Fundomate Technologies, Inc. together with its subsidiaries or
affiliates and any other entity, as applicable (collectively,
“Fundomate”, “we” or “us”) operating a platform which includes our
mobile application or our website, available at: www.fundomate.com and
any and all websites and applications that Fundomate operates or that
link to this Privacy Policy, including but not limited to, any and all
pages within each such website or application, any equivalent mirror,
replacement, substitute or backup website or application, and pages that
are associated with each such website or application (collectively, the
“Platform”), and shall govern the access, download and use of our
Platform and any services or products which may be provided therein
(collectively, the “Services”) by any of our users who accesses, uses or
otherwise interacts with the Platform (“you” or “user(s)”).
We at Fundomate respect your right to privacy as detailed in this
privacy policy (“Privacy Policy”). Please read and review carefully this
privacy Policy as it explains how we collect, process and use data we
collect from you in connection with the Platform and Services. We
encourage you to read this Privacy Policy prior to accessing or using
the Platform or Services. Any capitalized terms not defined here under
shall have the meaning ascribed to them under the terms of use of the
Platform available at Terms of use (the “Terms”). This Privacy Policy is incorporated by reference into the
Terms as an integral part thereof.
If you choose to access, use, register to the Platform or Services or
provide data to us or through the Platform or Services you explicitly
agree to the use of such data in accordance with this Privacy Policy.
You may not use the Platform or Services or submit any data through it
if you do not agree to any of the terms hereunder. This Privacy Policy
shall not be construed in any manner to derogate from the Terms or any
other agreement made by and between Fundomate and you.
Privacy Policy Highlights:
-
The content you upload to Platform or Services is not intended to be
confidential, and may be reviewed by us and our trusted third-party
partners and affiliates, including Blue Ridge Bank N.A. As such,
please do not share or disclose any information which is sensitive or
confidential unless you agree that any such information will be
disclosed to our trusted third-party partners and affiliates,
including Blue Ridge Bank N.A.
-
Personally Identifiable Information is information that, when used
alone or with other relevant data, can identify an individual
(“Personally Identifiable Information”). By agreeing to this privacy
policy you agree and understand that in the course of your use of the
Platform or the Services we may process Personally Identifiable
information related to you or your Personally Identifiable
Information.
-
You are not required by law to provide us with any Personally
Identifiable Information. Sharing Personally Identifiable Information
with us is entirely voluntary.
-
Our Platform and Services are intended for users over the minimum age
for providing consent to processing of Personally Identifiable
Information in the relevant jurisdiction. Children or minors under
such age are not permitted to register to the Platform or use the
Services. If you are under such age you should cease using the
Platform or Services immediately.
-
We do not sell, trade, or rent users’ Personally Identifiable
Information to third parties. We only share Personally Identifiable
Information with third parties in connection with the provision of the
Platform or Services to our users, or other limited circumstances
specified in this Privacy Policy.
-
You may be entitled under applicable law to request to review, amend,
erase or restrict the processing of your Personally Identifiable
Information. Please note that in case you request to erase or restrict
the processing of your Personally Identifiable Information, your use
of the Platform or Services may be restricted or disabled.
-
If you have any questions or requests regarding the processing of your
Personally Identifiable Information or would otherwise like to contact
us in connection with this Privacy Policy, please send us an email to:
admin@fundomate.com.
-
The Types of Personally Identifiable Information Fundomate Collects
About Users; What Is Personally Identifiable Information?
-
We have collected the following categories of Personally
Identifiable Information from consumers:
-
Identifiers, which may include real name and alias; mailing
address; unique personal identifier; online identifiers as
detailed below; Internet Protocol (“IP”) address; email
address; telephone number; account number, name, and password;
Social Security number; driver’s license number, passport
number, state or other government-issued identification card
number; and/or other similar identifiers.
