SILVUR PRIVACY POLICY

Effective as of: March 13th, 2020

At Silvur, we take seriously our responsibility to protect the privacy and confidentiality of information about you. Silvur is committed to earning and maintaining your trust by safeguarding your personal information and making its protection a priority. This Privacy Policy describes how Silvur and its subsidiaries and affiliates (collectively “Silvur,” “the Company,” “we” or “us”) collect, use, disclose, share, and protect information of users or visitors to our website located at www.silvur.com (the “Website”), the Silvur mobile application (the “Silvur Mobile App” which, together with the Website, is referred to in this Privacy Policy as the “Platform”) and users of any services which are provided, offered or made available by us through the Platform (the “Services”).

Your Acceptance of this Privacy Policy

By accessing or using the Platform or Services, you consent to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. The provisions contained in this Privacy Policy supersede all prior notices and statements regarding our privacy practices with respect to the Services. If you do not agree to every provision of this Privacy Policy, you may not access or use the Services.

How We Collect Information

When you access or use the Services, we may collect information that identifies you (“Personal Information”), and we may also collect information that does not identify you (“Anonymous Information”). We obtain information about you in a range of ways.

Information You Provide to Us

In general, you may visit the Website or download the Silvur Mobile App without telling us who you are or sharing any Personal Information with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Information, such as your name, email address, postal address, mobile number, demographic information (such as your occupation, gender, race, or nationality), Taxpayer Identification Number and financial account information. Additionally, if we are required by law to send to you and file certain forms with tax authorities, we may ask you to provide us or our service provider certain Personal Information. We may also ask you whether you want to receive text messages relating to the Services. By providing your mobile phone number, you expressly consent to receive text messages from us relating to the Services at that number. Third-party data and message fees may apply. You may decline to provide certain Personal Information to us, but, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

Information you provide us may also include user created content such as messages, comments, photos, audio, or video that you post, upload, submit, share, or otherwise provide on or through the Platform (“User Content”). You grant us permission to utilize the User Content in a commercially reasonable manner on the Platform, on any related and/or affiliated websites, and in marketing materials now and in the future, and you waive any and all rights to compensation as a result of such use. The posting of User Content is subject to our Terms of Use.

Information Collected from Devices

When you access or use the Platform or Services via a computer or mobile device, including, without limitation, a desktop computer, laptop, mobile phone, tablet, or other electronic device (each, a “Device”), we may collect information from your Device, such as your Device type and manufacturer, your Device operating system and version, your mobile carrier, your Device identifiers, your mobile phone number, your IP address, your location, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website and the Silvur Mobile App.

In addition, if you download the Silvur Mobile App to your mobile Device, we may collect information from your mobile Device about your location while you are accessing or using the Silvur Mobile App and while you are not accessing or using the Silvur Mobile App. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

Finally, we may generate analytics based on your preferences, characteristics, use, and interactions with the Platform and Services. Our Services may then analyze such data and generate derivative data or aggregated data as well as reports and other output.

Information Collected by Cookies and Tracking Technologies

Like many websites and online services, we may use cookies, pixel tags, log files, web beacon technologies, and other automated tracking technologies (collectively, “Cookies”) to obtain certain types of information when a web browser, mobile application, or other application accesses our Platform. A cookie is a small piece of data that we transfer to a computer’s or other device’s memory for record-keeping purposes.

Pixel tags, also known as “web beacons” or “clear GIFs,” are small electronic images, often a single pixel, that may be placed on users’ hard drives. We and our advertising partners may use pixel tags to conduct analytics on the Platform; to provide online advertising, including targeted advertising; and to determine the effectiveness of our advertising campaigns. If you use a mobile device to access our Platform or Services, we may automatically record the Advertising ID (if you are using an Android device) or your Advertising Identifier (if you are using an iOS device) for advertising or analytics purposes. Your device settings may allow you to opt out of tracking using Advertising IDs or Advertising Identifiers.

