Effex.io Privacy Statement
Last Updated: January 13, 2021
Scope of this Privacy Statement and our role
As a services technology company, we’re providing this Privacy Statement (which we’ll refer to as “Privacy Statement”) to explain how we collect, use, and share information when you interact with us and our offerings, services and experiences. This Privacy Statement is global in nature, meaning that it is applicable to all websites and offerings at Effex.io Inc., and it describes our privacy practices when we process:
a) Personal information for the purposes of providing the benefits of the Effex.io platform, which is collectively, all of Effex.io’ services, sites, experiences and software (including through our mobile applications) by Effex.io Inc. and its affiliates and subsidiaries (the “Effex.io Platform”); and/or
c) Personal information as necessary to manage, run and improve our business.
Effex.io Inc. determines the purposes and means of the processing of personal information (“Information Controller”). Effex.io Inc. may share your personal data with other affiliate companies to process as joint controllers for the purposes set out in this Privacy Statement. If you have any questions about the processing of your personal data, please contact us in the section “How to Contact Us” below.
This Privacy Statement does not apply where Effex.io processes personal information as a service provider on behalf of a customer or entity who acts as the Information Controller, for example, the customers of our communications partner. When we act as a service provider, the privacy statement of the relevant Information Controller and our agreements with such business or entity will govern our processing of personal information.
In certain circumstances, there may be more than one Information Controller processing your information. For example, your employer or a financial partner may also act as an Information Controller. In these situations, we act as an independent Information Controller over our processing activities – meaning that we make determinations over how your personal information will be processed independently from the other Information Controller. The other Information Controller may have their own obligations under
applicable information privacy law, and you may need to speak with the other Information Controller directly for questions on how they process your personal information.
The Effex.io Platform
The Effex.io Platform and your information
When we say “platform” we mean that when you choose to share data with us, or bring over information from third parties (like a bank), we use that data together, not just within the individual offering(s) you’re using.
The personal information we use in this centralized way is all the information that Effex.io knows about you. It includes your credentials; your name and contact details; payment information; information about your activities, your interests and preferences; insights about your finances or your business; the content you place in our Platform; and information we have collected about you from third-party sources.
Information we collect
Information we receive from you
The personal information that we receive about you depends on the context of your interactions with Effex.io, how you configure your account and the choices that you make, including your privacy settings. Personal information that you provide may also depend upon what services or experiences you use, your location and applicable law.
Information provided by others
Our platform is designed to help you connect with other people and organizations. As a result of those connections, others may be able to input information about you. For example, your employer may input information about your salary and work activity in order to process their payroll. You may also be able to input or process information about others, for example, if you are an account administrator. If you input information about others into our platform, you must only do so if you have first received the appropriate rights and permissions to do so, including by getting advanced written consent, if required by applicable law.
Other information sources
We may also get information about you from others where permitted by applicable law. We protect and process information obtained from those parties as described in this Privacy Statement, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the Effex.io
Platform. For example, we receive information from:
How we use personal information
We collect and process personal information from you only where:
service to you;
Personal information is used to operate our business for the following purposes that are required to originate and maintain our relationship with you, including but not limited to:
you, including through the development of insights about you and your needs
customers, employees or others and prevent fraudulent or illegal activity
this is permitted by applicable law.
To provide you with valuable personalized advice, recommendations and experiences, we may process your personal information using automated and manual (human) methods. Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience in the Effex.io Platform.
How we share your information
We may share your information in the following circumstances:
With your consent. Except for as outlined below, we only share your information with third parties when you have directed us to do so.
When you connect with an Effex.io Platform partner. You may be provided with offers, products, and services from third-party companies who integrate with our Effex.io Platform (“Platform Partner”). If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct Effex.io to share your information, including personal information, to the Platform Partner providing the service or offering. For example, when we send your personal information to partners in order to generate offers for you to review, when we send your application information directly to our partners, or
when we send you to the partner’s site for you to provide the information directly to them.
In some cases, if you click through to go to a Platform Partner’s site, you will automatically be sending your personal information to that Platform Partner. When this happens, you will still have to submit your application on the Platform Partner’s site. Remember that any information you provide to a Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
When you connect to your social media account. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.
For research. With appropriate controls, we may share information with third-parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that would not allow any individual to be identified.
For joint features, sales, promotions and events. We may share your information with third-parties companies who are jointly providing features, sales initiatives, promotions or events with us.
With financial services providers. We may share personal Information with collection agencies, credit bureaus and loan service providers, and payment card association members. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.
When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information, such as your name or user name. Anything you share in a public forum is public, and you should think carefully before you decide to share.
With service providers or agents. We share personal information with our service
providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Statement. Service providers or agents may include companies that assist us with our advertising, marketing and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business.
For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.
No sale of personal information to third parties. We do not and will not sell personal information to third parties. We do share personal information with third parties for the business purposes described in this Statement.
With our affiliates and subsidiaries and your right to limit information sharing. We may share your information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes. Certain laws may provide you with the right to limit our information sharing activities in certain circumstances.
Cookies and other tracking technologies. You can find information on changing your browser settings to opt-out of cookies in your browser settings. In certain countries, you may also be able to make changes to your cookies settings by using our cookie preferences tool. If you disable some or all of the cookies the service, or parts of the service may not work.
For advertising and analytics. Effex.io may use advertising networks and other providers to display advertising on our Effex.io Platform or to manage our advertising on other sites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements.
The Effex.io Platform is not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.
For legal reasons. We may share your information with third-parties for legal reasons without your consent, and as permitted by law, including:
Your information rights and choices
At Effex.io, we believe that you have rights to information that pertains to you, your household and/or your business. If another person has input or processed information in the Effex.io Platform on behalf of you, your family or your business (and we are processing such information as an Information Controller), you may ask to receive a copy of your information, even if you do not have an account with us.
Depending on where you live, you may have certain state- or nation-specific rights with respect to your personal information that we collect and process.
To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to us exercising your data rights. If we are unable to verify your identity or ownership rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents.
Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of the Effex.io Platform. However, even if you request a deletion, we may be required to maintain your information for as long as necessary to:
1) comply with our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us);
2) to exercise, establish or defend legal claims; and/or
3) to protect against fraudulent or abusive activity on our service.
This means we may keep different information for different periods. If your account is canceled because you’ve not used it in a long time, we may delete this information straight away.
There may be occasions where we are unable to fully delete, anonymize, or de- identify your information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.
You agree and Effex.io reserves the right to store and process your personal information in the United States and in any other country where Effex.io or its affiliates, subsidiaries, or service providers operate facilities in accordance with and as permitted by applicable laws and regulations. Some of these countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).
When we transfer, store or process personal information outside of your
jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Statement and applicable law.
Security of your personal information
We use physical, technical and organizational safeguards designed to protect your information. However, despite these controls, we cannot completely ensure or warrant the security of your information.
Changes to our Privacy Statements
From time to time we may change or update our Privacy Statement. We reserve the right to make changes or updates at any time. If we make material changes to the way we process your personal information, we will notify you by posting a notice in our platform or on a community post; by sending you a notification; or by other means consistent with applicable law.
You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement. Please review this Privacy Statement periodically to stay informed about how Effex.io protects your privacy.
Collection and use of children’s personal information
Our services are not intended for or directed to children. We do not knowingly collect personal information from children. If you believe we may have information from a child, please contact us.
Correct your personal information. You can edit and correct your personal information at any time by changing it directly in our products and services.