-
Commercial information, which may include records of personal
property; products or services purchased, obtained, or
considered; account balances, payment history, or account
activity; bank account information and other information
relating to your financial institution; credit application,
credit checks, and information from credit reporting agencies;
and/or other purchasing or consumer histories or tendencies.
-
Internet or other electronic network activity information,
including, but not limited to log-in and log-out time, the
duration of sessions, the content uploaded and downloaded,
viewed web-pages or specific content on web-pages, activity
measures.
-
Information relating to Internet activity or other electronic
network activity, which may include cookie identifiers, clear
gifs (a.k.a. web beacons/web bugs), browser type, internet
service provider (ISP), referring/exit pages, operating
system, date/time stamp, click stream data, device platform,
device version, and/or other device characteristics.
-
Geolocation data, which may include GPS data; locational
information based upon your IP address; cell network data;
and/or other similar locational data; and which may be
collected from various devices including your mobile
device(s).
-
Audio, electronic, or visual information, which may include
records of calls to or from our customer service centers;
and/or video surveillance information.
-
Professional or employment-related information, such as your
current and previous employers; job title and
responsibilities; assets; income; and/or other information
related to your work history and/or prospective employment.
- Education information.
-
Information not listed above and related to characteristics
protected under California or federal law; which may include
gender; race and ethnicity; nationality; marital status;
military service / veteran status; and/or date of birth.
-
Other personal information not listed above and described in
California Civil Code 1798.80(e), which may include signature;
physical characteristics or description; insurance policy
number; and/or bank account number credit card number, debit
card number, and other financial, medical, and/or health
insurance information.
-
Inferences drawn from any of information identified above to
create a profile about consumers.
-
Our Categories of Sources for Personally Identifiable Information.
-
We obtain the categories of personally identifiable
information listed above from the following categories of
sources:
- Users of our Platform.
-
Things that other third parties may post publicly about you or
otherwise provide to us, which may include review platforms,
public forums, and testimonial websites.
-
Third party service providers assisting us in connection with
‘know your customer’ and anti money laundering investigations
we are required to perform in accordance with applicable law.
-
What Do we Do with the Personally Identifiable Information We
Collect
-
We further use personally identifiable information to enable
the Platform and the Services, to study and analyze the
functionality of the Platform and the Services, to provide
support, to measure the Platform and the Services activity, to
maintain the Platform and the Services, to make the Platform
and the Services better, and to continue developing the
Platform and the Services.
-
If you provide us your email address, we may use it to contact
you when necessary, to provide information and notices about
the Platform and the Services. We will include commercial and
marketing information about our Platform and the Services.
-
If necessary, we will use personally identifiable information
for the following purposes:
-
to enforce our Terms, this Privacy Policy and other legal
agreements;
-
to comply with court orders and warrants, and assist law
enforcement agencies;
-
to collect debts, prevent fraud, misappropriation,
infringements, identity thefts and any other misuse of the
Platform and the Services;
-
to prevent cyber security attacks and any other unlawful
or unauthorized use of your personal information and the
Platform and the Services;
-
to take any action in any legal dispute and proceeding;
and
-
for additional purposes which are compatible with the
purposes listed under this policy and that we believe in
good-faith to be within your reasonable expectation.
-
Our Use and Disclosure Practices.
-
We use the personally identifiable information that we collect
or receive for the business purposes as described above under
the section titled “What Do we Do with Personally Identifiable
Information?” of this Privacy Policy.
-
We disclose personally identifiable information to third
parties for business purposes as described above under the
section titled “Sharing Data with Third Parties” in this
policy.
-
In the preceding twelve (12) months, we have disclosed the
following categories of personally identifiable information
for business purposes:
- Identifiers.
-
Internet or other electronic network activity information.
-
Inferences drawn from any of information identified above.