By accessing or using the Platform and Services, you consent to the placement of Cookies on your Devices as described in this Privacy Policy. If you prefer not to receive Cookies through the Services, you may control how your browser responds to Cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all Cookies, our systems may issue Cookies when you access or use the Platform or Services. If you set your browser settings to refuse all Cookies, the performance of certain features of the Platform or Services may be limited or not work at all.

In some of our email messages to you, we may use “click-through URLs” linked to content on the Website or the Silvur Mobile App. We track click-through data to help us understand and analyze interest in topics and use of the Services.

Information From Others

In addition to the information that you provide to us directly, we also may obtain information about you from other sources. For example, we may obtain information from a third-party service provider whose application you authorized or used to sign into our Platform. We may purchase information about you from third parties or gather publicly available information about you from online and offline sources, such as your public profile on social media. While we obtain information from third parties that we believe to be reliable, Silvur cannot guarantee the currency, accuracy, timeliness, completeness, or fitness of such information for any particular purpose. If we combine such information with the Personal Information that we collect from you, we will treat the combined information as Personal Information under this Privacy Policy.

How Your Information is Used

In general, we collect, use, store, and process your information to provide, enhance, and improve our Platform and Services, to develop new services, and to market our companies and the products and services we offer.

Here are some examples of how we use the information submitted, collected, received, or generated about you:

  • To operate, improve, maintain, administer and further develop the Platform and Services, and to operate and support our related business activities;
  • To provide and deliver products and services that you request;
  • To respond to comments and questions and provide customer service and user support;
  • To send information including confirmations, account statements, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • To provide personalized experiences and recommendations, location customization, personalized help and instructions, or other targeted improvements of the Platform and Services;
  • To communicate about promotions, upcoming events, and other news about products and services offered by us;
  • To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity as well as to address safety, security, or technical issues;
  • To better understand how users access and use the Platform and Services;
  • To conduct quality control and to fix technical and other errors or problems;
  • To conduct market research;
  • To respond to user desires and preferences;
  • To comply with applicable laws, rules and regulations, and any regulatory mandate or court order;
  • To protect the rights and property of Silvur, our agents, customers, and others, including enforcing our agreements, policies, and Terms of Use; and
  • To use in any other manner, or for any other purpose, for which you have given express permission or consent to us.

To the extent that you share your User Content through the Platform with our other users or public forums on the Platform, that User Content also may be shared by us with other users, larger groups of users, and/or the public in general.

If you wish to subscribe to updates, news feeds, or other materials we may distribute, we will use your name and email address to send these materials to you. Out of respect for your privacy, you may choose to stop receiving our materials or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at support@silvur.com.

We may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device to help with goals like research and marketing. We may perform analytics on your preferences, characteristics, use and interactions with the Platform to generate aggregated information. Our Services may then analyze such aggregated information to generate derivative data as well as reports and other output. Aggregated or de-identified, Anonymous Information is not Personal Information and this Privacy Policy does not apply to our use of such aggregated or de-identified information.

When Information is Shared with or Disclosed to Others or the Public

We may share Anonymous Information with third parties as described elsewhere in this Privacy Policy and for our commercial purposes. We do not share Personal Information with our affiliates or third-party service providers, except as described elsewhere in this Privacy Policy and as follows:

  • if you request or authorize it;
  • to complete a transaction or provide a service requested by you;
  • to our third-party service providers that provide services to support the Services, such as payment processing, data analysis, email delivery, hosting, order fulfillment, infrastructure, network storage, customer service, technical support, and promotional services;
  • to comply with applicable laws, rules, and regulations, including but not limited to tax laws;
  • to comply with governmental and regulatory requests, court orders, and subpoenas;
  • to protect our rights, property, and safety and the rights, property, and safety of our users and others or to prevent fraud;
  • to enforce our rights arising from any contracts entered into between you and us, including the Terms of Use;
  • with merchants that you transact with that already have Personal Information about you for the purpose of verifying offer-qualifying transactions; and
  • if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets) or in the event of bankruptcy.

