PRIVACY NOTICE
StreetFins (“we” or “us”), as a subsidiary of Peersdom, LLC, values our relationship with you and takes your privacy seriously. The purpose of this Privacy Notice is to identify how we may process, collect, store, share and use (collectively, “use”) the data that we collect from you in connection with your use of our application and related software and services (collectively, our “Application”). This Privacy Notice also identifies your rights with respect to your personal information, all as described in more detail below.
We may update or modify this Privacy Notice at any time, by posting the amended version including the effective date of the updated version. We will announce any material changes to this Privacy Notice by posting the amended version on our website and providing a notification upon login to our Application. By accessing and/or using our Application, you accept and agree to the terms of this Privacy Notice and the use of your data and personal information as described in this Privacy Notice. If you do not agree to be bound by this Privacy Notice or any subsequent modifications, you should not access or use our Application or disclose any personal information through any of our Application.
This Privacy Notice was last updated July 7, 2020.
Your privacy and the security of your personal information is, and will always be, important to us. We want to transparently explain how and why we gather, store, share, and use your personal information, as well as outline the controls and choices you have around when and how you choose to share personal information.
This Privacy Notice contains the following information, which you can access by scrolling down, which you can access by scrolling down:
- How to contact us.
- The information we collect about you.
- How we may use your information.
- Who we may share your information with.
- Your rights and options regarding your personal information.
- How we safeguard your personal information.
- How long we store your personal information.
- Links.
- Children.
- Special notice to non-U.S. users regarding data transfers.
- Governing law and jurisdiction.
1. How to contact us.
How to contact us and update your preferences and/or information:
You can update your preferences and information in the following ways by: updating your contact information in your profile or account through our Application; managing push notifications on your mobile device through preferences in the application or device settings; or contacting us at the e-mail or postal address below.
Additionally, if you have any questions or concerns about our use of your personal information, please do not hesitate to contact us through any of the methods listed below.
Phone: 925-202-4359
Email: streetfins@gmail.com
2. The information we collect about you.
Information we collect.
We obtain information about you and your use of our Service when you register a user account with us, or sign up to receive communications from us. The information we collect can include personal information (as described below) or non-personal information, which is information that does not identify or relate to an individual.
Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect information through any correspondence that you provide to us whether through email, mail, phone calls, or through our Application. Information that you provide might include, but is not limited to, the following: (a) first and last names; (b) demographic information; (c) mailing address; (d) email address; (e) phone number; (f) credit card number; (g) educational information; and (h) other information that personally identifies you.
We do not consider personal information to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
When and how do we collect your information?
We collect information from you both when you provide it voluntarily and also automatically when you use our Application. Most of the personal information we receive relates to your use and participation in our Application.
In some instances, we automatically collect certain types of information when you use our Application or correspond with us. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons.
For more information about the information we collect, read on below.
What information do we collect from you?
| Information collected through use of our Application |
| Categories of Information | Description of category |
| Account Registration Information | This is the personal information that is provided by you or collected by us to enable you to login and access your account and our Application. This includes your name, email address, phone number, and educational information. Some of the personal information we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal information in order to make your account more personalized. |
| Application Usage Information | This can be personal information and non-personal information that is collected about you when you are using our Application, and this may include: Information about your interactions with our Application, which includes the data and time of any information you enter into our Application, and your interactions with other users of our Application.User content you post to our Application including messages you send and/or receive through our Application and your interactions with our customer service team. Technical data which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our Application, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system. Further details about the technical data that is processed by us can be found below.Our Application uses cookies, unique identifiers and similar technologies to collect information about the pages you view, our Application functions that you access, the buttons and icons you click, and to remember your login information and Application settings to make it easier and more efficient for you to use our Application.Cookies. Cookies are small data files that are downloaded onto your computer or mobile device when you use our Application, which are unique to your device or account. Cookies make it easier for you to use our Application by saving your preferences so that we can use these to improve your next and subsequent visits to our Application – for example, remembering your login information. Cookies help us learn which areas of our Application are useful and which areas need improvement. Cookies may be either persistent or temporary (or session) cookies. A persistent cookie retains user preferences for a particular website, app or service, allowing those preferences to be used in future use sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.You can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable this function, your experience with our Application may be impaired and some features may not work as they were intended. When we use cookies or other similar technologies, we may set the cookies ourselves or ask third parties to do so to help us. Pixels, Web Beacons. We or third party partners may use invisible pixels or beacons on our Application to count how many users access or use certain pages, features or content. This information is collected and reported in the aggregate. We may use this information to improve our current Application offerings, develop new products or services, and target information to you that may be helpful and useful to you based upon your use of our Application.