- Tracking Technologies
-
When you use the Website or Services, we may use tracking
technologies known as cookies or web beacons and or similar
technologies. Cookies are small text files stored in a user’s
browser, and web beacons are electronic images that allow to count
visitors who have accessed a particular page and to access certain
cookies. Cookies are also normally used by websites that use third
party traffic monitoring and tracking services. For further
information on Cookies please see our Cookie policy
-
If you wish not to continue to receive cookies from us, with the
exception of technical cookies, you may notify us by following the
instructions for opting out of such cookies on our Website or
sending us an email to: admin@fundomate.com. If
you are accessing our Website from the European Economic Area, the
use of Cookies, including third party and persistent cookies,
shall be made in accordance with the laws applicable to you. In
case you have any questions about how we use cookies which are not
answered in this statement, you may contact us by sending us an
email to: admin@fundomate.com.
- Sharing Data with Third Parties
-
Please note that we do not share any Personally Identifiable
Information collected from you with third parties or any of our
partners except in the following events and solely to the extent
needed:
-
To provide our users with the Platform or Services in
accordance with the terms and conditions of this Privacy
Policy;
-
We may share IP addresses collected by us, for the purpose of
detecting any fraud, illegality, security risks or other
technical issues as related to the Platform or Services or as
required for the operation and improvement of the Platform or
Services;
-
If Fundomate is required or reasonably thinks that it is
required by law or law enforcement agencies to share or
disclose your information;
-
In any case of conflict, dispute, or legal proceeding of any
kind between users and Fundomate or between you and other
users with respect to, or in relation with the Platform or
Services;
-
In case you have breached our Privacy Policy or Terms, or you
have violated your rights to use the Platform or Services, or
acted in a manner which we reasonably believe to be violating
any applicable laws, rules, or regulations;
-
As required to prevent damage or breach to the rights or
interests (including any legal rights) of third parties,
including with respect to safety issues of Fundomate, our
users or any applicable third party;
-
If Fundomate organizes the structure or business of the
Platform or Services within a different framework, or through
another legal structure or entity, or in case of sale or
merger of Fundomate; and
-
In certain cases we may disclose Personally Identifiable
Information to our trusted partners and service providers so
that they can perform requested services on our behalf, such
as for fraud detection, server and data storage providers or
for security purposes etc.
- Will Fundomate transfer my Personally Identifiable Information
Internationally?
-
We will store and process information in the United States, on our
cloud-based services’ sites. From time to time, we will make
operational decisions which will have an impact on the sites in
which we maintain personally identifiable information. We make
sure that our data hosting service providers provide us with
adequate confidentiality and security commitments.
-
If you are a resident of the European Economic Area or any other
jurisdiction where transfer of your Personal Data (as such term is
defined in the EU General Data Protection Regulation (the
“GDPR”)), to another jurisdiction requires your consent, then you
provide us your express and unambiguous consent to such transfer.
You can contact us at admin@fundomate.com for further
information about data transfer.
-
To protect personally identifiable information related to you or
your Personally Identifiable Information when such information is
transferred to countries outside the European Economic Area and to
provide it with adequate level of protection, we have implemented
appropriate safeguards in accordance with applicable laws. For
example, the transfer of Personal Data to Israel is made in
accordance with the EU Commission decision 2011/61/EU of January
31, 2011, on the adequate protection of personally identifiable
information by the State of Israel with regard to automated
processing of personally identifiable information.
-
If any data transfer measure is terminated, revoked or
invalidated, or at our discretion, we will use alternative lawful
measures to transfer Personal Data, to the extent required under
EU data protection laws.
- EU Related Provisions
-
The Lawful Basis Under Which Fundomate Processes Personal Data.
-
As part of our Privacy Policy we would like to explain to you
the lawful basis under which we process Personal Data (as
defined below), all subject to the EU General Data Protection
Regulation (the “GDPR”), as well as other applicable data
privacy regulations, as follows:
-
Where a user uses our Platform or Services, we process
Personal Data of such user in order to perform our
contract with such user or provide the Services to such
user;
-
We process Personal Data, as described below, under the
lawful basis which relies on our legitimate interests.