In order to provide the Services and in connection with our everyday business purposes and activities, we may share your Personal Information with third parties who perform services on our behalf. Examples of these third parties and services include consumer identification verification services, public accounting firms and other professional firms, and certain other vendors and service providers who perform marketing, advertising, research, and analytics services on our behalf. We may also disclose your information to other third-party financial institutions (for example, if you ask to transfer assets from Silvur to another financial institution).

We may also share your Personal Information with our partners when you ask for their services. We may give you opportunities to interact with third party partners through our Services, such as when we provide you with the opportunity to review and send your Personal Information to a partner in order to pre-populate your application on the partner’s site, 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 a partner’s site for you to provide the information directly to them. In some cases, if you click through to go to a partner’s site, you will automatically be sending your Personal Information to that partner. When this happens, you will still have to submit your application on the partner’s site. Remember that any information you provide to the partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.

We may permit third parties to provide analytics services that allow us to optimize the functionality of our Platform and inform our marketing activities. These third parties may use Cookies, and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and third parties to analyze and track data, determine the popularity of certain content and other websites, and better understand your online activity. Our Privacy Policy does not apply to, and we are not responsible for, third party cookies, web beacons, or other tracking technologies; and we encourage you to check the privacy policies of these third parties to learn more about their privacy practices. We use Google Analytics to help collect and analyze certain information for the purposes discussed above. You can learn more about Google Analytics’ data practices by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here. Your use of our Platform and Services constitutes your consent to these analytics services that are critical to our business operations, including the following:

  • Google Tag Manager manages the JavaScript and HTML tags that may be placed on the Platform. To learn more, click here.
  • Mixpanel, Amplitude & Segment collect and analyze users’ movements, including across platforms, while on the Platform. To learn more about Mixpanel, click here; to learn more about Segment, click here; and to learn more about Amplitude click here. UXCam record and analyze users’ activities during each session visiting Platform. To learn more about UXCom here, respectively. These services collect personal information, including information you enter on our site, which we tie to information we have about you to provide better analytics, to optimize our website, and to inform our advertising campaigns.
  • Looker maps user interactions on the Platform to generate visual analytics reports. To learn more, click here.

We may allow third-party service providers to display advertisements to our users on third-party websites based on your browsing history by using cookies or other tracking technologies. For example, we may use Facebook’s advertising services, including Facebook’s Custom Audiences service, to target our advertisements to you. To learn more about Facebook Custom Audiences, including how to opt-out, click here, and to learn about Facebook’s advertising in general, including how to opt-out, click here.

To find out more about online advertising and your choices related to such advertising, including retargeted ads, please visit the Network Advertising Initiative ("NAI") website and the Digital Advertising Alliance (“DAA”)website. You can opt out of such online based advertising by following the instructions below. Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile Advertising IDs or Advertising Identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work, and you will need to opt out again.

  • Web Browser Opt-Out. To opt out in web browsers, please visit the opt-out pages of the Network Advertising Alliance and the Digital Advertising Alliance. To help preserve the choices that you make in the DAA’s WebChoices page, you can install the DAA’s “Protect My Choices” extension that is available here.
  • Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, or in Android, visit Settings > Google > Ads > Opt out of interest-based ads). You can also opt out for companies that participate in the DAA’s AppChoices tool by downloading AppChoices here and following the instructions in the app. For more information about opting out on mobile devices, please see here.

The Platform may also offer you the ability to interact with plugins from social media sites such as Facebook, Twitter, Pinterest, and others that may collect, use, and share information about you from our Platform as part of the operation of the plugins. These plugins are subject to the privacy practices of the respective third-party social media companies, which may differ from this Privacy Policy.

We share Personal Information among our affiliates and business units when we believe it will help enhance the Platform or Services we can provide, but only in circumstances where such sharing conforms to the law, any applicable confidentiality agreements, and our policies and practices.

Finally, we may disclose Personal Information in specific other cases with your consent or per your instructions.

