Revised: February 20, 2023
- Personal Information We Collect
“Personal Information” is information that identifies, relates to, or could reasonably be linked, directly or indirectly, with a natural person. We collect the following categories and types of Personal Information:
- Contact Information: your first and last name, mailing address, email address, and phone number;
- Other identifying information: IP address, social security number, driver’s license or passport number, social media user names, passwords and other security or log-in information for authentication and access;
- Financial Information: credit card, debit card and bank account information, wallet address, or public key for your blockchain-compatible wallet, tax identification number;
- Demographic information: gender, age, sex, ethnicity, citizenship, veteran information, membership in trade unions, ideological views or activities, marital status, professional or employment information and salary information;
- Geolocation data;
- Internet or other electronic activity: your browsing and click history, including information about how you navigate within our Site and Services and which elements of our Site and Services you use the most;
- Commercial information: products or services viewed on our Site;
- Audio and visual information: your videos and photos; and
- Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.
- How We Use Personal Information
We use your Personal Information for the following purposes:
Transactional Purposes: We use your contact information, financial information, and commercial information to:
- Provide our products and Services to you;
- Communicate with you about and process your requests for our products or Services.
- Analytical Purposes: We use your internet activity and browsing history, commercial information, demographic information, and geolocation data to analyze preferences, trends and statistics to improve and develop the Site and Services.
Marketing and Promotional Purposes: We use your contact information, commercial information, demographic information, internet or other electronic activity, and inferences to:
- Inform you of our new products, services and offers;
- Provide you with other information from and about our Company, including personalized marketing communications. You may opt-out of receiving marketing communications at any time using the “Unsubscribe” function we provide in those communications.
Maintenance and Improvement of the Site and Services: We use your contact information, commercial information, and internet activity and browsing history to:
- Provide you with the Site and Services, including to send you alerts about your account;
- Handle your customer services requests; and
- Help us diagnose technical and service problems and administer and improve the Site and Services.
- Security and Fraud Prevention: We use your contact information, other identifying information, commercial information, financial information, geolocation data, internet activity and browsing history, and inferences to protect the Site and services, our Company, and others and to prevent fraud, theft and misconduct.
- Sources of Personal Information
We collect Personal Information from the following sources:
- Directly from you. This includes, among other things, contact, identifying, financial and demographic information. We also automatically collect geolocation, commercial, internet or other electronic activity information using tools like browser cookies when you visit the Site [or use the Services]. These activities are further described in the Cookies section, below.
- From third parties. We collect your Personal Information from third parties, such as our partners or affiliates, social media sites, public records, insurance companies, employers, employment or credit or other references, consumer reporting agencies, and our service providers.
- Categories of Third Parties To Which We Disclose Personal Information
In general, we do not sell, trade, or otherwise disclose to third parties your Personal Information, except as described in this Policy.
- 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 disclose to our Service Providers the information necessary for them to perform these services on our behalf. We execute agreements with our Service Providers under which each (i) is prohibited from using Personal Information we disclose to them other than as specified by us; and (ii) 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.
- Our Affiliates. We may disclose Personal Information to businesses controlling, controlled by, or under common control with our Company.
- Third Parties. We may disclose your Personal Information to third parties whenever you consent to or direct such sharing. We may also share aggregated and/or de-identified information with third parties for any purpose we deem appropriate.
- Compliance with Laws and Law Enforcement. We may disclose Personal Information as necessary, in our discretion, to cooperate with lawful requests for information (including court orders and subpoenas) from government and law enforcement officials and private parties to enforce and comply with the law, and as necessary 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 otherwise comply with the law.
Our website does not respond to Do-Not-Track signals.
We use Google Analytics on the Site and Services 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/.
- Managing Your Information Preferences
You can review, correct, update, or change your Personal Information or opt out of receiving certain e-mails by e-mailing us at [email protected]. You can also opt out of receiving marketing e-mails from us by following the “Unsubscribe” link provided at the bottom of all marketing e-mails you receive from us. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account.