Such interest include, among others, processing Personal
Data of our users: (i) as required for the provision of
the Services in accordance with Recital 47 of the GDPR;
(ii) as necessary for the purposes of preventing fraud or
exploiting or abuse of the Platform and any of the
Applications or the Services ; (iii) as necessary for the
performance direct marketing and communication purposes;
(iv) as required to be shared among our affiliated
corporate entities for the purpose of the provision of the
Services; or (v) as required for the prevention of
unauthorized access to electronic communications networks
and malicious code distribution and stopping 'denial of
service' attacks and damage to computer and electronic
communication systems.
-
Some Personal Data, such as third-party cookies we use are
based on consent provided to us by the users as set forth
in our Cookie Policy.
-
Some of the Personal Data may be processed by our trusted
third-party partners, under the lawful basis which relies
on our legitimate interests, except where such interests
are overridden by the fundamental rights of natural
persons which require protection of Personal Data.
-
Special Categories of Personal Data.
We do not knowingly collect or process any Personal Data included in
Special Categories of Personal Data (as defined in the GDPR) In the
event you become aware that such data has been posted to the Platform
or collected by us, please inform us immediately.
-
Right of erasure and restriction.
You may be entitled to request the erasure or the restriction of your
Personal Data, and we will comply with such requests, to the extent
required under applicable law.
-
Reviewing and amending your Personal Data.
You may send us a request in connection with reviewing your Personal
Data to: admin@fundomate.com. In the event any
Personal Data is incorrect or outdated, you may update and correct
such data by providing us with appropriate notification or
correcting the data directly on the Site, where possible.
-
Retention of Data.
We reserve the right to retain any Personal Data for as long as reasonably
necessary in order to: (i) fulfill the purposes described herein; (ii)
in the defense or assertion of legal claims and liability; (iii) for
the analysis and development of the Platform or Services; and (iv)
to comply with applicable laws, regulations or rules. Non-Personal
Data and statistical anonymized data may be retained by us without
limitation.
-
Portability of Personal Data.
To the extent relevant to you and to the Services, you may be entitled
to request the portability of your Personal Data, and we will comply
with such requests, to the extent required under applicable law.
-
Objection to processing of Personal Data and Profiling.
You have the right to object, to or to request restriction, of the
processing of your Personal Data and you have the right to object to
profiling.
-
Withdrawal of Consent.
You have the right to withdraw your consent at any time. Please note
that there may be circumstances in which we are entitled to continue
processing your data, in particular if the processing is required to
meet our legal and regulatory obligations. Also, please note that the
withdrawal of consent shall not affect the lawfulness of processing
based on consent before its withdrawal.
-
Cross-Border Data Transfers.
You also have a right to request certain details of the basis on which
your personal data is transferred outside the European Economic Area,
but data transfer agreements and/or other details may need to be partially
redacted for reasons of commercial confidentiality.
-
Complaints
You have a right to lodge a complaint with your local data protection
supervisory authority (i.e., your place of habitual residence, place
or work or place of alleged infringement) at any time or before the
relevant institutions in your place of residence We ask that you please
attempt to resolve any issues with us before you contact your local
supervisory authority and/or relevant institution by contacting us
at: admin@fundomate.com.
-
Cookies Consent withdrawal.
If you wish not to continue to receive cookies from us, with the exception
of technical cookies, you may notify us by following the instructions
for opting out of such cookies on our Platform or sending us an email
to: admin@fundomate.com. If you are accessing
our Platform from the European Economic Area, the use of Cookies,
including third party and persistent cookies, shall be made in
accordance with the laws applicable to you. In case you have any
questions about how we use cookies which are not answered in this
statement, you may contact us by sending us an email to: admin@fundomate.com.
