THIS IS A WEBSITE PRIVACY POLICY DRAFTED
UNDER U.S. LAW. THIS POLICY IS NOT INTENDED TO SATISFY ANY ‘FAIR PROCESSING
NOTICE' OBLIGATIONS THAT YOU MAY HAVE UNDER GDPR OR OTHER
APPLICABLE NON-US LAW.
In this
Privacy Policy ("Policy”), we describe how Hydrogen ("Company”) collects, uses, and discloses
information that we obtain about visitors to our website https://www.hydrogenplatform.com
(the "Site”), users of our mobile Application and the
services available through our Site (collectively, the "Services”).
By visiting
the Site, using or downloading the Applications, or using any of our Services,
you agree that your personal information will be handled as described in
this Policy. Your use of our Site or Services, and any dispute over privacy, is
subject to this Policy and our Terms of Use,
including its applicable limitations on damages and the resolution of disputes.
The Company Terms of Use are incorporated by reference into this Policy.
The Information We Collect About You
How We Use or Disclose Your Information
How We Share Your Information
Our Use of Cookies and Other Tracking Mechanisms
Third-Party Ad Networks
User Generated Content
Third-Party Links
Security of My Personal Information
Access To My Personal Information
What Choices Do I Have Regarding Use of My Personal Information?
Special Information for California Consumers
Contact Us
The Information We Collect About
You
We may collect information about you directly from you, from
third parties, and automatically through your use of our Site or Services.
Information We Collect
Directly From You. The
information we collect from you depends on how you use our Services. To create
an account, you must provide your name, email address, phone number, country of
registration, company name, company type/vertical, and information about your
company such as EIN, number of employees, and mailing address. We also may collect additional information from you, including a description
of what you are trying to build. We use this to gather data for our CRM. If you make a purchase, we will collect your
payment information, such as your credit or debit card information, and your
billing and shipping address.
The following
is a disclosure from one of our service providers, Yodlee,
Inc., on the information they collect:
Our service is connected by Envestnet
| Yodlee. When you request
data from a source connected to our service, Yodlee,
Inc. collects that data and provides it to us. Yodlee,
Inc. acts on our behalf in this process, which means we share your data with Yodlee, Inc. as one of our service providers. For more
information on how Yodlee, Inc. collects, uses,
stores, and handles your data, please see Envestnet | Yodlee's
Commitment to its Clients and their Users (www.yodlee.com/clients-consumers).
If there is any inconsistency between Yodlee, Inc.'s
Commitment and this Privacy Policy regarding Yodlee, Inc.'s activities, then Yodlee
Inc's. Commitment is correct.
You provide log-in credentials to your
accounts at your own risk.
By using our service you agree that
the data sources that maintain your accounts and any third parties that
interact with your log-in credentials or account data in connection with our
service are not liable for any loss, theft, compromise, or misuse whatsoever in
connection with our services (including negligence), except to the extent such
liability cannot be limited under applicable law.
Data sources make no warranties of any
kind related to the data provided by our services--whether express, implied,
statutory, or otherwise. Except for PDFs of official account documents, we
retrieve on your behalf and provide to you without alteration, no data provided
by our services is an official record of any of your accounts.
Information We Collect
Automatically. We automatically collect information about your use of
our Site and Apps through cookies, web beacons, and other technologies, including
technologies designed for mobile apps. To the extent permitted by applicable
law, we combine this information with other information we collect about you,
including your personal information. Please see the section Our Use of Cookies and Other Tracking Mechanisms below for more information
Site:
· domain name;
· your browser type and operating
system;
· web pages you view on the Site;
· links you click on the Site;
· your IP address;
· the length of time you visit our Site
and or use our Services;
· the referring URL, or the webpage that
led you to our Site.
App:
· mobile device ID;
· device name and model;
· operating system type, name, and version;
· language information;
· activities within the App; and the
length of time that you are logged into our App;
· Use of location information. With your
permission, we will collect location information from your mobile device to advertise
services which may be of interest to you. You may turn off this feature through the location settings on your
mobile device.
