Privacy Policy

PersonaFi, Inc

Privacy Policy

Effective as of August 12, 2021

Please read our Privacy Policy (the “Privacy Policy”) carefully which applies to the PersonaFi mobile application (the “App”), website (the “Site”), emails and customer service operations, owned and operated by PersonaFi,Inc. (“PersonaFi,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information that PersonaFi will collect when you are using its App or Site, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms and Conditions. By visiting and/or using our App or Site, you are agreeing to the terms of this Privacy Policy and the accompanying Terms and Conditions. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

1.      SITE AND APP OWNER. PersonaFi is the owner of this web site www.personafi.co. PersonaFi can be contacted by email at info@personafi.co or by phone at XXXXXXXX. This privacy notice discloses PersonaFi information practices for its Site and App, including what type of personal identifiable information is requested in order to make a purchase, how the information issued, and with whom the information is shared.

2.     INFORMATION WE COLLECT OR RECEIVE. IN the course of operating the Site and App, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

(a)         Personal Information. We only receive or collect information that identifies you personally if you choose to provide suchpersonally identifiable information to us by any means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. We will collect Personal Information from you when you use the Site and App.

(b)         Service Quality Monitoring. Some Web site transactions may require a customer to telephone PersonaFi, or PersonaFi to call the customer. PersonaFi will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customer should be aware that it is PersonaFi's practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.

(c)         Payment Information. If you choose to make a purchase or subscribe to a feature or service ours that requires a fee, you will be required to provide us with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment vendors pursuant to the terms and conditions of their privacy policies and terms and conditions, and we do not obtain access to any Payment Information in connection with such purchases or subscriptions.

(d)         Geolocational Information. Certain features and functionalities of the Site or App are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”).Collection of such Geolocational Information occurs only when the Site or App is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.

(e)         Information from Children. PersonaFi does not sell products or services for purchase by children and will not collect or post information from a child under the age of 18 without the involvement of a parent or guardian. We adhere to the Children’s Online Privacy Protection Act(COPPA) and will not knowingly collect Personal Information from any child under the age of 18. We ask that minors (under the age of 18) not use the App. If a child under the age of 18 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records. PersonaFi does not use personally identifying information collected from children for marketing or promotional purposes and does not disclose such information to any third party for any purpose whatsoever.

(f)          Lost or Stolen Information. If acustomer's credit card and/or password is lost or stolen, the customer should promptly notify PersonaFi in order to enable PersonaFi to cancel the lost or stolen information and to update its records with a changed credit card and/or password.

(g)         Links to Other Web Sites. An PersonaFi Site or App may contain links too their web sites. PersonaFi is not responsible for the privacy practices or the content of those other Web sites.

(h)         Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (e.g., Google Analytics) to evaluate your use of the Site and App, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site and App and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit https://aws.amazon.com/compliance/data-privacy-faq/.Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Site or App.

(i)           Other Information. In addition to the Personal Information, Payment Information, and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the Site or App; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Site or App (collectively, the “Other Information”). Such Other Information may include:

(i)         From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.

(ii)       From Your Activity. We may collect or receive information regarding:

(A)      IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;

(B)       browser type and language;

(C)       referring and exit pages and URLs;

(D)      date and time; and

(E)       details regarding your activity on the App, such as search queries and other performance and usage data.

(iii)     About Your Mobile Device or Web Browser. We may collect or receive information regarding:

(A)      type of mobile device, browser, or computing device;

(B)       advertising Identifier (“IDFA” or “AdID”);

(C)       operating system and version (e.g., iOS, Android or Windows);

(D)      carrier; and

(E)       network type (WiFi, 3G, 4G, LTE).

(iv)      Collection of Non-Identifiable Information. PersonaFi may collect non-identifiable information from user visits to the PersonaFi Site(s) or App in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on PersonaFi Site(s) or App; Site, App and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." PersonaFi or its contractors may use this data to analyze trends and statistics.

(v)       From Cookies. We may use both session cookies, which expire once you close the App, and persistent cookies, which stay on your mobile device until you delete them and other technologies to help us collect data and to enhance your experience with the Site and/or App. Cookies are small text files an app can use to recognize a repeat visitor to the app. The cookie is then stored on customer's computer as an anonymous tag that identifies the customer's computer, but not the customer. We may use cookies for various purposes, including to:

(A)      type of mobile device;

(B)       personalize your experience;

(C)       analyze which portions of the App are visited and used most frequently; and

(D)      measure and optimize advertising and promotional effectiveness.

