Effective as of 10.05.2021
Personal information we collect
How we use your personal information
How we share your personal information
Other sites and services
International data transfer
How to contact us
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
• Contact data, such as your name, email address, billing and mailing addresses, professional title and company name, and phone number.
• Company information, including company name, address, employer identification number, and names of company employees, contractors or authorized users.
• Business owner or registered officer information, including the name, phone number, email address, billing and mailing addresses, date of birth, Social Security number, professional title and company name for any owner(s) or registered officer(s) of the business.
• Profile data, such as the username and password that you may set to establish an online account on the Service, links to your profiles on social networks, interests, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.
• Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
• Transactional data, such as information relating to or needed to complete transactions on or through the Service, including details regarding dates, amounts and merchants associated with your transaction history.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content, such as profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Financial information, such as financial account numbers or payment card information.
• Employment and professional information, such as professional and employment history, including licenses and certifications.
• Promotional information, including information you share when you take advantage of promotions, enter a competition, or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Marketing partners, such as joint marketing partners.
• Third-party services, such as anti-money laundering, know-your-client, and business credit reporting vendors used in connection with providing the Service.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• (Precise geolocation/Location) data when you authorize (our mobile application/the Service) to access your device’s location.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. Some of the automatic collection is facilitated by the following technologies:
• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
• Session Replay Technologies. We use third party services provided by Cohere that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Cohere at https://cohere.io/privacy.
Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to: • provide, operate and improve the Service and our business; • establish and maintain your user profile on the Service; • facilitate your invitations to friends who you want to invite to join the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• Provide you with the products, services, programs, offers, or information you request from our partners and financial institutions, and for related purposes such as determining eligibility.
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
• Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Compliance and protection. We may use your personal information to:
• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics, Mixpanel and Segment for this purpose. You can learn more about Google Analytics, Mixpanel and Segment at https://policies.google.com/privacy?hl=en-US, https://mixpanel.com/legal/privacy-policy/ and https://segment.com/legal/privacy/.
Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
How we share your personal information
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, anti-money laundering, know-your-client, business credit reporting , marketing, consumer research and website analytics).
Payment processors. Any payment card or ACH information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Unit Finance Inc. Unit Finance Inc may use your payment data in accordance with its privacy policies.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party partners with whom we are collaborating to offer you additional services, including special promotions. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Toolbox or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and accessing the “My Profile” section.
Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.
Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
Advertising choices. You can limit use of your information for interest-based advertising by:
• Browser settings. Blocking third-party cookies in your browser settings.
• Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising: o Google: https://adssettings.google.com/ o Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
o Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
o Digital Advertising Alliance: optout.aboutads.info.
o AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device from which you wish to opt-out.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.
California residents. California residents have certain rights over the information that we have about you. Information collected about you is done solely in the context of your role as an employee or authorized user of our business customer. As a California resident, you are able to: (a) access a copy of any personal information about you, (b) delete any personal information we have about you (as long as we are not legally or contractually obligated to retain this information or otherwise require it for a legitimate business function), and (c) correct any personal information we have about you by accessing them in the app or contacting us as described below.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer.
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
How to contact us.
Mail: 169 Madison Avenue, #2032, New York, NY 10016.