How We Use or Disclose Your Information
We use your information,
including your personal information, for the following purposes:
· To provide our Services to you and to
fulfill your orders;
· To communicate with you about your use
of our Services, to respond to your inquiries, and for other customer service
purposes;
· To tailor the content and information
that we may send or display to you, to offer location customization, and
personalized help and instructions, and to otherwise personalize your
experiences while using the Services;
· To send you email marketing about our
products and services;
· To send you news and newsletters;
· To send you email marketing about
products and services of our affiliated entities;
· To send you email marketing about products and services of other entities that we think may be of interest to you;
· To assist us in advertising on third
party websites, mobile apps, and other online services, and to evaluate the
success of our adverting campaigns through third party channels (including our
online targeted advertising and offline promotional campaigns);
· To better understand how users access and use our Services, both on an aggregated and
individualized basis. For example, we will evaluate which features of our Site
and App are more (or least) used by users, and we will use this information;
· For research and analytics purposes;
· To administer our customer loyalty
program;
· To administer surveys and
questionnaires, such as for market research or member satisfaction purposes;
· To comply with legal obligations, as
part of our general business operations, and for other business administration
purposes;
· Where we believe necessary to
investigate, prevent or take action regarding illegal activities, suspected
fraud, situations involving potential threats to the safety of any person or
violations of our Terms of Use or this Privacy Policy.
How We Share Your Information
We may share
your information, including personal information, as follows:
· Service Providers. We disclose the information we
collect from you to service providers, contractors or agents who perform
functions on our behalf. These service providers include Marqeta, Inc., EML Payments USA, LLC, MX Technologies, Inc., Yodlee, Inc., IDology, Inc., Pathward N.A., Very Good Security, Inc., Dwolla, Inc.,
The Currency Cloud Ltd., Cross River Bank, Inc., Amazon
Web Services, HubSpot, Inc., and Sendgrid, Inc.
The following statements are disclosures from some of our
service providers:
·
During the term of this agreement Yodlee, Inc. may use an individual end user of their
service's account information, account access information and registration
information, as provided by an individual end user of their service and/or
retrieved by Yodlee, Inc. from a third-party
information source where the individual end user of their service holds an
account from which Yodlee, Inc. retrieves information
(for example: bank, broker, lender, or other financial service provider) and/or
provided by your company to solicit individual end users of their service to
provide and improve their service;
·
During and after the term of this
agreement Yodlee, Inc. may use, sell, license,
distribute, and disclose individual end user of their service's account
information, account access information and registration information, as
provided by an individual end user of their service and usage information from
which all direct and known indirect identifiers have been removed, and on which
technical, organizational and legal controls prevent employees, researchers or
other third parties from re-identifying individuals as permitted by law;
·
Yodlee, Inc. shall not use an individual end user of their service's
account information, account access information and registration information,
as provided by an individual end user of their service and/or retrieved by Yodlee, Inc. from a from a third-party information source
where the individual end user of their service holds an account from which Yodlee, Inc. retrieves information (for example: bank,
broker, lender, or other financial service provider) and/or provided by your
company to solicit individual end users of their service and/or provided by your
company to solicit individual end users of the Yodlee,
Inc. technology.
· Affiliates. We disclose the information we
collect from you to our affiliates or subsidiaries.
· Company Users. our username and any information that you post to
our Site, including, without limitation, reviews, comments, and text will be
available to, and searchable by, all users of the Site and Services.
We also disclose
information in the following circumstances:
· Business Transfers. If (i) we or our affiliates are or may be acquired
by, merged with, or invested in by another company, or (ii) if any of our
assets are or may be transferred to another company, whether as part of a
bankruptcy or insolvency proceeding or otherwise, we may transfer the
information we have collected from you to the other company. As part of the business transfer process, we
may share certain of your personal information with lenders, auditors, and
third party advisors, including attorneys and consultants.
