Effective Date: July 1, 2020
TABLE OF CONTENTS
COLLECTION OF YOUR INFORMATION
Registration, account, and sign-up information. We may collect Information in the course of your use of, or registration with, our Sites and/or Gigafin Mobile App. For example, when you create an account, register for or download our Gigafin Mobile App, or sign-up for a product or service that we offer, you may provide us with certain personal information. This type of personal information may include your name, phone number, postal address, fax number, email address, or certain payment information (e.g., credit card and billing information). We may also receive Information about your interest in and use of various products, programs, services, and content available on or through our Sites and Gigafin Mobile App.
Mobile device data. Information about you that we derive (a) from your mobile device or computer such as your device type, machine or mobile device identification number, model and manufacturer, version of your operating system, phone number, country, location, Geolocation Information (as defined below),time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes.
Personal Data. Information such as your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers). Also demographic (e.g., age, race, gender), psychographic (e.g., lifestyle, attitudes, political opinions, trade union membership, activities and interests) and other personal information that you voluntarily give to us when choosing to participate in various activities related to the Sites and/or Gigafin Mobile App, such as chat, posting messages in comment sections or in our community forums, liking posts, sending feedback, and responding to surveys.If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Sites and/or Gigafin Mobile App, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Sites and/or the Gigafin Mobile App servers.
Derivative Data.Information our servers automatically collect when you access the Sites and/or the Gigafin Mobile App, such as your native actions that are integral to the Sites and/or Gigafin Mobile App, including liking, re-blogging, or replying to a post, as well as other interactions with the Sites and/or Gigafin Mobile App and other users via server log files.
Facebook Permissions. If you authorize Facebook Connect, the plug in allows us access to your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
Geolocation Information. Information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We may request access or permission to track Geolocation Information from your mobile device, either continuously or while you are using the Gigafin Mobile App, to provide you with location-based Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. In addition, some of our Services may ask you for permission to share your current location with other Gigafin Mobile App users within your device settings to enhance our Services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, sensors, SMS messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Push Notifications. We may request to send you push notifications regarding any of your Site accounts or Gigafin Mobile App account or the Gigafin Mobile App in general. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Third-Party Data. Information from third parties, such as personal information or network or community friends, if you connect your account to the third party and grant the Gigafin Mobile App permission to access this information.
Data from Contests, Rewards and Surveys.Personal and other information you may provide us when entering contests, claiming and collecting rewards provided to you by us and/or responding to surveys.
We are committed to providing a safe, secure and outstanding service. Therefore, before
permitting you to use the Services, we may require additional information from you that we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.
When you are using the Services, we collect information about your Gigafin Mobile App account transactions, and we may collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically
described here. For example, we may collect information related to your contact with other users of the Gigafin Mobile App or our customer support team.
INFORMATION FROM MINORS
The Services are not directed to persons under the age of 18, and therefore we do not knowingly solicit information from or market to minors. If we obtain actual knowledge that we have collected personal information from a minor, we will promptly delete it, unless we are legally obligated to retain such data. If you become aware of any data we have collected from a person under the age of 18, please contact us using the contact information provided below.
SECURITY OF YOUR INFORMATION
We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
We strive to ensure security on our systems, and while we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our best efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.Any information disclosed online is vulnerable to interception and misuse by unauthorized parties.Therefore, we cannot guarantee complete security if you provide personal information.
If we learn of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that we may communicate with you electronically. We may post a notice on the Sites or send you a push notification or a Gigafin in-app message on your mobile device if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at [email protected].
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience with our Sites and our Gigafin Mobile App.Specifically, we may use information collected about you via the Sites or the Gigafin Mobile App to:
- create and manage your Gigafin Mobile App account;
- provide the Services and customer support you request;
- generate a personal profile about you to make future visits to the Sites and/or the Gigafin Mobile App more personalized;
- process transactions and send notices about your transactions or your Gigafin Mobile App activity;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent potentially fraudulent, prohibited or illegal activities, and enforce our Gigafin Mobile App End User License Agreement and our Mobile App/Website Terms and Conditions through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
- create an account connection between your Gigafin Mobile App account and a third-party account or platform;
- administer loyalty and rewards programs, sweepstakes, promotions, and contests;
- compile anonymous statistical data and analysis for use internally or with third parties;
- deliver targeted rewards, coupons, written and video content, and other information relating to the Sites and Gigafin Mobile App to you;
- email you regarding your Gigafin Mobile App account;
- enable user-to-user communications;
- increase the efficiency and operation of the Sites and the Gigafin Mobile App;
- monitor and analyze usage and trends to improve your experience with the Sites and the Gigafin Mobile App;
- notify you of updates to the Sites and the Gigafin Mobile App; and
- request feedback and contact you about your use of the Sites and the Gigafin Mobile App.
HOW WE SHARE YOUR PERSONAL INFORMATION WITH OTHER PARTIES
We do not share your personal information with third parties for their promotional or
marketing purposes. We do not sell your personal information for money. Some personal information is public information (including your Gigafin Mobile App username, profile photo, profile first and last name, month and year of account creation), and may be seen by anyone on the internet, whether or not they have a Gigafin Mobile App account. Public information may also be seen, accessed, reshared or downloaded through our APIs or third-party services that integrate with our Services.
We may share your personal information as follows:
Third-Party Service Providers. We may share your personal information with third parties that we contract with who help with parts of our business operations (for example, fraud prevention, payment processing, customer service or technology services). Our contracts with third-party service providers dictate that they t only use your personal information in connection with the services they perform for us and not for their own benefit.
Other Third Parties. We may share your Information with other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
- Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection. For example, personal information that we share with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the third-party’s account or platform privacy practices.
Marketing Communications. With your consent, or with an opportunity for you to withdraw consent, we may share your personal information with unaffiliated third parties for marketing purposes, as permitted by law.
If you wish to withdraw your consent or opt-out of our sharing your personal information with unaffiliated third parties for the third parties’ direct marketing purposes, you may do so under certain circumstances by sending us a request to do so (along with your full name, email address, postal codes, and the subject line labeled “Opt-Out of Sharing Personal Information with Third-Party Marketers”) by regular U.S. mail or by email as follows:
Interactions with Other Users. If you interact with other users of the Sites and/or the Gigafin Mobile App, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts and following blogs.
Online Postings. When you post comments, contributions or other content to the Sites or the Gigafin Mobile App, your posts may be viewed by all users and may be publicly distributed outside the Sites and Gigafin Mobile App in perpetuity.
Third-Party Advertisers.We may use third-party advertising companies to serve ads when you visit the Sites and/or use the Gigafin Mobile App. These companies may use information about your visits to the Sites or your use of the Gigafin Mobile App and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
Change of control. We may transfer your personal information in the event of a business transaction, such as if we or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.
CONTROLS FOR DO-NOT-TRACK FEATURES
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
To access the personal information that we have collected about you online from the Sites and/or the Gigafin Mobile App, or to update your user profile, please log into your account if you have created one with us, or send an email to [email protected]. For California residents, please see below for additional information on accessing information about you.
CALIFORNIA PRIVACY RIGHTS
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your California Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected California Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use California Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Time to Your Verifiable Consumer Request and Format of the Information to be Provided to You. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account or by mail or email, at your option. If you do not have an account with us, we will deliver our written response by either mail or email, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your California Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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 tell you why we made that decision and provide you with a cost estimate before completing your request.
MobilityPay Holdings, Inc.
Attention:Chief of Staff
28126 Peacock Ridge Drive, #210
Rancho Palos Verdes, CA 90275