If you do not want us to deploy cookies in the Site or App, you can opt out by setting your mobile device to reject cookies. You can still use the Site or App if you choose to disable cookies, although your ability to use some of the features may be affected.

3.     INFORMATION COLLECTED BY OR THROUGHTHIRD-PARTY ADVERTISING COMPANIES. We may share Other Information about your activity on the App with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, retargeting, analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

4.     HOW TO OPT OUT OF THIRD-PARTYINTEREST-BASED ADVERTISING. If you wish to opt out of third-party interest-based advertising, please visit http://www.networkadvertising.org andhttp://www.aboutads.info/choices for details on how to do so. Additionally, users of mobile Devices can follow the below instructions:

Android Users

For Android devices with OS2.2 and up and Google Play Services version 4.0 and up: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising.”

iOS Users

iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.

iOS 6: Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting.

5.     HOW INFORMATION IS USED AND SHARED.

(a)         You authorize us to use the Personal Information, Payment Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:

(i)         provide and improve our App or Site;

(ii)       provide our services;

(iii)     administer our promotional programs;

(iv)      to get reviews and ratings;

(v)       for our marking purposes;

(vi)      internal business analysis or other business purposes consistent with PersonaFi’s mission and to carry out other purposes that are disclosed to you and to which you consent;

(vii)   solicit your feedback; and

(viii) inform you about our products and services.

(b)         In order to provide our services and administer our promotional programs, we may share the Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.

(c)         We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law

(d)         In an ongoing effort to better understand our users, the App or Site, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the App or Site and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the App or Site and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

(e)         We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

(f)          As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

(g)         To the extent permitted by law, we may also disclose the Information:

(i)         when required by law, court order, or other government or law enforcement authority or regulatory agency; or

(ii)       whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

6.     ACCESSING AND MODIFYING INFORMATION ANDCOMMUNICATION PREFERENCES. If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the App or Site (e.g., requests for support).

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

7.     INFORMATION SECURITY.

(a)         Commitment to Security. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

(b)         No Liability for Acts of Third Parties. PersonaFi will exercise all reasonable efforts to safeguard the confidentiality of customer personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, PersonaFi  shall not be liable for unauthorized disclosure of personal information due to no fault of PersonaFi including, but not limited to, errors in transmission and unauthorized acts of PersonaFi staff and/or third parties.  

8.     CORRECTIONSAND CHANGES TO PERSONAL INFORMATION. Help PersonaFi to keep customer personal information accurate. If customer's personal information changes, or if customer notes an error upon review of customer information that PersonaFi has on file, please promptly e-mail info@personafi.co and provide the new or correct information.

9.     YOURCALIFORNIA PRIVACY RIGHTS. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of PersonaFi who are California residents to request certain information regarding PersonaFi’s disclosure of personal information for their direct marketing purposes. To make such a request, please email PersonaFi at: info@personafi.co.Within 30 days of receiving such a request, PersonaFi will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. PersonaFi reserves its right not to respond to requests submitted other than to the address specified in this paragraph.

California’s privacy laws require a company to provide notice to California users of their rights to receive information onto which entities their information was shared for marketing purposes.

10.  IMPORTANTNOTICES TO NON-U.S. RESIDENTS. The App and Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App or Site, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

11.  APP STORES;EXTERNAL WEBSITES. Your app store (e.g., iTunes or Google Play)may collect certain information in connection with your use of the App, such as Personal Information, Payment Information, Geolocational Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

The App or Site may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms and conditions when visiting any other websites.

12.  CHANGES TOTHIS PRIVACY POLICY. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the App or Site. By accessing the App or Site after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

13.  GOVERNINGLAW; VISITORS RESIDING OUTSIDE THE UNITED STATES. This Privacy Policy and the privacy practices of PersonaFi will be subject exclusively to the laws in which PersonaFi provides its services.

14.  QUESTIONS, PROBLEMS AND COMPLAINTS. If you have a question about this policy statement, or a complaint about PersonaFi compliance with this privacy policy, you may contact PersonaFi by e-mail info@personafi.co.

15.  TERMSOF USE. If customer chooses to purchase OR to subscribe to PersonaFi's services, customer's action is hereby deemed acceptance of PersonaFi practices described in this policy statement. Any dispute over privacy between customer and PersonaFi is subject to the provisions of this notice and to PersonaFi's Terms and Conditions which can be read at www.PersonaFi.co/termsandconditions.

16.  HOW TO CONTACTUS. If you have questions about this Privacy Policy, please-mail us at info@personafi.co with “Privacy Policy” in the subject line or mail us at the following address:

[mailing address].