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HOARD PRIVACY POLICY

This Privacy Policy was last modified on 10/1/2018.

Hoard, Incorporated ("Hoard", “we”, “our” or “us”) collects Personal Information about you from various sources to provide our Site to you, to analyze and improve our Site, and to communicate with you. ThisPrivacyPolicycoversourtreatment of the personally identifiable information (“Personal Information”) that we gather when you access or use our Site offered at hoardinvest.com (“Site”), but not to the practices of companies we don’t own or control, or people that we don’t manage.

  1. Who we are

    Our Privacy Policy applies to our Site hoardinvest.com and all services we offer, but excludes any products applications or services that have separate privacy policies which do not incorporate this Privacy Policy. For the purposes of data protection laws of the United States (“US”) and the European Union (“EU”) (“Data Protection Laws”), Hoard is a data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).

  2. Information we collect and for what purpose

    We gather various types of Personal Information from our users and Site visitors, and we use this Personal Information internally in connection with our Site. In certain cases, we may also share some Personal Information with third parties.

    • Information you provide - when you interact with our Site you may voluntarily provide us with Personal Information, such as your name (including business name), payment information, address, email address and phone number. You may provide this Personal Information to us when you contact us, create an account with us, inquire about careers at Hoard, or request information about our Site. We may also collect additional Personal Information from you as part of signing up for our Site. We also collect information you provide when contributing content or commentary on our Site in the form of forum posts, comments, and the like (“User Content”). Please note that User Content is published on our Site and may be viewable by the public. We may offer services that allow you to share information with third party social media sites such as Facebook, Google, or others. When you link your account or engage with our Site through third-party social media sites, you understand that you may be allowing us to have ongoing access to certain information stored on those social media sites. We may also collect demographic information, such as your age, gender, or zip code, as well as certain information from third parties that we combine with information you provide to us.
    • Information Automatically Collected - Hoard receives Personal Information for individuals related to processing payment transactions initiated through our merchant clients, and when individuals maintain a card with one of our financial institution clients. This information may include names, cards or account numbers, CVV codes, purchase amounts, purchase dates, and methods of payment. We also automatically collect other technical information about your use and interaction with our Site, which may be collected through cookies, web beacons and other similar technology as described in Section 5 (how we use cookies and other tracking technology to collect information).
    • Do Not Track - our Site does not respond to Do Not Track signals communicated by your browser.
  3. How we collect information

    To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

    • Register to use our Site;
    • Complete online forms (including call back requests), take part in surveys, post on any forums, download information such as white papers or other publications or participate in any other interactive areas that appear within our Site;
    • Interact with us using social media;
    • Provide your contact details to us when registering to use or access any services we make available or when you update those details; and
    • Contact us or otherwise connect with us offline.

    We will also collect your information where you only partially complete and/or abandon any information inputted into our Site and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

    We also collect information from your devices (including mobile devices) and applications you or your users use to access and use our Site (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described in Section 5 below).

    We may enhance Personal Information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

    If you intend to give us Personal Information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable Data Protections Laws. In so far as required by applicable Data Protection Laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their Personal Information, or direct them to read our Privacy Policy.

  4. How we use your information

    To the extent permissible under Data Protection Laws, we use your information to:

    • Provide any information or services that you have requested or ordered;
    • Compare information for accuracy and to verify it with third parties;
    • Provide, maintain, protect and improve our Site;
    • Manage, monitor, and administer your use of the Site and provide an enhanced, personal, user experience for you;
    • Manage our relationship with you (for example, customer services and support activities);
    • Undertake internal testing of our Site or systems to test and improve their security and performance (in these circumstances, we would de-identify any information used for such testing purposes);
    • Provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
    • Detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
    • Contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
    • Monitor, carry out statistical analysis and benchmarking (provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual);
    • Deliver advertising, marketing (including in-product messaging) or information which may be useful to you; and
    • Deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers).

    To the extent permitted by Data Protection Laws, we retain information about you after the closure of your Hoard account, if your application for a Hoard account is declined or if you decide not to proceed.

    Our Site may contain technology that enables us to:

    • Check specific information from your device or systems directly relevant to your use of the websites, applications or Site against our records to make sure the Site services are being used in accordance with our end-user agreements and to troubleshoot any problems;
    • Obtain information relating to any technical errors or other issues with our Site;
    • Collect information about how you use the features of our Site; and
    • Gather statistical information about the operating system and environment from which you access our Site.

    In addition to the purposes described in this section 4, we may also use information we gather to deliver targeted and interest-based advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the Site or any other information we have about you (depending on the Site, you may able to configure these features to suit your preferences). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may adjust your ad preferences through your social media settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

  5. How we use cookies and other tracking technology to collect information

    Cookies are small text files which are transferred from our Site and stored on your device. We use cookies to provide personalized service, and to help make our Site easier for you to access. Our cookies may be; 1) temporary session cookies (cookies that identify and track users within our Site that are deleted when you close your browser or leave your session in the application or service); or, 2) persistent cookies (cookies that enable our Site to “remember” who you are and to remember your preferences within our Site and which will stay on your computer or device after you close your browser or leave your session in the applicable Service).

