1. PURPOSE OF THIS PRIVACY NOTICE
CMDTY Inc. takes your privacy seriously. This notice (“Privacy Notice”) explains how we collect, use, disclose, retain and protect information that identifies you personally (your “Personal information”), and it applies to each of our websites, apps, services or tools that contain a link to this Privacy Notice (collectively, the “Services”). We reserve the right to update or change this Privacy Notice from time to time and if we do so, the updated version will be made available through the Services and/or otherwise made available to you, and we will provide a prominent notice and/or contact you by email or other method if we make material changes to it. By using the Services after receipt of any notice of an update to this Privacy Notice, you agree to the updated version to the extent permitted by law. Please periodically review this Privacy Notice for the latest information on our practices with respect to your Personal Information.
2. INFORMATION WE COLLECT
When you use the Services, we may ask you to provide us with certain Personal Information that can be used to contact or identify you. We collect or receive information in different ways, depending on how you use and interact with the Services. In some instances, you can choose which information you provide to us, but in others certain information is required so that we can provide the Services to you. More information on this is immediately below.
- Personal identifiers. This includes information provided when you create or update your user account or fill out a web form, such as your name, business address, e-mail addresses, payment information (including your credit card details), phone numbers, login and password.
- Business information. This includes information about services or products you purchased, your feedback or reviews, or details related to your business.
- Your content. We may collect from information you post on our website or on social media, or when you contact or otherwise communicate with us. It enables us to tailor the Services to your preferences. If your content contains any information about another person, please make sure you have their consent to share it.
Information collected from third parties. This information serves to supplement the information we collect directly from you. It can be from commercial data aggregators or marketing and advertising partners.
- For referral services. We may offer for you to tell friends about the Services. In order to use this referral service, we will need to collect your contact’s name and email address, and they would receive an automatic one-time invitation via email that we send on your behalf inviting them to use our Services.
3.HOW WE USE YOUR PERSONAL INFORMATION
We use your Personal Information to provide, improve and personalize the Services for you, if we need to contact you about your user account or the Services, to provide you with customer support, or to prevent fraud or other illegal activities. Additional details on how we use your Personal Information are below.
- To provide you with the Services. This includes processing and communicating with you about your use of the Services, to provide you with customer support or otherwise contact you about your use of the Services.
- To communicate with you. This includes to answer any questions you may have of us, or with respect to any of your account activity.
- To improve and personalize the Services for you. This helps us provide you with a more customized user experience based on your provided preferences. We also might get information about you from third parties and combine it with what you’ve provided to us for this purpose.
- For security purposes. This is to help protect you, our Services, company and our other customers from fraud or other illegal activities.
For marketing purposes. This is so we can let you know about new features or promotional offers that you might be interested in based on your provided preferences.
- To pursue our legitimate interest. For example, direct marketing, research (including marketing research), network and information security and fraud prevention.
- We use Personal Information as otherwise permitted or required by law, as long as it’s necessary or relevant to our business, or as we may otherwise notify you.
4.SHARING OF YOUR PERSONAL INFORMATION
We may share your Personal Information with third parties under certain limited circumstances. Additional detail on who we share your information with, and why we share it, is below.
- Third party service providers. They may, as our trusted service providers, need certain of your Personal Information for payment processing, billing, account security, customer support, personalized advertising and other business operations. Third party service providers and/or the equipment on which such service providers store or process Personal Information may be located outside the United States.
- Third party collaborations. After removing certain identifiers, like your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, we may use, sell, license and/or share your information with third parties for research, business or other purposes.
- As part of a business transaction or in connection with negotiations and preparations for a possible business transaction. This includes if we are involved in a merger, acquisition, financing due diligence or other similar event.
- Credit agencies or bureaus. We may need to share (where legally permitted) certain information if you’ve missed payments or defaulted on your user account.
- Our affiliated or related entities. This is in order to ensure that you have a secure and consistent experience using the Services. These companies may be providing you with various products and services as our business evolves.
- To comply with applicable law, enforce our terms of service, prevent, detect, mitigate or investigate fraud or other illegal activity or to protect our legitimate business interests.
You have a choice about how we handle your Personal Information. There are various ways you are able to control the personal information of yours that we receive and retain, and how your activity is tracked when using the Services.
- In general. You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us at [email protected].
- To opt out of marketing communications. You can opt out of marketing communications by following the instructions in any marketing email. This does not apply to transactional messages that relate specifically to your use of the Services.
- Updating your account information. This includes updating or deleting incorrect user account information (you must log in to your account to do this).
- Do Not Track (“DNT”). This is a privacy preference that users can set in certain web browsers. We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Shine the Light Law (for California residents). If you are a California resident and have an established business relationship with us, you have the right to request certain information regarding our disclosure of your personal information to third parties for direct marketing purposes. To make such a request, you can email [email protected].
6.HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We keep your Personal Information for as long as is reasonably necessary in order to provide you with the Services, or until your account has been deleted (whichever happens first). This is subject to any longer period that might be required by applicable law or notified to you. If you delete your account, it may take additional time to fully delete your Personal Information. We may retain Personal Information from deleted accounts in order to prevent fraud, enforce our rights under our terms of service, to enforce our legal rights generally or to comply with our legal obligations.
7. OUR SECURITY MEASURES
We strive to protect your Personal Information using reasonable, industry standard technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. However, no one can guarantee absolute protection on the Internet, so we cannot ensure or warrant the security of any information you provide to us.
8. INTERNATIONAL DATA TRANSFERS
You understand and agree that we may transfer and process your Personal Information anywhere in the world, including the United States. We are located in and subject to United States laws, which may not afford the same level of protection as those in your country. We will take all reasonably necessary steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Notice. By providing us with any Personal Information, you consent to our transfer of Personal Information across national borders.
9. THE SERVICES ARE NOT INTENDED FOR CHILDREN
Our Services are meant for adults. We do not knowingly collect Personal Information from people under the age of 16, nor do we sell such Personal Information. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us at [email protected]. If we become aware that we have collected Personal Information from children under 16 without verification of parental or guardian consent, we take steps to remove that information from our servers.
10. WE MAY LINK TO THIRD PARTY SITES OR SERVICES WE DON'T CONTROL
The Services may contain links to third party websites that we do not control. This Privacy Notice does not apply to the privacy practices of those websites. Read the privacy notices of other websites carefully. We are not responsible for these third party sites. The Services may also serve third party content that contains their own cookies or tracking technologies, and we do not control the use of those technologies.
11. QUESTIONS OR CONCERNS?
If you need to reach us about anything related to this Privacy Notice or our handling of your Personal Information, please contact us via email at [email protected], or by writing to CMDTY Inc., 368 9th Avenue, 6th Floor, New York, NY 10001, Attn: Privacy. Please reference this Privacy Notice and do not include any sensitive details.