|
| Anonymized Information | We use anonymized and aggregated information that may be created or derived from your personal information or usage of our Application for purposes that include data analysis, improving our Application, advertising, and developing new features and functionality within our Application. |
3. How we may use your information.
We will only use your information for the purposes identified below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here.
In the table below, we have set out the reasons why we process your information, the associated legal basis we rely upon to legally permit us to process your information, and the categories of information (identified in “The information we collect about you” above) used for these purposes:
| Why we process your information | Legal basis for the processing purpose | Categories of information we use for the processing purpose |
| To provide our Application and services to you. | Legitimate interest | Account Registration Information, Application Usage Information, Anonymized Information |
| To personalize and improve your experience with our Service, for example by providing customized or localized content, recommendations, support, and features through our Application. | Legitimate interest | Account Registration Information, Application Usage Information, Anonymized Information |
| To ensure technical functionality and proper operation of our Application, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience. | Legitimate interest |
Application Usage Information |
| To monitor the security of our Application and prevent and/or investigate security breaches or other potentially prohibited activities. | Legitimate interest |
Application Usage Information |
| To improve our Application and services and develop new products and services, for example by reviewing your access to and use of our Application, including your interactions with applications or functionality made available, linked to, or offered through, our Application to learn what is most valuable and helpful to you. | Legitimate interest |
Application Usage InformationAnonymized Information |
| To communicate with you for Application and service-related purposes, such as regarding support issues, password retrieval, and guides and information about your Application account. | Legitimate interest | Account Registration InformationApplication Usage Information |
| To communicate with you, either directly or through one of our service providers, for the following purposes: marketing, research, or other promotional purposes, via email, notifications or other messages, consistent with any permissions you may have communicated to us. | ConsentLegitimate Interest |
Application Usage InformationAccount Registration Information |
| We may use information about your use of our Application, including pages viewed, length of user session, and content accessed, in order to compile overall statistics about how users interact with our Application and content they find useful in order to enable us to analyze how our Application is being used and how we can improve them. | Legitimate Interest | Application Usage Information |
| For us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using user data in the aggregate to assess our obligations under applicable data security and privacy requirements) | Legal obligations | Account Registration InformationApplication Usage InformationAnonymized Information |
Legitimate Interests
Where we rely on legitimate interests as the reason for processing your information, we carry out a balancing exercise to make sure your rights as an individual are not impacted unnecessarily.
We consider that it is reasonable for us to process your personal information for the purposes of our legitimate interests when, on balance, (a) we process your personal information only so far as is necessary for such purpose, and your rights and freedoms do not outweigh such purposes, and (b) it can be reasonably expected for us to process your personal information in this way. In most cases, the information is being processed for your benefit as well as ours.
We have a legitimate business interest in processing your personal information where:
- We need the information to respond to your inquiries;
- We need the information to send you information; or
- We would be unable to provide our Application without processing your information.
If we wish to process your existing information for a new purpose other than as stated above, we must inform you of that further processing and provide information surrounding your information’s use.
4. Who we may share your information with.
In connection with our Application, we may share your personal information with the following types of recipients and for the following reasons:
| Categories of Recipients | Reasons for sharing |
| Service providers | We use service providers to operate our software and infrastructure, in particular providers which host, store, manage, and maintain our Application, its content and the data we process. This includes our email marketing, text messaging component for our Application, and information security service providers. |
| Your school | We may share your personal information with your school (or any organization on whose behalf you are accessing and using our Application) to aid such organizations in their business operations and decision making, which may include monitoring and analyzing your use of our Application. |
| Participants in our data sharing agreements | We may share your personal information with participants that have executed data sharing agreements with us for purposes of business development, and research and analytics. |
| Data analytics providers | We will share your personal information to create general data analytics regarding usage of our Application on an aggregate basis and without personal identifiers. For example, we use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with our Application. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. |
| Law enforcement and government authorities | We will share your personal information with third parties where required by law (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with our Application or where we have another legitimate interest in doing so. |
| Other legal or regulatory authorities | We will share your personal information for us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using user purchases in the aggregate, including revenues generated in connection with our regulatory tax requirements). |
| Buyer or successor of our business | We will share your personal information with any buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of title. |
Most, if not all, of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States.