- California Residents related provisions
This section of our Privacy Policy applies to you, if you are a California
resident
-
Your Rights as a California Resident.
You are entitled to the following specific rights under the California
Consumer Privacy Act in relation to your personally identifiable information:
-
Access to Specific Information and Data Portability Rights.
You have the right to request that we will disclose certain information
to you about our collection and use of your personally identifiable
information over the past 12 months. After verifying your request,
we will disclose to you:
-
The categories of personally identifiable information that
we collected about you;
-
The categories of sources for the personally identifiable
information that we collected about you; and
-
Our business or commercial purpose for collecting or
selling personally identifiable information related to
you.
-
The categories of personally identifiable information that
we disclosed for a business purpose or sold, and the
categories of third parties to whom we disclosed or sold
that particular category of personally identifiable
information;
-
The specific pieces of personally identifiable information
that we have collected about you;
-
If we sold or disclosed personally identifiable
information related to you for a business purpose, we will
provide you with two separate lists which will identify
the personally identifiable information categories that
each category of recipient purchased or obtained.
-
Deletion Rights.
You have the right to request that we delete personally identifiable
information related to you that we collected from you. After verifying
your request, we will delete the personally identifiable information
that you have requested to delete from our records, unless an exception
applies (such as if we are required to maintain records in accordance
with applicable law).
-
The Right to Opt-Out.
You have the right to opt out of the sale of personally identifiable
information related to you.For a period of 12 months following the
execution of your request to opt out, we will not ask your permission
to sell personally identifiable information related to you.
-
Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for
the exercise of the privacy rights described above.
-
Exercising Your Rights.
-
To exercise the access, data portability, and deletion rights
described above, please submit your request to us by sending
us a detailed message to: admin@fundomate.com.
-
To exercise your right to opt out of the sale of personally
identifiable information related to you, please submit your
request to us by sending us a detailed message to:
admin@fundomate.com.
-
Only you or a person authorized to act on your behalf, may
make a request related to personally identifiable information.
You may also make a request on behalf of your minor child.
-
A request for access can be made by you only twice within a
12-months period
-
We cannot respond to your request or provide you with the
requested personally identifiable information if we cannot
verify your identity or authority to make the request and
confirm the personally identifiable information that relates
to you. We will only use the personally identifiable
information provided in your request to verify your identity
or authority to make the request.
-
We will do our best to respond to your request within 45 days.
If we need more time (up to additional 45 days), we will
inform you of the reason and extension period in writing. We
will deliver our written response by email.
-
Any disclosures that we provide will only cover the 12-months
period preceding receipt of your request.
-
The response we provide will also explain the reasons for our
inability to comply with your request, if applicable.
-
We do not charge a fee to process or respond to your
verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the
request warrants a fee, we will inform you of the reasons for
such decision and provide you with a cost estimate before
processing further your request.
- Protection of Personal Data
-
We use industry standard tools and security measures to prevent
unauthorized access or disclosure of users’ Personally
Identifiable Information including unlawful destruction or
accidental loss, as is acceptable in the industry. In the event
you believe that your privacy rights or security is not treated in
accordance with this Privacy Policy, or you have reasonable
concerns with respect to our Service, please contact us at:
admin@fundomate.com.
-
Although we strive to use our best efforts to protect Personally
Identifiable Information, please be aware that these security
measures cannot fully eliminate security risks associated with
Personally Identifiable Information. Therefore, while Fundomate
strives to use commercially acceptable means to protect Personally
Identifiable Information, we cannot guarantee its absolute
security, and therefore, we shall not be liable for any damages
caused by unauthorized access to your Personally Identifiable
Information, unless prohibited by applicable laws and regulations.
-
Please note that in the event of a security incident, in which we
discover that your Personally Identifiable Information may be at
risk, we will take reasonable efforts to notify you and the
applicable authority (if required, subject to applicable laws and
regulations).
- Will I Receive Promotional Materials from Fundomate?