Security and the Protection of Your Information

Silvur is focused on protecting your information. We employ physical, technical, and administrative safeguards to keep your information secure. We use robust, industry-standard browser encryption; store all of your data on servers in secure facilities; and implement systematic processes and procedures for securing and storing data. We limit access to your Personal Information to only those employees with authorized access who need to know the information in order to perform their jobs. Furthermore, if you choose to close your Account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain an Account with us that you access through our Platform, you are responsible for protecting and maintaining the confidentiality of your Account and password and restricting access to your computer. While Silvur follows generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security.

Accessing or Changing Your Information

If the Personal Information on file for you changes, or if you no longer desire access to our Platform or Services, you may update your information by contacting us at support@silvur.com.

We will retain copies of your Personal Information in a form that permits identification for as long as we deem necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulation requires us to preserve this information for a longer or shorter period. In particular, we will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

International Visitors

Our Platform and Services are hosted in the United States and are only intended for residents of the United States. If you use our Platform or Services from the European Union, Asia or any other country outside the United States with laws or regulations governing personal data collection, use, and disclosure that differ from the United States laws and regulations, please be advised that through the continued use of the Platform and Services, you are (i) permitting the transfer of your personal information to the United States; and (ii) permitting the use of your Personal Information in accordance with this Privacy Policy.

Links to Other Services and Applications

Our Platform and Services may contain links to, interoperate with, and allow you to share content to and from third party services, websites, and applications. The fact that we link to a website, service, or application or allow you to share content with or through these third parties is not an endorsement, authorization, or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. Other websites, services, and applications follow different rules regarding the collection, use, storage, or disclosure of personal and other information. We encourage you to read the privacy policies or statements of the other websites, services, and applications you use.

Other Information for You

Former Customers

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

How We Respond to Do Not Track Signals

At this time, we do not respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser. Please note that blocking cookies may affect your browsing experience on many sites and may limit your ability to use certain features of our Services, including many of the personalized features we provide for our users.

How You Accept This Policy

By using and continuing to use or visit the Platform and Services, or otherwise providing us with Personal Information (such as an email address) you agree to the terms and conditions of this Privacy Policy and any updates thereto. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. Our Terms of Use take precedence over any conflicting Privacy Policy provision.

Changes to the Policy

We may revise this Privacy Policy from time to time in our sole discretion and without prior notice, subject to applicable law. When we revise this Privacy Policy, we will post the revised version on the Platform. The revised Privacy Policy will be effective upon posting on the Platform, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing and using the Platform and Services. If you do not agree to this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access to and use of the Platform and Services. Except as otherwise expressly stated by us, your access to and use of the Platform and Services are subject to the version of this Privacy Policy in effect at the time of your access or use of the Services.

Our Policy Toward Children

In order to use the Platform and other Services you must represent and warrant that you are over the age of 18 in the sign-up process. Children under the age of 18 are not eligible to use the Services and must not attempt to sign-up with the Services and/or submit any Personal Information to us. We do not knowingly collect Personal Information from any person who is under the age of 18 or allow them to register. If it comes to our attention that we have collected Personal Information from a person under the age of 18, we will delete this information as quickly as possible, subject to our legal and/or regulatory obligations. If you believe we might have any personal information from or about a child under the age of 18, please contact us at support@silvur.com.

Limitation of Liability

Even though we have taken reasonable commercial steps and efforts to prevent your Personal Information and other information covered by this Privacy Policy from being accessed, used, intercepted, or disclosed by unauthorized individuals, you should know and you acknowledge that we cannot fully eliminate risks associated with your information. By providing to or allowing access by us to your information as a result of your use of the Platform and/or Services, you acknowledge and agree that we are not liable for (i) any special, indirect, consequential, incidental or punitive damages, costs, or liabilities whatsoever arising out of or resulting from your use of the Platform or Services, including from uploading, posting, providing, storing, using, analyzing, transmitting, sharing, and/or allowing access to Personal Information and other information and content; or (ii) any loss, disclosure, or use of your Personal Information or other information and content.

We want to hear from you if you have questions.

If you have any comments, questions, or concerns about any of the information in this Privacy Policy, or any other issues relating to the processing of your Personal Information by us under this Policy, please contact us at support@silvur.com.