Privacy Policy

Effective as of: Nov 11, 2024
A. Scope

Safeguarding your personal information is of utmost importance to our organization. The guidelines below outline the fundamental privacy practices and principles governing the information we gather. Our offerings, including products and services, are rendered by Fynlo Inc. or by related entities sharing common ownership or control. 

This privacy policy applies to: our products and services offered under the Fynlo brand;
our websites and the products and services offered through those websites (including www.fynloapps.com and its subdomains (the “Site”) that incorporate this privacy policy. If you have questions or complaints regarding our privacy practices or principles, please contact [email protected]

Third Parties 

This privacy policy does not extend to products or services provided by third parties on or through our website or services, nor does it encompass offerings from third-party websites, each of which is governed by its own terms and conditions and privacy policies. It is advisable to review the privacy policies and terms applicable to any third-party products or services you engage with.

By requesting products or services from third parties, you consent to the sharing of your information necessary for the fulfillment or processing of your request. 

Additionally, your interaction with social media features may involve scripting or require the sharing of your IP address and the specific page you are visiting to ensure proper functionality. Such social media features and widgets may be hosted by a business partner or directly on our site, and your engagement with these features is subject to the privacy notice of the respective provider. Examples of these features include the Facebook “Like” button, the “Share This” button, and interactive mini-programs that may operate within our services. 

Definition of Personal Information In the course of delivering products and services to you, we may gather various types of information, including personal information, pertaining to you and your business. “Personal Information” refers to data that can be utilized to identify an individual uniquely. This policy outlines our practices regarding the collection, protection, utilization, retention, disclosure, and other processing of Personal Information, as well as your rights concerning these activities.

Categories of Personal Information Collected 

The information we may collect encompasses, but is not limited to, the following categories:
Contact Information: Such as name, phone number, address, and email address.
Government Identification Numbers: Including Social Insurance Number or Social Security Number, and other identification numbers (e.g., Employer Identification Number or Driver’s License Number).
Date of Birth
Financial Information: Details related to income, revenue, assets, credits, deductions, expenses, and bank account information.
Payment Data: Information regarding checking, debit, and credit card account numbers, balances, and payment history.
Health Information: Including health insurance status and financial details related to payment for healthcare services.
Geo-Location Information:
Usage Data: Involves interactions with our website, mobile application, or advertisements.
Device Information: Such as internet protocol (IP) address, device type, unique identifiers, application version, operating system, network data, and phone state.
Login Information
Demographic Information
Professional or Employment-Related Information
Educational Information

This information is crucial for the effective provision of our services and to ensure compliance with applicable regulations.

Aggregate Data  We also collect certain aggregated or anonymized data regarding our users. Aggregate data refers to information that summarizes or combines data points without identifying individual users. For example, the statement “John Smith purchases a coffee at a coffee shop on Main Street” qualifies as Personal Information pertaining to John Smith. Conversely, the statement “20% of Fynlo users purchase coffee on Tuesdays” constitutes aggregate data. We may utilize and disclose such aggregated or anonymized information in our public communications and for the purpose of identifying individuals who may have an interest in our Services. 

Privacy Principles 

1. Accountability and Compliance 
1.1 Designation of Privacy Officer. Fynlo has appointed a Privacy Officer responsible for overseeing compliance with privacy regulations and managing our privacy policies and procedures aimed at safeguarding your Personal Information. For inquiries or concerns regarding our privacy practices or this policy, please contact us at: [email protected]
2. Purpose of Information Collection 
2.1 Collection, Use, and Disclosure of Personal Information. Fynlo collects, utilizes, discloses, and manages Personal Information in connection with our website and the services we provide. The categories of Personal Information we collect depend on your interactions with our services. For instance, while providing your customer’s email address is optional when creating an invoice, it becomes necessary if you wish to deliver the invoice via email. 
2.2 Methods of Information Collection. 
  • Direct Collection. We collect Personal Information directly from you when you interact with our website, such as when you set up an online account, authenticate your identity, apply for or purchase a product, or upload documents to your Fynlo account. If you choose not to provide certain requested information, our ability to serve you may be limited.
  • Third-Party Collection.We may also collect Personal Information from third parties when you connect your Fynlo account to their services. Such integrations may import or export data between Fynlo and third-party services. When connecting to a third-party service, the terms and policies of that service apply. 
  • Public Areas. Our website may include publicly accessible blogs or community forums. Any Personal Information shared in these areas may be read and utilized by other users. To request removal of your Personal Information from these forums, please contact us at [email protected]. In some instances, we may not be able to comply with such requests. 