· In Response to
Legal Process. We
disclose your information to comply with the law, a judicial proceeding, court
order, or other legal process, such as in response to a court order or a subpoena.
· To Protect Us and Others. We disclose your information when we believe it is
appropriate to do so to investigate, prevent, or take action regarding illegal
activities, suspected fraud, situations involving potential threats to the
safety of any person, violations of our Terms of Use or this Policy, or as
evidence in litigation in which we are involved.
· Aggregate and
De-Identified Information. We share aggregate, anonymized, or de-identified information about
users with third parties for marketing, advertising, research or similar purposes.
Our Use of Cookies and Other
Tracking Mechanisms
We and our
third party service providers use cookies and other tracking mechanisms to
track information about your use of our Site or Services. We may combine this
information with other personal information we collect from you (and our third
party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we
transfer to your device's hard drive through your web browser for
record-keeping purposes. Some cookies allow us to make it easier for you to
navigate our Site and Services, while others are used to enable a faster log-in
process or to allow us to track your activities at our Site and Service. There
are two types of cookies: session and persistent cookies.
· Session Cookies. Session cookies exist only during an online
session. They disappear from your device when you close your browser or turn
off your device. We use session cookies to allow our systems to uniquely
identify you during a session or while you are logged into the Site and
Services. This allows us to process your online transactions and requests and
verify your identity, after you have logged in, as you move through our Site
and Services.
· Persistent
Cookies. Persistent cookies remain on your device after you have closed your browser or
turned off your device. We use persistent cookies to track aggregate and
statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you
can edit your browser options to block them in the future. The Help portion of
the toolbar on most browsers will tell you how to prevent your computer from
accepting new cookies, how to have the browser notify you when you receive a
new cookie, or how to disable cookies altogether. Visitors to our Site and
Services who disable cookies will be able to browse certain areas of the Site,
but some features may not function.
Flash Local Storage
Objects. We may use Flash Local Storage Objects ("Flash LSOs”) to store your Site preferences
and to personalize your visit. Flash LSOs are different from browser cookies
because of the amount and type of data stored. Typically, you cannot control,
delete, or disable the acceptance of Flash LSOs through your web browser. For
more information on Flash LSOs, or to learn how to manage your settings for
Flash LSOs, go to the Adobe Flash Player Help Page, choose "Global Storage
Settings Panel” and follow the instructions. To see the Flash LSOs currently on
your computer, choose "Website Storage Settings Panel” and follow the
instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs, pixel tags
and other technologies. Clear GIFs are tiny graphics with a unique identifier,
similar in function to cookies. In contrast to cookies, which are stored on
your computer's hard drive, clear GIFs are embedded invisibly on web and app pages.
We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in
connection with our Site and Services to, among other things, track the
activities of Site visitors and app users, help us manage content, and compile
statistics about Site usage. We and our third party service providers also use
clear GIFs in HTML e-mails to our customers, to help us track e-mail response
rates, identify when our e-mails are viewed, and track whether our e-mails are
forwarded.
Third Party Analytics. We use automated devices and
applications, such as Google Analytics, to evaluate usage of our Site, and to
the extent permitted, our Apps. We also may use other analytic means to
evaluate our Site and Apps. We use these tools to help us improve our Site's
and Apps' performance and user experiences. These entities may use cookies and
other tracking technologies, such as web beacons or local storage objects
(LSOs), to perform their services. To learn more about Google's privacy
practices, please review the Google Privacy Policy at
https://www.google.com/policies/privacy/. You can also download the Google
Analytics Opt-out Browser Add-on to prevent their data from being used by
Google Analytics at https://tools.google.com/dlpage/gaoptout.
Cross-Device Use.
We and our third party service providers, including Google, may use the
information that we collect about you (whether directly from our Site, from our
mobile applications, through your device(s), or from a third party) to help us
and our third party service providers identify other devices that you use
(e.g., a mobile phone, tablet, other computer, etc.). We, and our third party
service providers also may use the cross-device use and other information we
learn about you to serve targeted advertising on your devices and to send you
emails. To opt-out of cross-device advertising, you may follow the instructions
set forth in the Third Party Ad Networks section below. Please note: if you opt-out of these targeted advertising
cookies, your opt-out will be specific to the web
browser, app, or device from which you accessed the opt-out. If you use multiple
devices or web browsers, you will need to opt-out each browser or device that
you use.
