Privacy Policy

Effective as of January 1, 2023

Personal Information We Collect

Personal information you may provide to us through the Platform include:

  • Contact data, such as your first and last name, email address, billing and mailing addresses, and phone number.
  • Government identifiers, such as national identification number (e.g. Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
  • Profile data, such as username and password for your Datality account, date of birth, and any other information that you add to your account profile.  
  • Billing data, such as the payment card or bank account numbers that you use to make payments or receive payouts through the Platform.
  • Communications that we exchange with you through the Platform, including (but not limited to) chat and other interactive features. 

We may also collect personal information not specifically listed above, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third Parties

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Your bank account, when you authorize us to collect your information from them.
  • Identity verification providers, when you authorize us to collect your information from them.
    Cookies and Related Technologies

    The Platform employs the following for data collection and storage:

    • The Platform employs session cookies that expire when you close your browser and persistent cookies that remain stored on your device.  The Platform employs cookies for the following purposes:
      • Technical operation – To allow the efficient technical operation of the Platform, such as by remembering your selections and preferences.
      • Functionality – To enhance the performance and functionality of the Platform.
      • Analytics – To help us understand user activity on the Platform to better understand how to maintain and improve the Platform. 
    • Local HTML5 storage technologies provide functionality by storing larger amounts of data on your device outside of your browser in connection with specific Platform functions.
    • Chat technologies provided by third-party vendors may employ cookies so you can communicate with us through the Platform. We and such third-party vendors may monitor, record and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other information you share through online chats for the purposes described in this Privacy Policy.

    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:

    Platform Operations

    We may use your personal information to:

    • provide, operate and improve the Platform and our business
    • fulfill your requests for products and services
    • facilitate invitations to contacts you may invite onto the Platform
    • communicate with you about the Platform, including through chat features, announcements, updates, security alerts, and support and administrative messages
    • personalize your experience with the Platform and our communications
    • troubleshoot and provide support for the Platform, and respond to your requests, questions and feedback
    Platform Marketing

    We, our service providers and our third-party marketing partners may collect and use your personal information for marketing purposes:

    • Direct marketing – We may send you marketing communications, including through text message or email.  You may opt-out of our marketing communications at any time.  
    • Promotions – We may use personal information to provide the promotional programs that we offer, such as recommending specific new products on the Platform based on your interests. We may provide these programs in collaboration with affiliate brand partners and other businesses, websites, mobile applications or third parties.  
    Platform Development 

    We may use your personal information for research and development purposes, including for analysis and improvement purposes for both the Platform and our business.  We may create anonymous, aggregated or deidentified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or deidentified data by removing all information that makes the data identifiable to you.  We may use this anonymous, aggregated or deidentified data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and promote our business.    

    Compliance and Legal Protection

    We may use your personal information to:

    • comply with applicable laws, legal requests, and legal processes when required by government authorities
    • protect rights, privacy, safety or property 
    • adhere to compliance with legal and contractual requirements or our internal policies
    • enforce the terms and conditions that govern the Platform
    • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including fraud, cyberattacks and identity theft
    Retention

    We retain classifications of personal information based on fulfilling the purposes for which we collected it, including satisfying legal, regulatory, accounting, or reporting requirements, establishing or defending legal claims, enforcing our agreements, dispute resolution or fraud prevention.

    How We Share Your Personal Information

    We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

    Service Providers –  Third parties that provide services on our behalf or help us operate the Platform or our business, including communications delivery, hosting, information technology, customer support products and services, emailing, text message delivery, marketing, consumer research, and Platform analytics. 

    Financial Institutions – Datality uses Plaid Inc. (“Plaid”) to gather your data from financial institutions, with your prior authorization. By using the Platform, you grant Datality and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid privacy policy. The Platform may also use financial institutions to process ACH funds transfers from or to your source bank account, with your prior authorization, in accordance with our Terms of Use.  

    Professional Advisors – Professional advisors, such as attorneys, auditors and insurers, where necessary in the course of the professional services that they provide to us.

    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 – Parties to business transactions or proposed 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, Datality or our affiliates (including, in connection with insolvency, bankruptcy or similar proceedings).

    Closing Your Account

    Please contact us to request account closure and deletion of your personal information.  Certain personal information may be retained after closure in accordance with our data retention policies where required or permitted by applicable law.

    Security 

    We employ, test and routinely audit and evaluate reasonable best-practice technical, logistical and physical security implementations designed to protect the confidentiality, integrity and security of the personal information we collect, including when we receive it, during transit and at rest.