2.3 Purposes for Collecting Personal Information.

Fynlo may collect, use, or store Personal Information for various purposes, including but not limited to:

  • Promoting or offering services and assessing eligibility for new products.
  • Offering products and services from business partners.
  • Providing educational materials and guides pertinent to our services.
  • Contacting you regarding service updates and notifications.
  • Delivering customer support related to our services.

2.4 Usage Data Collection.

We collect information and usage data when you interact with our services, including online and through mobile applications. This data may encompass your activity on our website, including pages visited and actions taken. We may utilize web technologies such as cookies and web beacons for this purpose. Please refer to Section B.7 for details on these technologies and opt-out options. 

2.5 Information from Third Parties. We may obtain information from third parties, including business partners and government entities, in accordance with their privacy policies. This may include data from credit reporting agencies or other regulatory bodies. 
2.6 Identity Verification. To enhance the security of our services and protect your information, we may verify your Personal Information against publicly available records from identification verification companies. 
3. Usage of Your Information 
3.1 General Use.
Your Personal Information may be utilized to deliver the products and services you request, manage your account, provide relevant information, and enhance our offerings. These activities may be performed by Fynlo or service providers acting on our behalf. 

3.2 Specific Uses. 

  • To contact you about products and services related to Fynlo or affiliated companies.
  • To assess geo-location for service enhancements and local service offerings.
  • To authenticate your identity and facilitate account setup.
  • To improve service security and protect your identity.
  • To assign unique identifiers for tracking and personalization of services. 
3.3 Referral Program. Participation in our referral program may require you to submit the name and contact details of the individual being referred. We will send a single invitation email to the provided address. We do not retain this information beyond the scope of the referral program. Referred individuals may request the removal of their information by contacting us at [email protected]
3.4 Automated Decision Making. We may employ automated decision-making processes regarding your Personal Information for risk management and fraud prevention purposes. We do not sell your Personal Information to third parties. 
4. Disclosure of Information 
4.1 General Disclosure. We may disclose your Personal Information to affiliated companies, service providers, and business partners under written agreements that restrict the use and disclosure of your Personal Information. Such disclosures may occur as required to provide the services you request or as permitted by law. 
4.2 Affiliates and Business Partners. We may share your Personal Information with companies related to us through common ownership or control for customer service and transaction processing. If you prefer that we do not share your Personal Information for marketing purposes, please notify us at [email protected]
4.3 Service Providers. Personal Information may be disclosed to service providers who assist us in operating our website and processing transactions. These third parties are contractually obligated to safeguard your Personal Information and are prohibited from using it for any purposes other than fulfilling their contractual obligations. Your Personal Information may be processed in jurisdictions outside the United States and will be subject to the applicable laws of those jurisdictions. 
4.4 Marketing Arrangements. We may share Personal Information with entities with which we maintain joint marketing arrangements. All such arrangements are governed by written contracts requiring the safeguarding of your Personal Information and prohibiting its unauthorized use or disclosure. 
4.5 Business Transfers.
In the event of a sale or transfer of our business or assets, your Personal Information may be included in that transaction. Should such a transfer lead to significant changes in this privacy policy, we will notify you according to the procedures outlined below. 
4.6 Legal Compliance.
We may disclose Personal Information when we have a good faith belief that such action is required by law, such as in response to a court order or legal investigation. We may also disclose information to public authorities to meet national security or law enforcement obligations. 
4.7 Protection of Rights. We may disclose your Personal Information when necessary to protect our rights or those of others, including notifying law enforcement of activities that may violate criminal laws.
4.8 Aggregate Data. We may disclose aggregated information that does not identify you personally, such as demographic information or usage statistics. 
4.9 Third-Party Advertisements.
Our website may feature advertisements from third parties. If you interact with these advertisements, you may be required to provide your Personal Information to those advertisers. Your interactions with such advertisers will be governed by their own privacy policies. 
5. Consent and Your Choices 
5.1 Access to Personal Information.
You may request access to your Personal Information or confirmation of whether we hold such information. In certain circumstances, you may request that we provide your Personal Information in a portable, machine-readable format. 
5.2 Correction of Information.
You may request corrections to any inaccurate or incomplete Personal Information we maintain about you. Please note that historical information may be retained in our backup systems as permitted by law. 
5.3 Deletion of Information.
You may request the deletion of your Personal Information. We will comply with such requests as required by law, although we may need to retain certain information to fulfill legal obligations or resolve disputes. 
5.4 Opt-Out of Sharing.
You may request that we refrain from sharing your Personal Information for cross-contextual behavioral advertising. 
5.5 Online Tracking. We do not currently recognize “Do Not Track” signals. 
5.6 Email Communications. We may use your Personal Information to communicate about products and services. If you wish to limit promotional communications, please contact us at [email protected] or follow the unsubscribe instructions in any marketing communication you receive. 
5.7 Submissions of Others’ Personal Information. If you submit the Personal Information of customers or employees, you are responsible for informing them of Fynlo’s practices and obtaining necessary consents. 
5.8 Account Closure. You may close your Fynlo account at any time without penalty. Ensure you follow the account closure process, including confirming via email, to avoid account retention. 