Do-Not-Track.
Currently, our systems do not recognize browser "do-not-track” requests. You
may, however, disable certain tracking as discussed in this section (e.g., by
disabling cookies); you also may opt-out of targeted advertising by following
the instructions in the Third Party Ad Network section.
Third-Party Ad Networks
We use third parties such as network advertisers to serve
advertisements on our Site, App, and on third-party websites or other media
(e.g., social networking platforms). This enables us and these third parties to
target advertisements to you for products and services in which you might be
interested. Third-party ad network providers, advertisers, sponsors and/or
traffic measurement services may use cookies, JavaScript, web beacons
(including clear GIFs), Flash LSOs and other tracking technologies to measure
the effectiveness of their ads and to personalize advertising content to you.
These third-party cookies and other technologies are governed by each third
party's specific privacy policy, not this one. We may provide these third-party
advertisers with information, including personal information, about you.
Users in the United States may opt out of many third-party
ad networks. For example, you may go to the Digital Advertising Alliance
("DAA") Consumer Choice
Page for information about opting out of interest-based advertising and
their choices regarding having information used by DAA companies. You may also
go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for
information about opting out of interest-based advertising and their choices regarding
having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page
will opt you out from those companies' delivery of interest-based content or
ads to you, but it does not mean you will no longer receive any advertising
through our Site, Services, or on other websites. You may continue to receive
advertisements, for example, based on the particular website that you are
viewing (i.e., contextually based ads). Also, if your browsers are configured
to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is
available on the DAA's website at www.aboutads.info or the NAI's website
at www.networkadvertising.org.
User Generated Content
We invite you
to post content on our Site and Services, including your comments, pictures,
and any other information that you would like to be available on our Site or
Services. If you post content to our Site or Services, all of the information
that you post will be available to all registered users on our Site. If you
post your own content on our Site or Services, your posting may become public
and Company cannot prevent such information from being used in a manner that
may violate this Policy, the law, or your personal privacy.
Third-Party Links
Our Site and Services may contain links to third-party
websites. Any access to and use of such linked websites is not governed by this
Policy, but instead is governed by the privacy policies of those third party
websites. We are not responsible for the information practices of such third
party websites.
Security of My Personal
Information
We have implemented commercially reasonable precautions to
protect the information we collect from loss, misuse, and unauthorized access,
disclosure, alteration, and destruction. Please be aware that despite our best
efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access
to your password, phone, and computer by, among other things, signing off after using a shared
computer, choosing a robust password that nobody else knows or can easily
guess, and keeping your log-in and password private. We are not responsible for
any lost, stolen, or compromised passwords or for any activity on your account
via unauthorized password activity.
Access To My Personal Information
You may
modify personal information that you have submitted by logging into your account
and updating your profile information. Please note that copies of information
that you have updated, modified or deleted may remain viewable in cached and
archived pages of the Site or Application for a period of time.
What Choices Do I Have Regarding Use of My Personal Information?
We may send
periodic promotional emails to you. You may opt-out of promotional emails by
following the opt-out instructions contained in the email. Please note that it
may take up to 10 business days for us to process opt-out requests. If you
opt-out of receiving promotional emails, we may still send you emails about
your account or any services you have requested or received from us.
Special Information for California Consumers
Additional Information for California
Residents
In this section,
we provide additional information to California residents about how we handle their personal information, as required
under California privacy laws including the California Consumer Privacy Act ("CCPA"). This section does not address or apply to
our handling of publicly available information lawfully made available by state
or federal government records or other personal information that is exempt
under the CCPA.
A.