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.
- 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 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.
- Processing in the United States
Please be aware that we are located in the United States, and your Personal Information 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.
- Notice to California Residents/Your California Privacy Rights
If you are a California resident, you may have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This Section provides notice to California residents of the Personal Information we collect, how we use it, and describes the CCPA Rights and how you can exercise them with our Company.
Note: CCPA does not apply to certain information, such as information subject to the Gramm Leach-Bliley Act (“GLBA”). As a result, the CCPA Rights described herein may not apply with respect to, for example, nonpublic personal information that we collect about California residents in connection with our provision of financial products or services for personal, family, or household purposes.
Categories of Personal Information We May Collect or Have Collected in the Past 12 Months
- Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license or other government ID number, passport number, employee ID number or other similar identifiers;
- Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information;
- Commercial information, such as records of personal property;
- Characteristics of protected classifications under California or federal law, such as age, race, color, ancestry, national origin, immigration status, citizenship, marital status, medical condition, physical or mental disability, sex, gender, pregnancy or childbirth and related medical conditions or veteran or military status;
- Audio, electronic, visual, or similar information, such as pictures, audio or video recordings;
- Professional or employment- related information, such as current or past job history or performance evaluations, professional license information and bar standings, corporate expense information, salary information, drug screen results, fitness-for-duty or pre- employment physical exam results, tax rates, retirement fund information, compensation information, bonus information, benefits information or stock option information;
- Education Information, such as schools attended, degrees and certificates awarded or in process, grades achieved in education courses, vocational trainings and certifications and transcript information;
- Internet or other electronic network activity information, such as browsing history, search history and information regarding interaction with an internet website or application;
- [Geolocation data, such as information collected through GPS technology;]
- Inferences, such as inferences drawn from any of the personal information identified above in the records we keep, which may include your preferences or characteristics.
- Biometric information, such as genetic, physiological, behavioral and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait or other physical patterns, and sleep, health or exercise data.
Some of the information that we collect may also be considered “sensitive personal information,” such as personal information that reveals certain information, including social security, driver’s license, state identification card, or passport number.
Categories of Sources of Your Personal Information
In addition to the sources described above, the categories of sources from which we collect or receive personal information may include government entities and other sources, publicly available sources, our affiliates and business partners, credit agencies or bureaus, service providers or other third parties.
Business or Commercial Purpose for Collection or Use
In addition to the purposes described above, we may collect, use, or disclose your personal information for the purposes as described below:
- For security purposes, including helping to ensure security and integrity or debugging to identify and repair errors;
- Undertaking internal research for technological development;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by us;
- Commercial purposes, including marketing to provide you with information about our services.
To exercise your CCPA Rights, you or your authorized agent may submit requests to [email protected] Please indicate in the subject line the right you wish to exercise, as detailed below. To process your requests, please provide us with information sufficient to verify your identity, including your first name, last name, email address, and phone number. To verify your identity, we will match that information to the information we have on our systems. To designate an authorized agent to act on your behalf you must send a signed, written authorization containing your first name, last name, email address, and phone number to:
1 N. Wacker Drive, Suite 3601
Chicago, IL 60606
You can also call us toll free at (800) 596-3603 to submit your request by phone. You must provide us with all of the information set forth above in any such request, including what request you are making.
Right to Know
You can request what Personal Information we have collected about you in the preceding 12 months. In particular, you have the right to request:
- The specific pieces of Personal Information we have collected about you;
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information was collected;
- The business or commercial purpose for collecting or selling the Personal Information; and
- The categories of third parties with whom we shared Personal Information.
Right to Deletion
You have the right to request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:
- Transactional: to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
- Security: to detect, investigate, and prevent data security incidents;
- Error Correction: to debug or repair any errors;
- Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
- Internal Use: to use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
We will also maintain a record of your CCPA Rights requests.