5.9 Limitations on Communication Preferences. Your choice to limit our use of your Personal Information may affect your experience with our products and services. Certain communications, such as system notifications and service-related updates, will continue to be sent regardless of your preferences.
6. Changes to This Privacy Policy  We may update this Privacy Policy from time to time. We will notify you of any material changes through the same procedures utilized to inform you of updates to this policy. 
7. Limiting Collection 
7.1 Collection of Personal Information. Fynlo is dedicated to collecting only the Personal Information necessary to provide our services to you. The specific Personal Information we collect is primarily determined by the services you utilize. We may also provide you with the option to share additional information to enhance your experience with Fynlo. 
7.3 Guest Collaborators. Certain services may allow you to grant access to your Fynlo account to authorized users, referred to as “guest collaborators.” Guest collaborators will have access to the information within your account, including Personal Information, and may perform various tasks on your behalf. You assume full responsibility for any collection, use, or disclosure of your Personal Information by your guest collaborator(s). 
7.4 Access Provisioning. To provide access to a guest collaborator, you must supply their name and email address. We will send an invitation email to the specified address. Fynlo utilizes this information solely for the purpose of inviting the guest collaborator. You are responsible for ensuring that the email addresses submitted belong to individuals or entities with whom you have a relationship and who would consent to receive such communications. The guest collaborator may request removal of their name and email address from our database by contacting us at [email protected], which will revoke their access rights. 
8. Limiting Use, Disclosure, and Retention 
8.1 Use and Disclosure of Personal Information. Fynlo is dedicated to collecting only the Personal Information necessary to provide our services to you. The specific Personal Information we collect is primarily determined by the services you utilize. We may also provide you with the option to share additional information to enhance your experience with Fynlo.
8.2 Retention of Personal Information. We will retain your Personal Information for as long as necessary to provide you with our services, maintain your account, operate our business, or enhance our offerings. Your information, including geo-location data, will be retained while your account is active or as required to deliver services. We may also retain your information to comply with our policies, fulfill legal obligations, resolve disputes, and enforce our agreements. If you choose to close your Fynlo account, we will delete your Personal Information within ninety (90) days, unless we are legally required to retain it longer or determine it necessary for legal defense. 
9. Accuracy  
9.1 Responsibility for Accuracy. Fynlo is dedicated to collecting only the Personal Information necessary to provide our services to you. The specific Personal Information we collect is primarily determined by the services you utilize. We may also provide you with the option to share additional information to enhance your experience with Fynlo.
10. Safeguards 
10.1 Security Measures. We prioritize the security of your Personal Information and employ administrative, technical, and physical safeguards to protect it. For inquiries regarding the security of our services, please contact us at [email protected]. We take measures to protect information during transmission and upon receipt; however, no method of transmission over the Internet or electronic storage is entirely secure, and we cannot guarantee absolute security. 
10.2 Compliance with Standards. Our safeguards comply with applicable laws and federal standards and are designed to limit access to your information. These include administrative controls (policies, procedures, and training), technical controls (encryption, firewalls, and secure coding practices), and physical controls (secured hosting environments). 
10.3 Sensitive Information. If we collect sensitive information (such as Social Security Numbers), we will encrypt its transmission using Transport Layer Security (TLS). When sharing your information with service providers, we require written contracts that mandate the safeguarding of your information and prohibit unauthorized use or disclosure. 
10.4 Notification of Data Security Incidents. In the event of a data security incident, we may notify you via email, mail, or telephone, as permitted by law. We ensure that any third party acting on our behalf maintains reasonable safeguards regarding your Personal Information. 
10.5 User Responsibility. You are also responsible for protecting the security of your Personal Information. For example, do not disclose your email account information or passwords to third parties. Our team will never request your password or PIN, and we advise you not to post account or credit card information in support channels. 
11. Openness 
11.1 Transparency. This policy outlines our privacy practices. If you have questions regarding this policy, please contact our Privacy Officer at [email protected]
12. Individual Access  
12.1 Access to Personal Information. You may access, update, and correct inaccuracies in your Personal Information in our custody or control at any time, subject to limited exceptions prescribed by law. You may contact us regarding your information at [email protected]. If you are a Fynlo user, you can access your information through your Fynlo account and update it where applicable. You may also download or export data you have input into the Site at any time. 
12.2 Account Deletion. You may delete your Fynlo account through the “Profile” and “Personal Information” sections, where you will find the “Close Your Account” option. The types of information you can access and update may change over time. Please note that some information we collect may not personally identify you or may not be stored in an accessible format, and thus may not be retrievable through your Fynlo account. 
12.3 Record Maintenance. When you update or delete your information, we may retain a copy in our records. If you request permanent deletion of your account or information, we may still retain and use your information as necessary to comply with legal obligations. 
12.4 Unauthorized Profiles. If an unauthorized profile has been created about you, please contact us at [email protected] to request deletion. We will respond to your request within a reasonable timeframe. 
12.5 Verification of Identity. To request access, corrections, or updates to your Personal Information, including information not available through your account, please contact us as specified in this privacy policy. We may require certain Personal Information to verify the identity of the individual seeking access to their records. 
B. Additional Details