We do not send users any commercial or promotion information via direct
mailing such as emails or SMS messaging without obtaining the users’ explicit
prior consent. You may unsubscribe from receiving such communications at
any time, by sending us a notification to: admin@fundomate.com, or following the instructions for unsubscribing included in such
communications.
- Changes to The Privacy Policy
-
Please be advised that we reserve the right to change this Privacy
Policy from time to time and we will post the amended terms on the
Platform or Services and make reasonable efforts to notify you by
email of material changes. The last revision will be reflected in
the “Last Revised” date above. Amended terms will take effect
immediately. Therefore, you should review the Privacy Policy
periodically in order to remain informed of any changes. You agree
to accept the posting of a revised Privacy Policy as actual notice
to you.
-
Your continued use of the Platform or Services after any changes
to this Privacy Policy have been posted as of the “Last Revised”
date above indicates your acceptance of those changes. If you do
not agree to the revised Privacy Policy, please refrain from using
our Platform or Services and contact us by sending an email to:
admin@fundomate.com
- Persons Under 18
Our Platform and Services are intended for a general audience, which is
not directed to persons under 18 years old. If a parent or guardian becomes
aware that his/her child has provided us with Personally Identifiable Information,
he/she should contact us immediately. We do not knowingly collect or solicit
Personally Identifiable Information from people under 18 years old. If
we become aware that a person under 18 years old has provided us with Personally
Identifiable Information, we will delete such data from our databases.
If you are aware that your child has provided us with Personally Identifiable
Information, please contact us at: admin@fundomate.com.
- Links to Third Party Websites/Applications
Please note that our Platform or Services may link to other websites or
applications of third parties that provide useful information/services.
Any information users provide on the linked pages is provided directly
to this third party and is subject to that third party’s privacy policy.
We are not responsible for the content or privacy practices of websites
which are linked via the Platform. Links from our platform to third parties
or other sites are provided for users’ convenience. You should learn about
the privacy practices of each website before providing them with Personally
Identifiable Information.
- Applicable Laws
-
Please note that the provisions included in this Privacy Policy
relating to matters regulated under the GDPR will apply only to
the processing of Personally Identifiable Information which is
subject to the GDPR in accordance with the applicability of the
provisions contained therein. If the GDPR does not apply to the
processing of your Personally Identifiable Information, some of
the provisions above may not apply to you.
-
Please note that the provisions included in this Privacy Policy
relating to matters regulated under the CCPA will apply only to
the processing of Personally Identifiable Information which is
subject to the CCPA in accordance with the applicability of the
provisions contained therein. If the CCPA does not apply to the
processing of your Personally Identifiable Information, some of
the provisions above may not apply to you.
-
Please note that the provisions included in this Privacy Policy
relating to matters regulated under the United Kingdom’s Data
Protection Act 2018 and any other data protection laws
substantially amending, replacing or superseding the GDPR
following the exit by the United Kingdom from the European Union,
and the data protection or privacy laws of any other country
including, without limitation, the Israeli Protection of Privacy
Law 5741-1981 and any regulations enacted thereunder including the
Privacy Protection Regulations (Transfer of Data to Databases
Abroad), 5761-2001 and Privacy Protection Regulations (Data
Security), 5777-2017, and any guidelines and/or instructions
published by the Israeli Privacy Protection Authority will apply
only to the processing of Personally Identifiable Information
which is subject to the aforementioned legislation, if the
aforementioned legislation does not apply to the processing of
your Personally Identifiable Information, some of the provisions
above may not apply to you as well.
- Questions or Concerns Regarding Privacy
-
If you have any questions or concerns regarding privacy issues,
please send us a detailed message to: admin@fundomate.com and we will make every effort to resolve your concerns without delay.
-
You are also entitled to file a complaint with the appropriate
supervisory authority in connection with concerns you may have
with regards to your privacy and Personally Identifiable
Information.