Categories of Personal Information Under
the CCPA (Last Updated: January 1, 2021)
While our
collection, use and disclosure of personal information varies based upon our
relationship and interactions with you, in this section we describe, generally,
how we have collected and disclosed personal information about consumers in the
prior 12 months (from the Last Updated date above).
Categories and Sources of Personal Information Collected. The table below identifies, generally, the
categories of personal information (as defined by the CCPA), we have collected
about consumers. For more information about the
business or commercial purposes for which we collect and use personal
information, please see the Use of Information
section above.
|
Categories of
Personal Information
|
Description
|
|
Identifiers
|
Includes
direct identifiers, such as name, alias, user ID, username, account number or
unique personal identifier; email address, phone number, address and other
contact information; IP address and other online identifiers; SSN, driver's
license number, passport number, tax ID and other government identifiers; and
other similar identifiers.
|
|
Customer Records
|
Includes
personal information, such as name, account name, user ID, contact
information, education and employment information, SSN and government
identifiers, account number, and financial or payment information, that
individuals provide us in order to purchase or obtain our products and
services. For example, this may include information collected when an
individual register for an account, purchases or orders our products and services,
or enters into an agreement with us related to our products and services.
|
|
Commercial Information
|
Includes
records of personal property, products or services purchased, obtained, or
considered, or other purchasing or use histories or tendencies. For example,
this may include demographic information that we receive from third parties
in order to better understand and reach our customers.
|
|
Usage Data
|
Includes
browsing history, clickstream data, search history, access logs and other usage
data and information regarding an individual's interaction with our websites,
mobile apps and other Services, and our marketing emails and online ads.
|
|
Geolocation Data
|
Includes
precise location information about a particular individual or device.
|
|
Professional information
|
Includes
professional and employment-related information such as current and former
employer(s) and position(s), business contact information and professional
memberships.
|
|
Education Information
|
Information
about an individual's educational history, such
as the schools attended, degrees you were awarded, and associated dates.
|
|
Biometric information
|
Physiological,
biological or behavioral characteristics that can be used alone or in
combination with each other to establish individual identity. For example, we collect and process
voiceprints for fraud detection and authentication purposes when you contact
us by phone about your application or account, or if you choose
to set and use facial recognition or fingerprints to login to your account.
|
|
Inferences
|
Includes
inferences drawn from other personal information that we collect to create a
profile reflecting an individual's preferences, characteristics, predispositions,
behavior, attitudes, intelligence, abilities or aptitudes. For example, we
may analyze personal information in order to identify the offers and
information that may be most relevant to customers, so that we can better
reach them with relevant offers and ads.
|
Sources of Personal Information. As further described in
the Collection of Personal Information section above,
we may collect personal information from
the following sources:
• directly from the individual;
• advertising networks;
• data analytics providers;
• social networks;
• internet service providers;
• operating systems and platforms;
• government entities;
• data brokers;
• business customer/client.
Disclosures of Personal Information. In the table below, we
identify the categories of personal information we have disclosed for a
business purpose, as well as the categories of third parties to whom we may disclose
such personal information. For more information about the business and commercial
purposes for which we may disclose personal information, please see How We Use or
Disclose Your Information.
|
Categories of Personal Information
|
Do We Disclose for a Business Purpose?
|
Do We Sell?