1. Public Content and Social Media 

Fynlo may have public forums and blogs. Any information submitted there may be read and collected by anyone. You may request removal of Personal Information from forum or blog posts and comments by contacting us at [email protected]

If you provide us with a testimonial, with your consent we may post it on our Site or in other materials and media, along with your name. If you want your testimonial removed, please contact us at [email protected]
You may engage with us through social media sites. When you engage with us on these sites, we may have access to certain information about your account (e.g., name, username). These sites may collect your IP address, how you’re engaging with us, and may use cookies to enable the site to function properly. We may use this information to personalize your experience and to provide you with other products or services you may request. 
 

2. Additional Information on Service Providers 

We may use service providers to verify the bank account information you provide to us in providing our services to you. 
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Plaid. Fynlo uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using our service, you grant Fynlo and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy. 
 
We may also use services provided by third-party platforms (such as social networking sites) to serve targeted ads on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the sharing of your information with such platforms, please send an email to [email protected]

3. California Consumer Privacy Act 
California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the privacy notice. 

Categories of Personal Information Collected and Disclosed. 

 California law requires organizations to disclose whether certain categories of personal information are collected, disclosed for an organization’s “business purpose”, or “sold” and/or “shared” for purposes of cross-context behavioral advertising (as those terms are defined under California law). We may collect, share, and disclose personal information that is subject to the Gramm-Leach-Bliley Act and other federal laws. Such information is not subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “California Privacy Law”). In addition, we may have collected, shared, and disclosed personal information in various contexts that may be subject to California Privacy Law, which is reflected in the table below. Please note that the following table is comprehensive, and we collect different information about people based on their relationships and interactions with us. 

Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect to government entities, as may be needed to comply with law or prevent illegal activity, or professional services organizations, such as auditors and law firms. We do not “sell” your personal information for money. As discussed elsewhere in this privacy notice, we use cookies and similar tracking technologies for purposes of targeted advertising. The types of information that you can access and update may change over time. Remember, some of the information we collect does not identify you personally or is not stored in an online accessible format and thus, may not be accessible through your Fynlo account. For more information, please see Section B.7. 

California Sensitive Information Disclosure.   Some of the personal information we collect is considered “sensitive personal information” under California law. We collect the following categories of sensitive personal information (as defined under California law): Social security, driver’s license, state identification card, or passport number; and account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with products and services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.  

Your Privacy Rights. 