5. Your rights and options regarding your personal information.
You have choices about how we use your personal information to communicate with you, send you marketing information, and whether you want to stay signed into your account. You can opt out from receiving future marketing communications from us at any time by:
- Using the unsubscribe function in the email you receive from us; or
- Contacting us as set forth under “How to contact us” above.
In addition, as noted above in “The information we collect about you,” you can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Application may be impaired and some features may not work as they were intended.
You may select a “do not track” setting on your web browser. However, these features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Notice.
Depending on where you live, you may have the following rights with respect to your data under certain circumstances, which may include the following:
- The right to request access to your personal information and the following information regarding our use of your personal information:
- The purpose of such use
- The categories of your personal information that we have used
- Who we have disclosed your personal information to
- The right to request us to erase your personal information when we no longer need such data in connection with our Application.
- The right to request us to correct any inaccurate personal information concerning you. You may also update or change your information under your account settings.
- The right to withdraw consent to our use of personal information, if we are relying on consent to use your personal information.
- The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
- The right to object to our use of your personal information where we are not using it to perform Application you have requested from us.
- The right to receive a copy of your personal information.
- The right to lodge a complaint with the supervising authority of your country.
If you want to exercise any of the rights listed above and you are a resident of a jurisdiction providing you such rights (as of May 25, 2018, residents of the European Economic Area, and effective January 1, 2020, residents of California for the first two rights listed above), please contact us through one of the methods listed in under “How to contact us” above.
6. How we safeguard your personal information.
We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Third parties we engage in our business who may have access to your personal information will only process your personal information on our instructions and they are required to only use your data as necessary to perform their contract with us.
While we are committed to protecting your personal information, please note that information communicated over the Internet is never 100% secure. Any transmission of personal information is at your own risk.
7. How long we store your personal information.
We may store your personal information as long as you use our Application and for legitimate business purposes.
We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements. Additionally, we may continue to store your personal information contained in our standard back-ups.
Upon your request, we will delete or de-identify your personal information unless we are legally required or allowed to maintain such personal information.
8. Links.
Our Application may provide links to third-party websites that we do not control. We cannot be held responsible for third parties’ privacy practices or content provided on these websites. If you click on one of these links, please understand that you are leaving our Application and any information you provide will not be covered by this Privacy Notice. Please read that website’s privacy policy before providing any information.
9. Children.
Our Service is not directed to children under the age of fourteen (14) years. By using our Application, you represent that you are at least fourteen (14) years old. If you do not meet this age requirement, then you must not access or use our Application. If you are under 14, you may continue to use the Application without creating an account.
We do not knowingly collect information from children under the age of thirteen (13) years old. If you are under the age of thirteen (13) years old, please do not use our Application and do not provide any information to us. For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.
If you think we have collected information from a child under the age of thirteen (13) through our Application, please contact us through one of the methods listed under “How to contact us” above. If we learn that we have collected the information of a child under the age of thirteen (13) years old, we will take reasonable steps to delete such information.
10. Special notice to non-U.S. users regarding data transfers.
We store your personal information in the United States or other locations outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.
If you are located in a country outside the U.S. and submit personal information to us, you consent to the general use and disclosure of such information as provided in this Privacy Notice and to the transfer and/or storage of that information to the U.S. and other countries outside your home country.
11. Governing law and jurisdiction.
This Privacy Notice shall be construed and governed under the laws of the United States and State of California (without regard to rules governing conflicts of laws provisions). You agree that venue for all actions, arising out of or relating in any way to your use of our Application, shall be in federal or state court of competent jurisdiction located in Alameda County, within one (1) year after the claim arises. Each party waives any objections based on forum non conveniens and waives any objection to venue of any action instituted hereunder to the extent that an action is brought in the courts identified above.
25811709.2
