fbChroniFI | Privacy Policy

CHRONIFI INC. PRIVACY NOTICE

Last Updated: September 29, 2022

ChroniFI Inc. (“ChroniFI” or “we”, “us” or “our”) respects your privacy. We will only use your Personal Data in accordance with the terms of this Privacy Notice (“Notice”). This Notice describes how we collect, use, protect and disclose Personal Data received from your use of our website, www.chronifi.com, along with the features, functionalities, applications, browser extensions and other services available through our website (collectively, our “Website”), our products and services (our “Services”), and any third party site connected to our Website where we post content or invite your feedback or participation, including, without limitation, LinkedIn (collectively, “Third Party Sites” and, together with our Website and Services, our “Platform”).

You can access and interact with our Platform in many ways, including from a computer or mobile device. This Notice applies regardless of how you access or interact with our Platform. Depending on how you interact with our Platform, there may be some cases where we need to provide you with additional information about how we use your Personal Data and/or what options you have regarding our use of your Personal Data. We may provide this additional information via notices on the Platform or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Notice.

Please read this Notice carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Notice, please do not use our Platform, provide us with your Personal Data or authorize a third party to make your Personal Data available to us. By using the Platform, providing us with your Personal Data or otherwise making your Personal Data available to us, you acknowledge that you understand that we may use your Personal Data as described in this Notice. If you have any questions about how we collect, use, protect, disclose or otherwise process Personal Data, including whether we have received your Personal Data from a third party, please contact us by email at info@chronifi.com.

WE COLLECT PERSONAL DATA AND USAGE INFORMATION

Personal Data

When we refer to “Personal Data” in this Notice, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.

Our primary goals in collecting Personal Data are to provide and improve our Platform, conduct our operations, communicate with you and enable visitors to our Platform to enjoy and easily navigate it.

Categories of Personal Data We Collect

Depending on the type of activity you are performing on the Platform or how you use or interact with our Platform, we may collect and disclose the following Personal Data:

  • identifiers and contact information, such as your real name, alias, email address, telephone number, postal address, physical address, date of birth, online identifier, IP address and other similar information;
  • demographic information, such as your age, national origin, and other similar information;
  • internet and other similar network activity information, such as your browsing history, search history, interactions with the online portions of our Platform and online advertisements and other similar information;
  • commercial information, such as records of personal property, products, or services purchased or obtained or other purchasing histories;
  • financial information, such as bank account number, account balances, digital wallet information and other similar information;
  • professional or employment-related information, including current or past job history and other similar information;
  • online identifiers you use, such as your username, social media handles and other similar information;
  • communication information, such as information contained in voicemails, chats, emails and other similar information;
  • location information, such as where you live, where you are located and other similar information; and
  • other information you provide us or authorize us to collect about you.

Usage Information

In addition to Personal Data, we, or third parties acting on our behalf, may collect certain information about the device you use when you interact with our Platform through the normal operation of our Platform and through the use of cookies, pixels, and other web technologies on our Platform (collectively, “Usage Information”). Usage Information, by itself, generally does not identify the specific person using the device that generated it. This means that unless required pursuant to applicable law, Usage Information usually will not be considered Personal Data and the ways we use Usage Information may differ from what is described in this Notice. However, if we link Usage Information directly with your Personal Data or other information that could identify you, we will treat the linked Usage Information as Personal Data and use the linked Usage Information as described in this Notice.

Depending on how you access, interact with, or use our Platform, the Usage Information that we, or third parties acting on our behalf, collect may include:

  • device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a computer or mobile device used to access or interact with our Platform;
  • information about your interactions with our Platform, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with activities on our Platform;
  • information about Internet and network activity, such as websites visited, search engine results and other similar information associated with a computer or mobile device that accesses or interacts with our Platform;
  • information automatically collected by cookies and other technologies on our Platform; and
  • any other information that a computer or mobile device automatically sends whenever connected to a website or an online application.

Our collection, use, disclosure, and storage of the Personal Data we receive from Third Party Sources will be as described in this Privacy Notice.

Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more Third Party Sources.

HOW WE COLLECT YOUR PERSONAL DATA

A large portion of the Personal Data we, or third parties acting on our behalf, collect is collected directly from you. In some cases, we may collect Personal Data from third parties in the ways described in this Notice.

Directly From You.

When you engage with us in connection with our Platform, such as requesting information, creating an account, communicating with us or otherwise interacting with us, we may ask you to provide certain Personal Data. Some of the Personal Data we request may not be required, however, we will specifically indicate what Personal Data is required to engage in such activity.

From Third Parties.