 If you are a California resident, you may have the following rights over your information: For the period covering the twelve (12) months preceding your request, you may request that we disclose to you the categories and specific pieces of information collected about you, as well as certain information about our collection and use of your personal information. You may request that we delete the information we collected from you, subject to certain exceptions. You may request that we correct inaccuracies in the personal information that we maintain about you. You may opt out of the sharing of your personal information for purposes of cross-context behavioral advertising. You have the right not to be discriminated against for exercising your rights over your information. 

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. You, or an authorized agent acting on your behalf, may submit a request to exercise your rights by contacting [email protected]. We will collect Personal Information from you, such as your name, address, state of residence, email address, phone number, last four (4) digits of your social insurance number or social security number, and your birth year, to verify your identity in order to process your request. To have an authorized agent submit a data subject access request on your behalf, we require you to submit a form that verifies your identity and that you have authorized the agent to act on your behalf. Government identification may be required. 
 
To prevent online tracking based targeted advertising (e.g., cookies), opt out of social media and targeting/advertising cookies in the prompt presented to you in our cookie banner. You may change your cookie setting preferences by clicking on “Cookies Settings”. 

California Notice of Financial Incentive.  We offer certain programs, such as our referral program, that provides financial rewards to those of our customers who have elected to participate (the “Program”). When you apply for and have been accepted into the Program, we typically ask you to provide your name and contact information (such as your email address), as well as the contact information for individuals you will refer to us. Under California law, our Program might be interpreted as a “financial incentive” program as it involves the collection of personal information. We do not assign a monetary value to the information we collect. Based on our reasonable estimate, the value of the personal information you provide to us is related to the value of the referral provided and commission paid through the Program. This value is based on the expense related to offering those free or discounted products or services. You or any person you refer to us may withdraw from participating in the Program at any time by contacting us at [email protected]

4. General Data Protection Regulation 

We process your Personal Information to provide the products and services you request and for our legitimate business interests, including marketing. Our services are hosted on servers located in the United States. We also use service providers located in the United States to provide you with our services. The transfer of your Personal Information, and the information you input into our services to the United States is necessary to deliver our services. Please be aware that the laws in the United States may not provide the same level of protection to your personal information as your home country. 

If you are accessing our services from the European Union, you may have certain rights regarding the processing of your Personal Information. For instance, if the information you provide contains special categories of personal data, we will only process it with your explicit consent, which can be withdrawn at any time. You may have the following additional rights:  
 
You have the right to access and correct your information.  
You have the right to obtain erasure of your information, object to or restrict processing activities related to your information, or withdraw your consent to the processing of your information after you have provided it.  
You have the right to obtain a copy of your information in a structured, commonly used, machine readable format.  
You have the right to lodge a complaint with your local supervisory authority regarding our processing of your information. 
To exercise your rights, or if you otherwise have questions about the processing of your personal data, you may contact us at [email protected]
 

5. Brazil 

If you are accessing our products or services from Brazil, you have certain rights regarding the processing of your personal information. You have the right: 
 
To confirm if we are processing your information; 
To access your data; to correct incomplete, inaccurate or out-of-date data;  
To anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with Brazilian law;  
To the portability of data to another service or product provider, by means of an express request;  
To delete personal data processed with the consent of the data subject;  
To information about public and private entities with which the controller has shared data;  
To information about the possibility of denying consent and the consequences of such denial;  
And to revoke consent. 
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To exercise your rights, or if you otherwise have questions about the processing of your personal data, you may contact us at [email protected]
 

6. Visiting the Site  In general, you can visit the Site without telling us who you are or submitting any Personal Information. However, we collect certain information and usage data whenever you interact with us, whether online, through a mobile application, or through email. We and/or our service providers (such as Google Analytics) collect which websites you visit, what you click on, when you performed those activities, your IP (Internet protocol) addresses from all visitors to the Site and other related information such as page requests, browser type, operating system, and average time spent on our Site.  
7. Use of Web and Wireless Technologies (including Cookies, Tags, and Web Beacons)  We, and our service providers, use commonly used technologies, such as cookies or similar technologies, to remember you and to personalize your experience with features and advertisements. We, and our service providers, use these technologies to help us know your usage patterns, track your preferences, analyze how you use our services, administer the website and mobile application, and gather demographic information about our user base, as a whole. We may receive reports on an individual or aggregate basis based on these technologies. You may opt-out of some of these technologies. 