Please note that if we delete your Personal Information, some of our services may not function properly. For example, your saved preferences and information may no longer be available.
Right to Opt Out of Sale/Sharing
California residents have the right to opt out of the sale or sharing of your Personal Information to third parties, as “sale” is defined under CCPA.
To opt out of the sale or sharing of your Personal Information, please follow the “Do Not Sell/Share My Personal Information” link or reach out via the mechanisms mentioned above.
Do Not Sell or Share My Personal Information
We may “sell” or “share” (as such terms are defined in CCPA) your personal information to or with select third parties when we provide our professional services, including without limitation, for fraud prevention and investigation. We do not knowingly sell the Personal Information of minors under the age of 16.
Personal Information that We Sell or Share
We may “sell” or “share” (as those terms are defined in CCPA) the following categories of Personal Information:
- Characteristics of protected classifications under California and federal law;
- Internet/electronic activity; and
- Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, preferences, behavior and attitudes.
We do not sell or share any “sensitive” personal information.
We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.
We may offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by contacting us at [email protected] or by unsubscribing to our email marketing by visiting our website. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.
- Notice for Users located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”)—Your Rights and Choices
The data controller for the Site and Services is:
1 N. Wacker Drive, Suite 3601
Chicago, IL 60606
We use the information we collect about you to pursue the following purposes, which are necessary for the performance of the contract between us to provide you with the products or services you requested or which we consider in our legitimate interests:
- To enable you to register to the Site and Services;
- To send you transaction-related emails or push notifications;
- To offer you the features for which you provide Personal Information;
- To handle consumer services requests, such as resolving your problem or question, handling your warranty request; managing any complaints or dealing with any feedback you may provide us;
- For statistical analysis of aggregated data to help us segment our offering and develop our products and services;
- To better understand the way in which the Site and Services are working, to offer a better experience to you when using the Site and Services, to create statistics in relation to the use of the Site and Services, and our other services and offerings in general; and
- To help us diagnose and respond to technical and service problems and administer the Site and Services.
Based on your voluntary consent, which you may withdraw at any time, we also use:
- your browsing data to better understand your profile, interests, preferences to enhance your user experience and facilitate your experience and offer you relevant information and promotional materials; and
- your Personal Information and we may combine these with third-party data to send you personalized emails and push notifications tailored to you and your interests.
In order to comply with our legal obligations, we may also use some of your Personal Information to detect and prevent illegal uses, abuse, spam, fraud, security incidents and other harmful activity or government or court orders.
You may have certain rights under applicable data protection legislation with respect to your Personal Information, such as the right to request:
- Access to and be provided with information on the processing of your Personal Information;
- Correction of your Personal Information if such Personal Information proves inaccurate or incomplete;
- A copy of Personal Information which you provided to us in a structured, commonly used and machine-readable format and to transmit it to another provider provided it is processed based on your consent or our contract.
In addition, you may:
- object to the processing of your Personal Information for direct marketing purposes or to any processing which we would have based on our legitimate interest (e.g. profiling);
- withdraw any consent you may have provided, to the extent we previously requested and you provided your consent to the processing of your Personal Data (note that your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal); and
- lodge a complaint with your relevant data protection authority.
If you wish to exercise any of your above rights, please send an email to [email protected]. You must use “European Rights Request” in the subject line of your email.
Regarding the transfer of Personal Information to countries outside the EEA, Switzerland or the UK, we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the Commission of the European Union, and/or International Data Transfer Agreements or Addendum to the Standard Contractual Clauses as approved by the UK Information Commissioner Office, for the international transfer of Personal Information to controllers or processors established in third counties, as the case may be.
The principle that we apply is that your Personal Information will be deleted when it is no longer necessary for the purpose for which it was collected. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), prevent fraud, resolve disputes, and enforce our legal agreements and policies.
- Contact Us
If you have any questions or concerns, you may contact us at [email protected].