share Your Information
We may share your information, including personal information, as follows:
Others on the Platform. We may share limited personal information with others who have registered on the Platform or who have entered Platform or Pooling Agreements, or their representatives for the purpose of their consideration of forming a pool with you, joining your pool or having you join their pool, however, if we do, their use and disclosure of your personally identifiable information will be maintained by such persons in accordance with the confidentiality terms of such agreements.
Others Considering Registering on the Platform. We may share your name and the fact that you have registered on the Platform to others who are contemplating registering on the Platform or entering into a Platform Agreement.
Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.
Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or if we are in negotiations for any such transactions, we may transfer the information we have collected from you to the other company.
In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties and publicly for marketing, advertising, research or similar purposes.
Please note that except as noted above, we will not sell or share your personal information with any third party for their direct marketing purposes without your consent.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Site and Services.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.
Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Services.
Third Party Analytics
Our Site and Services may contain links to third-party websites, including any link you access either through our Site or by means of electronic communication from us. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites and affiliates on its website. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Location of Information
Our Site and Services are offered from the United States. We store any information we collect in the United States. If you access the Services or Site from outside the United States, you agree to the transfer of your information to the United States, which may have less protections for your personal information than your jurisdiction of residence.
Access, Correction and Deletion of My Personal Information
You may request access, modification or deletion of personal information that you have submitted to us by contacting us at firstname.lastname@example.org. We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain personal information to comply with legal obligations, to exercise or defend legal claims or for other business purposes. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
What Choices Do I Have Regarding Marketing?
We may send periodic promotional or informational emails to you if you have subscribed to receive such communications on our Site. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us. Please note that to help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail com if your computer supports such capabilities.
Children Under 13
Our Site and Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site or if you have an account with us, providing notice to the email address in your account (for this reason you should make sure to update your account information promptly if it changes).