Cookies.

Cookies are small alphanumeric identifiers that a web server transfers to your computer or mobile device via your Internet browser. When your Internet browser visits a web page, a cookie is set with a unique number. This number is recorded in a small text file that is transmitted to your computer or mobile device and stored in the cookie directory of your hard drive. Then, when you visit each web page or component of our service or mobile application on which the cookie technology is enabled, the website or mobile application can recognize your browser as a unique user. 
 


The purpose of cookies is to make your experience more convenient and personal. For example, knowing what products interest you, helps us tailor your experience to meet your needs. We also have service providers that use cookies on our website to facilitate measurement and reporting. We also use cookies for session tracking to make it possible to navigate the secure environment inside our website and application. These cookies (1) may let us know who you are, (2) are necessary to access your account, and (3) will give us information that we can use to personalize our website and application according to your preferences. You can control the use of cookies in your browser. If you disable cookies, you will not be able to access your account or take advantage of all of the features of the website and application. 
 


We, or service providers acting on our behalf may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests. 
 


To opt out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit the Digital Advertising Alliance (DAA)’s self-regulatory opt-out page, the Digital Advertising Alliance of Canada’s self-regulatory opt-out page, the mobile application-based AppChoices download page, the European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page, or the Network Advertising Initiative (NAI)’s self-regulatory opt-out page. 
 


You may adjust your browser settings to accept or deny all cookies, or to request your permission each time a site attempts to set a cookie. Although cookies are not required for some parts of our services, our services may not work properly if you disable cookies entirely. Clearing cookies from your web browser may revoke a prior opt-out you have selected.

Local Storage Objects HTML5.  We, and third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity, use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. 
Clear GIFs or Web Beacons.  We employ a software technology called clear GIFs (also known as pixel tags or web beacons), that help us better manage content on our websites by allowing us to understand usage patterns, fix issues, and improve the products and services offered to you on our websites. We may use clear GIFs in our emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. These activities may be performed by us or a service provider acting on our behalf. 
Log Files.  Like most websites, we use log files. Information collected in log files may include IP addresses, unique device IDs, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the site or mobile application, track user movement in the aggregate, and gather broad demographic information for aggregate use. 
Traffic Data.  We collect information relating to traffic on our website. We may collect and record information on pages visited, mouse movements and clicks, scrolling activity, keystroke data that you voluntarily enter on our website, HTML data on a page visited, IP address or information your browser provides to our web server, such as browser type, operating system, average time spent on our website or mobile application, language, screen resolution, referring URL, etc. Our collection of website traffic information is anonymized and does not include personally identifiable information. We utilize this data to improve our website and the products and services offered to you. 
Online Behavioral Advertising.  We allow third-party companies, such as Google Ads, to serve ads and collect certain pseudonymous information when you visit our websites. These companies may use this information (e.g., clickstream information, browser information, time and date, device ID, geo-location, IP address, or subject of advertisements clicked or scrolled over), during your visits to our websites in order to provide advertisements about goods and services likely to be of interest to you and to enhance your consumer experience across the different devices that you use. These companies typically use a cookie or third-party web beacon to collect this information. We may engage different providers to provide similar services from time to time. To opt out of this type of advertising you may refuse to accept cookies or by visiting the Network Advertising Initiative’s opt-out page. The options you select are browser and device specific. You may also opt out of this kind of advertising by adjusting the browser settings on your device. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. 
Mobile Device Information.  We may record data from your mobile device such as Apple IDFA, device brand and model, general characteristics of your device, and other device IDs. 
‍Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application. 

How do we respond to web browser “do not track” signals? 

We treat the Personal Information of everyone who comes to our Site in accordance with this privacy policy, whatever their “do not track” setting. While we do not respond to web browser “do not track” signals, we give you choices about receiving promotional offers from us or third parties. You can exercise your choices as described in this privacy policy.

If you are located in California, you may prevent us from storing cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts by declining cookies in the cookie banner presented to you when you visit our website. 

8. Notification of Privacy Policy Changes 
We may update this privacy policy to reflect changes to our information practices. If we make a material change to this privacy policy, including a material change in the way we use any Personal Information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our website at least 30 days prior to the change becoming effective. We encourage you to periodically review our privacy policy for the latest information on our privacy practices. 

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