The following policy applies to prospective member sand members doing business in and regulated by U.S. market regulators.
Personal Data. When you interact with our Services, contact us, or become a user, we collect information you voluntarily give us that alone or in combination with other information could be used to identify you. This includes for instance, your name, contact information (including postal address, email address, phone number), username, password, social security number, tax identification number, bank account information, other financial information related to accredited investor status and wire transfer instructions, as well as any other information you provide to us, including but not limited to, by joining our mailing list or seeking to become a member. For purposes of this Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a member or a member representative. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
When you visit, use, and interact with the Site, we may receive certain information about your visit, use or interactions with the Site. For example, we may monitor the number of people that visit our Site, peak hours of visits, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Chrome, etc.), broad geographical information, and Site-navigation patterns. The types of information we collect depends on the type of device used and its settings.
We may also collect personal data from third parties, such as parties that interact with us, including other financial institutions, product sponsors, business partners and contacts, service providers, background check companies, recruiters or referral sources, subscription information or analytic services, public sources, government records and sources, and other parties that interact with us or store information on our systems.
In particular, in the past twelve (12) months, we may have collected and disclosed the following categories of personal data for business purposes to our third-party service providers, our affiliates and business partners, and regulators/government agencies. We may also continue to collect these categories of Personal Data.
Address and other identifiers
Name, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Characteristics of protected classifications
Age, gender, and marital status
Unique and online identifiers
IP address, device IDs, browsing history, search history, and information on consumer’s interaction with a website
Internet or other electronic network activity information
Browsing history, search history, settings, and information regarding an individual’s interaction with an internet website, application, or advertisement, device information, including name of device and operating system, cookies and pixel tags, city of login, and other data that your browser automatically sends
Audio or video footage or other visual information
Visual copy of Government Issued ID
Professional or Employment Information
The table includes examples in each category, but these examples are not exclusive. In addition, we may draw inferences about you or the entity you represent based on the information provided, such as individual preferences or characteristics, and we may collect and use information as described when collecting the information. We may also receive Personal Data that individuals provide to use or store on our system.
Cookies. In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. In order to personalize your use of the Site, we may use local shared objects, also known as Flash cookies, to display content based upon what you view. Flash cookies are different from browser cookies (discussed above) because of the amount and type of information they generate, and how they store that information. Cookie management tools provided by your browser will not remove Flash cookies. When you visit the Site or view one of our emails, we may use pixel tags or “clear” gifs to track links and/or similar technology to note some of the pages you visit on our Site and to personalize your experience. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.
In the past twelve (12) months, we may have collected and used Personal Data for the following purposes;
To process and facilitate transactions and maintain accounts.
To operate, maintain, and improve the Site, products, and services. This includes use of personal and other information to support delivery of our services under contract, assist with service requests, monitor for errors, remedy security or technical issues, and analyze website and application performances.
To communicate with you, respond to comments and questions, verify permission access, and provide customer service.
To send information including confirmations, technical notices, updates, security alerts, and administrative messages.
To communicate system updates, upcoming events, and other news and information about products and services offered by us. For instance, we may contact you to inform you about important services-related notices, such as privacy and policy updates or changes in our terms of service.
For statistical and business operations and planning purposes.
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
To improve, provide, and deliver products and services.
We may also continue to collect and use Personal Data for these purposes.
We do not sell personal information and in, the preceding twelve (12) months, we have not sold any personal information to any other entity.
We may aggregate the information that we collect and use such aggregated data for commercial, statistical, and market research purposes, including sharing it with affiliates, third parties and business partners. This data may include location information derived from your IP address or mobile device.
We do not share your Personal Data outside of ReFlow except in following circumstances:
Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy, or similar event, Personal Data may be part of the transferred assets and may otherwise be shared with business partners and non-affiliates for the purposes of carrying out transactions.
Affiliates, Non-Affiliates and Business Partners. We may also share your Personal Data with our affiliates and non-affiliates and our business partners for business purposes, including the processing of consumer transactions.
Agent, Consultants, Vendors, and Service Providers. Like many businesses, we sometimes hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments.
Legal Requirements. We may also disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) protect against legal liability.
You can contact us at 866-473-3569 or firstname.lastname@example.org to do the following at anytime:
See what data you provided through the Services, if any. Change/Correct any data you provided through the Services. Express any concern you have about our use of your data. Request we delete your data.
California residents may request information regarding the types of personally identifiable information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. As noted above, we do not provide Personal Data to third parties for their direct marketing purposes.
Access Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request access to certain information about the Personal Data we collect about you. In particular, these individuals have a right to request that we provide the following information:
The categories of Personal Data that ReFlow or Provenance has collected about you.
The categories of sources from which ReFlow or Provenance collected the Personal Data.
The business or commercial purposes for which ReFlow or Provenance collected and/or sold the Personal Data.
The categories of any third parties with which ReFlow or Provenance shared the Personal Data.
The specific pieces of Personal Data Provenance collected over the past year.
The categories of Personal Data, if any, ReFlow or Provenance has sold about you, categories of third parties to which ReFlow or Provenance sold that Personal Data, and the categories of Personal Data sold to each type of third party.
The categories of Personal Data that we have disclosed for a business purpose.
Our responses to such requests will cover the 12-month period preceding our receipt of the request.
To request access to this information, you may contact ReFlow at 866-473-3569 or email us your request via email@example.com. You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and your relationship with ReFlow. You may also designate an agent to submit a request on your behalf. We will likewise need to verify the agent.
Deletion Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request that we delete certain personal information from our records, subject to certain exceptions. We are not required to delete information that is necessary for us to: complete the transaction for which we collected the information; provide you with a good or service you requested; perform a contract Provenance entered into with you; detect security incidents; maintain the functionality or security of ReFlow’s systems; comply with or exercise rights provided by law; or the use of information internally in ways that are comparable with the context in which you provided the information to ReFlow or that are reasonably aligned with expectations based on your relationship with ReFlow, among other things. We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies.
To submit a deletion request, you may contact ReFlow at 866-473-3569 or email us your request via firstname.lastname@example.org. You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and relationship with ReFlow.
We will respond to requests for access or deletion as soon as practicable and in any event generally not more than within 45 days after receipt of your request. We may extend this period to 90 days in some cases.
Accessibility. We are committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this policy in alternative formats by contacting us at the address, phone, or email address below.
This website is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us by either:
Calling us at 866-473-3569
Emailing us at email@example.com
DO NOT TRACK SIGNALS
You use the Services at your own risk. We use reasonable precautions, including technical and administrative measures, to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent toor from us in connection with the Services may not be secure. Therefore, you should take special care in deciding what information you send to us.
Because we are based in the United States, if you use our Site or Services from outside the United States your information will be transferred to the United States. By using our Site, products and services, you consent to the collection, international transfer, storage and processing of your information. If it is illegal to access our Site or transfer your data to the United States, please do not use our Sites.