|
Categories of Third Parties to Whom Information is
Sold or Disclosed
|
|
Identifiers
|
YES
|
NO
|
• service providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising
networks
• data analytics
providers
• social networks
• internet
service providers
• operating
systems and platforms
• data brokers
• business
customer/client
|
|
Customer
Records
|
YES
|
NO
|
• service
providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising
networks
• data analytics
providers
• social networks
• internet
service providers
• operating systems
and platforms
• data brokers
• business
customer/client
|
|
Commercial
Information
|
YES
|
NO
|
• service
providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising
networks
• data analytics providers
• social networks
• internet
service providers
• operating
systems and platforms
• data brokers
• business
customer/client
|
|
Usage
Data
|
YES
|
NO
|
• service
providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising
networks
• data analytics
providers
• social networks
• internet
service providers
• operating
systems and platforms
• data brokers
• business
customer/client
|
|
Geolocation
Data
|
YES
|
NO
|
• service
providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising networks
• data analytics providers
• social networks
• internet service
providers
• operating systems and
platforms
• data brokers
• business customer/client
|
|
Professional
information
|
YES
|
NO
|
• service
providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising
networks
• data analytics
providers
• social networks
• internet
service providers
• operating systems
and platforms
• data brokers
• business
customer/client
|
|
Education
Information
|
YES
|
NO
|
• service providers
• advisors and agents
• government entities and law enforcement
• affiliates and subsidiaries
• advertising networks
• data analytics providers
• social networks
• internet service providers
• operating systems and platforms
• data brokers
• business customer/client
|
|
Biometric
information
|
YES
|
NO
|
• service providers
• advisors and agents
• government entities and law enforcement
• affiliates and subsidiaries
• advertising networks
• data analytics providers
• social networks
• internet service providers
• operating systems and platforms
• data brokers
• business customer/client
|
|
Inferences
|
YES
|
NO
|
• service
providers
• advisors and
agents
• government
entities and law enforcement
• affiliates and
subsidiaries
• advertising
networks
• data analytics
providers
• social networks
• internet
service providers
• operating
systems and platforms
• data brokers
• business
customer/client
|
B.
California Residents' Rights
CCPA Rights. In general, California
residents have the following rights with respect to their
personal information:
·
Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California
consumers, including those we have actual knowledge are younger than 16.
·
Right of deletion: to request deletion of their personal information that we have
collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
·
Right to know: with respect to the personal information we have collected
about them in the prior 12 months, to require that we
disclose the following to them (up to twice per year and subject to certain
exemptions):
•
categories of personal information
collected;
•
categories of sources of personal
information;
•
categories of personal information
about them we have disclosed for a business purpose or sold;
•
categories of third parties to whom we have sold or disclosed
for a business purpose their personal information;
•
the business or commercial purposes for collecting or selling personal information; and
•
a copy of the specific pieces of personal information we have collected about them.
·
Right to
non-discrimination: the right not to be subject to
discriminatory treatment for exercising their rights under the
CCPA.
Submitting CCPA Requests. California residents
may submit CCPA requests through one of the following methods:
·
Online at www.hydrogenplatform.com/contact
·
By phone at +1 800-315-9554
When you submit a request to know or a request to delete, we will take
steps to verify your request by matching the information provided by you with
the information we have in our records or database. You must complete all required fields on our
webform, or otherwise provide us with this information via the above toll-free
number, to verify your request. In some cases,
we may request additional information in order to verify your request, or where
necessary, to verify your identity or process your request. If we are unable to
adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on
behalf of another individual by contacting us by
phone or online at the above link; authorized agents will be required to
provide proof of their authorization and we may also require that the relevant
consumer directly verify their identity and the authority of the authorized
agent.
Your Privacy Rights Under California
Shine the Light Law. Under California's "Shine the Light” law (Cal. Civ.
Code § 1798.83), California residents who provide us certain personal information are entitled to request
and obtain from us, free of charge, information about the personal information
(if any) we have shared with third parties for their own direct marketing use. Such requests
may be made once per calendar year for information about any relevant
third-party sharing in the prior calendar year. To
submit a "Shine the Light” request, email us at [email protected],
and include in
your request a current California address and your attestation that you are a California resident.
Contact Us
If you have questions about the privacy aspects of our
Services or would like to make a complaint, please contact us at [email protected]
or +1 800-315-9554.
Changes to this Policy. This Policy
is current as of the Effective Date set forth above. We may change this Policy
from time to time, so please be sure to check back periodically. We will post
any changes to this Policy on our Site and Application. If we make any changes
to this Policy that materially affect our practices with regard to the personal
information we have previously collected from you, we
will endeavor to provide you with notice in advance of such change by
highlighting the change on our Site and Application.