We, or third parties acting on our behalf, may collect Personal Data about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Data from these Third Party Sources can occur in a variety of ways, including, without limitation:

  • When you interact with us on Third Party Sites such as LinkedIn or share our content via the Third Party Sites, we may receive information about you from those sites. As a result, you we, and third parties acting on our behalf, may share, store, use, and otherwise process any Personal Data we receive from or in connection with those Third Party Sites. In some cases, you may be able to revoke our access to your Personal Data and other content and information we receive from Third Party Sites by changing the appropriate settings for your account with the applicable Third Party Site.
  • When you use single sign-on tools. Some of the features of our Platform may provide you with the ability to register and sign into our Platform through the accounts you have with certain third parties, such as Google (“Third Party Single Sign On Providers”). When you use these features, we, or third parties acting on our behalf, gather the data necessary to create an account on our Platform from the applicable Third Party Single Sign On Provider, which may include, without limitation, your name, email address, IP address, device model, device operating system and web browser, time zone, carrier, screen size, processor cores, total disk space and remaining disk space. Your data associated with the applicable Third Party Single Sign On Provider will not be sold, redisclosed or edited through this process. Your ability to use this option may be limited where the applicable Third Party Single Sign On Provider requires you to use a device or operating system that meets that Third Party Single Sign On Provider’s requirements. Please note, by using these features, the applicable Third Party Single Sign On Provider will know that you are signing into our Platform and that you are a user of our Platform.
  • We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with our Platform (“Service Providers”). Service Providers may include, without limitation, third parties that host our Platform, parties that provide us services related to the communications we send and receive, and other financial institutions and financial services companies that we partner with to provide our Services.
  • Third parties whose content is linked to on our Platform. Any links to other websites, applications or other third party content on our Platform, are not an endorsement, authorization, or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications, or content you access.

Our collection, use, disclosure, and storage of the Personal Data we receive from Third Party Sources will be as described in this Privacy Notice.

Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more Third Party Sources.

We, and third parties acting on our behalf, collect Usage Information in a variety of ways. Some Usage Information, such as the IP address of a device attempting to access, use or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Information, such as information about which features of our Platform are popular, helps us improve and advertise our Platform. The primary systems and technologies used to collect Usage Information in connection with our Platform are:

  • the systems we use to make our Platform available to you, including the systems we use to help us identify and address technical issues and errors. When you access, use, or interact with our Platform, these systems automatically record certain information that your browser or device sends whenever you visit a website or utilize an online application as well as information about how long your device is connected to our Platform and the activities that device engages in while connected. These systems also automatically collect information about your actions and activities on our Platform.
  • cookies, which are small data files that are uploaded to the hard drive or other storage on devices that access, use, or interact with portions of our Platform. Among other things, cookies help us improve our Platform and our users’ experience. We use cookies to see which areas and features are popular and to understand usage of our Platform. We use first party cookies, served directly by us to the devices that access our Platform, to recognize those devices when they revisit. We also use third party cookies, which are cookies that are placed by other parties we work with, such as Google or LinkedIn. These third parties may upload unique cookies to your device to collect information about your use of our Platform and potentially other online activities you engage in over time across different Platform and other online applications. The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be uploaded to your device, including how to disable such technologies. You can disable our cookies, or all cookies, through your browser settings, but please note, disabling cookies may impact some of the features of our Platform and prevent them from operating as intended. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/.
  • embedded videos. When you play embedded videos on our Platform, the third parties we use to support that technology, including YouTube API (https://developers.google.com/youtube/terms/developer-policies), may collect certain information about you including Usage Information and may be subject to the third party’s terms and conditions and privacy policy, including without limitation the YouTube Terms (https://developers.google.com/youtube/terms/api-services-terms-of-service) and Google’s Privacy policy at http://www.google.com/policies/privacy.
  • other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Platform, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
  • Third party analytic tools, such as:
    • Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. (“Google”), to assist us in understanding how our Platform is used. Google Analytics will place cookies on your computer or mobile device that will generate information that we select about your use of the Platform, including your computer’s or mobile device’s IP address. That information will be transmitted directly to and stored by Google. The information will be used for the purposes of evaluating use of our Platform, compiling reports on activity on our Platform for our use and providing other services relating to activity on, and usage of, our Platform. 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. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of our Platform. The use of cookies by Google Analytics is covered by Google’s privacy policy, available at https://policies.google.com/privacy. Google allows you to opt out of Google Analytics. You may opt-out by visiting https://tools.google.com/dlpage/gaoptout.
    • Meta Pixel. We may use Meta Pixel, a cookie placed by Meta, that enables us to measure the effectiveness of advertising campaigns served on Meta sites. The information collected by that cookie will be transmitted directly to and stored by Meta. For more information about Meta’s privacy practices, please refer to https://www.facebook.com/about/privacy. To opt-out, please visit https://www.facebook.com/help/247395082112892.
    • TikTok Pixel. We may use TikTok Pixel, a cookie placed by TikTok, that enables us to measure the effectiveness of advertising campaigns served on TikTok. The information collected by that cookie will be transmitted directly to and stored by TikTok. For more information about TikTok’s privacy practices, please refer to https://www.tiktok.com/legal/privacy-policy-us?lang=en.
    • HubSpot Analytics. We may use HubSpot Analytics, a web analytics service provided by HubSpot, Inc. that uses cookies and beacons to track how long users are on our Platform, what marketing pages they visit, what marketing offers they respond to and a user’s identity, to improve our customer education material, set up accounts and operate our Platform. For a description of all HubSpot cookies and information about HubSpot’s privacy practices, please refer to their privacy policy at https://legal.hubspot.com/privacy-policy and their cookie policy at https://legal.hubspot.com/cookie-policy.
    • LinkedIn Insight Tag. We may use Linked Insight Tag, a cookie placed by LinkedIn that enables us to measure the effectiveness of advertising campaigns served on LinkedIn. The information collected by that cookie will be transmitted directly to and stored by LinkedIn. For more information about LinkedIn’s privacy practices, please refer to https://www.linkedin.com/legal/privacy-policy. To opt-out, you can update your advertising preferences through your LinkedIn account. If you do not have a LinkedIn account, LinkedIn allows you to opt-out of applicable targeted advertising by visiting https://www.linkedin.com/psettings/guest-controls.
    • Hotjar. We may use Hotjar in order to better understand our users’ needs and to optimize our Platform. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. For a description of all HubSpot cookies and information about HubSpot’s privacy practices, please refer to their privacy policy at https://www.hotjar.com/legal/policies/privacy/

Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

HOW WE USE YOUR PERSONAL DATA AND USAGE INFORMATION

This section describes the primary purposes for which we use the Personal Data we, or third parties acting on our behalf, collect.

  • Operational Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Platform, which may include, without limitation, presenting content to you and other users to fulfill our business purposes and to facilitate your use of features you elect to use on our Platform, such as engaging in transactions with other users through our Platform; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) notifying you about issues with, or changes to, our policies, terms, and agreements; (5) sending you emails to provide you with alerts and updates about your engagement with our Platform; (6) providing customer service; (7) conducting statistical or demographic analysis; (8) complying with legal and regulatory requirements; (9) customizing your experience with our Platform; (10) protecting and defending ChroniFI against legal actions or claims; (11) preventing fraud; (12) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (13) any purpose for which you authorize or instruct us to use your Personal Data; and (14) other business purposes permitted under applicable law.
  • Marketing Purposes – we may, either on our own or jointly with our third party marketing partners (“Marketing Partners”), use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Notice) and use such linked information for Marketing Purposes. Our Marketing Purposes may include using Personal Data collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our Marketing Partners on and off our Platform. If you do not want us to use your Personal Data for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Data” section below.

We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Platform for materially different, unrelated or incompatible purposes without providing you notice.

Anonymized Data.

Please note, we may use and disclose aggregated, anonymized or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Notice. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Notice.

HOW – AND WHY – WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES

To operate our Platform and provide our Services, we may share certain Personal Data that we, or third parties acting on our behalf, have collected, with certain third parties under 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.

• With our Service Providers. We may share your Personal Data with our Service Providers as needed to complete any transaction or provide any Service you have requested or in connection with the services they provide to us, including, without limitation, order fulfillment, marketing of our products and services, data hosting, fraud protection and prevention, and as otherwise provided in this Notice. We require these Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which it was provided to them.

• For mergers and acquisitions. We may share your Personal Data with applicable third parties in connection with a merger, acquisition, bankruptcy or other sale of all or a portion of our assets. We reserve the right, in connection with these types of transactions, to transfer or assign your Personal Data and other information we, or third parties acting on our behalf, have collected to third parties or to authorize such third parties to use any such information. Except as ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to this Notice. However, any Personal Data you submit or that is collected after this type of transfer may be subject to a new privacy Notice adopted by the successor entity.

• For legal reasons. We may share your Personal Data with government and law enforcement officials or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available or to comply with applicable laws.

MANAGING YOUR PERSONAL DATA

We offer you several choices with respect to how we use your Personal Data. This section describes the mechanisms available to you to control the Personal Data we use about you in connection with our Platform.

Tools to Contact Us

If you want to update any Personal Data you have provided to us, update your preferences, control communications we send you or otherwise contact us about your Personal Data, please email us at info@chronifi.com.

Additional Tool for Communications

For marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Platform.

PROTECTING YOUR PERSONAL DATA

We are committed to protecting the security of your Personal Data. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the transmission of information via the internet and mobile platforms. Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose online, and you do so at your own risk.

CHILDREN’S PRIVACY

We do not direct or target any piece of our Platform to children under the age of 18. If we learn that we have collected the Personal Data of anyone under the age of 18, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 18 and discover that your child has submitted Personal Data to us, please contact us at info@chronifi.com. We will make reasonable efforts to remove such information from our databases.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Data third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.

You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:

ChroniFI Inc.

Attn: CA Privacy Rights Request

1942 Broadway St., STE 314C

Boulder, CO 80302

CHANGES AND UPDATES TO THIS NOTICE

Because the methods used to protect your Personal Data and the Services we provide are continually evolving, this Notice may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Notice, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Notice has been updated.

Your continued use of our Platform after any changes to this Notice become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Notice.

CONTACT US

If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Data third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.

We welcome your questions, comments and concerns about privacy. Please email us at info@chronifi.com with any questions or feedback you have pertaining to our privacy practices.