    We use the following different types of cookies:

    • Strictly necessary cookies - these cookies are needed for our Site to function properly, for example, these cookies allow you to access secure areas of our Site.
    • Performance cookies and analytics technologies - these non-identifying cookies collect statistics about how visitors interact with our Site, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or Site.
    • Functionality cookies - these cookies allow our Site to remember choices you make (such as your username, language or region) and allow Hoard to provide enhanced personalized features.
    • Targeting or advertising cookies - these cookies are used to deliver adverts tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. They are usually placed by advertising networks with Hoard’ permission.
    • Web beacons and parameter tracking – we use cookies and similar software known as web beacons to count users who visit our Site after clicking through from our advertisements on other websites or in emails. These web beacons collect limited information which does not identify particular individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.
    • IP Address and traffic data - we keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our Site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
    • Google Analytics - Google Analytics uses cookies to help the Site analyze how visitors use our services. The information generated by the cookie will be transmitted to, and stored by, Google, on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site by compiling reports on website activity for website operators and providing other reports relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. To find out more, see “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).
  6. How we use mobile data

    We may obtain information through mobile applications that you install on your mobile devices to access and use our Site. These mobile applications may be our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, you must read their privacy policy as it will apply to your use of that third-party mobile application. We are not responsible for such third-party mobile applications and their use of your Personal Information.

  7. How we share your information

    We may share your information with:

    • Our corporate family, affiliates and subsidiaries;
    • Our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organizations we engage to help us send communications to you);
    • Partners, including system implementers, resellers, value-added resellers, independent software vendors and developers;
    • Third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
    • Third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third-party application providers);
    • Third parties for marketing purposes;
    • Third party credit reference and fraud prevention agencies;
    • Third parties to enforce our legal rights and satisfy our legal obligations, including without limitation any reporting or disclosure obligations under applicable law or regulations or subpoena, court order or other judicial or administrative process, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others;
    • Third parties to comply with the rules, regulations and guidelines of the payment networks in which transactions are processed;
    • Our professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
    • Third parties to transfer information and/or assets in the event of a merger, acquisition, sale, bankruptcy filing, or other corporate restructuring; another organization to whom we may transfer our agreement with you; and
    • Third parties for any other purpose permitted under applicable law and regulation or agreed to in this Privacy Policy or disclosed at the time the information is collected.

    If you follow a link from our Site to another site or service, this Privacy Policy will no longer apply. We are not responsible for the information handling practices of third party sites or Site and we encourage you to read the privacy notices appearing on those sites or Site.

  8. Legal basis for processing in the EU

    In the EU, we collect your personal data for the following purposes:

    • Where necessary to perform any contract we enter into, or have entered into, with you to provide services or access to our Site;
    • Where necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
    • Where we need to comply with a legal or regulatory obligation in the EU.

    If you require details about the specific legal basis we are relying on to process your personal data please contact us at support@hoardinvest.com.

  9. How we store and protect your information

    We will endeavor to keep your information secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction or damage. We will take commercially reasonable steps to protect your Personal Information but we cannot guarantee the security of your information which is transmitted to our Site or to other website, applications and Site via an internet or similar connection.

    For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfil the purposes for which we collect the data (see above under "Information we collect and for what purpose"), except if required otherwise by Data Protection Laws. Please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same Data Protection Laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

    If you believe your account has been compromised, please contact us at support@hoardinvest.com.

  10. Your choices

    1. Personal Information

      You may provide us with instructions on what to do with your Personal Information. Users have choices and control over their Personal Information. Since these choices and instructions may result in loss of access to the Site and services, please review your options carefully.

    2. Other information

      If you have any questions about your Personal Information, our use of this Personal Information, or your rights when it comes to any of the foregoing, contact us at support@hoardinvest.com.

    3. Your rights in respect to your Personal Information if you are located in the EU or Switzerland

      If you are located in the EU or Switzerland, you have the following rights in respect to the Personal Information that we hold:

      • Right of access - the right to obtain access to your personal data,
      • Right to rectification - the right to obtain rectification of your Personal Information without undue delay where the data is inaccurate or incomplete,
      • Right to erasure - the right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the data is no longer necessary in relation to the purposes for which it was collected or processed,
      • Right to restriction - the right to restrict data processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data,
      • Right to portability - the right to portability allows you to move, copy or transfer Personal Information easily from one organization to another; and,
      • Right to object - you have a right to object to data processing based on legitimate interests and direct marketing.

      If you wish to exercise one of these rights, please contact us at support@hoardinvest.com.

      If you feel your Personal Information has been inappropriately handled, you can lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

    4. Other Choices

      In addition, the browser you use may provide the ability to control cookies or other types of local data storage. Hoard does not control these choices, or default settings, which are offered by makers of your browser.

  11. Changes to our privacy policy

    We may change our Privacy Policy from time to time. We will update this Privacy Policy on our website, so please try to read it when you visit the website (the ‘last modified’ reference tells you when we last updated our Privacy Policy).

  12. Further Information

    If you have any queries about how we treat your information, the contents of this notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please email us at support@hoardinvest.com.