Last updated: March 2022
© 2022 Civex LLC. All rights reserved.
INFORMATION WE COLLECT
- Information we may collect directly from you:
- Personal Information that identifies you, such as your name, contact details including phone number, email address, postal address, telephone or fax number; area code only and zip code only;
- Account Registration Information, such as information provided by you when you register for an account to use the Civex System either directly through the Civex System or using third party credentials (e.g., Facebook, Apple, or Google), including User ID, log-in details, security questions (and associated answers and passwords), and any additional information you choose to provide during registration such as interests and preferences;
- Financial and Commercial Data, such as name, billing address and any account information from your brokerage accounts or from other financial institutions;
- Securities Data, such as types and quantities of securities you buy/sell/hold (e.g., stocks, mutual funds, bonds) securities preferences and other investment portfolio data that you may provide in relation to the Services, and stockholder voter proxy details;
- Audiovisual Materials, such as photographs or images that you upload to identify yourself or otherwise as part of your use of the Civex System;
- Professional or Employment related information you provide, such as your current position, job title, employer, or location, that you may provide in relation to the Services;
- Information pertaining to your interests, such as your hobbies, activities, and concerns;
- Marketing and Communications Data, including your marketing preferences or your interest in our Services; and,
- Other personal information you submit to us through communications, customer support exchanges, our “Contact Us” link, surveys, a competition or promotion, reporting a problem, email, or otherwise.
2) Information we may obtain about you based on your usage, from others or by automated means:
- Information We Obtain from You Based on Your Personalized User Experience, such as age, birthdate, gender, dependents, spousal and other family information and household information;
- Information We Obtain from Third Party Business Partners, such as personal contact details, account information from your brokerage accounts or from other financial institutions that you link to the Services;
- Derivative Data, such as technical information about the Services, including device name and type, IP address, other setup data, usage, battery charge level, operating system, browser type, access times, pages viewed directly before and after accessing the App, other interactions with the application which are automatically collected and stored in log files;
- Data from our Social Media Pages, such as items, comments, feedback or content posted on our social media pages;
- Geolocation Data, including physical location of your device(s) through collection of data by using satellite, cell phone tower or Wi-Fi signals;
- Information We Obtain from Third Party Social Media Services, such as Facebook, LinkedIn, Twitter, Google, Instagram and similar sites.
- Information We Collect from Publicly Available Sources, including registers, the internet, public authorities, previous employers, educational institutions, suppliers and vendors without obligations of confidentiality;
- Market and Research Information, such as IP address, social media handle, or other online identifiers of a person, email address/mobile number if used for direct marketing and name and address, demographic data, (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers);
- Cookies, web server logs, web beacons and other technologies (See also Cookies Section below); and
- Information from your computer and mobile devices (where allowed by individual browsers and/or operating systems), such as:
- Unique device identifiers (e.g., Media Access Control (MAC) and Internet Protocol (IP) addresses);
- Browser type, version, language, and display/screen settings;
- Information about how you use and interact with our Site and App (e.g., activities on pages visited, links clicked or unique and measurable patterns such as keystrokes, mouse clicks and movements, swipes and gestures);
- Responses to advertisements on sites and mobile apps where we advertise;
- Log information, such as your search and voice to text queries in the mobile app;
- Search engine referrals;
- Geolocation information; and
- Social media preferences
HOW WE USE THE INFORMATION WE COLLECT
We use your personal and other information to:
- Manage our contractual relationship with you, including providing you with information regarding our Services and products, billing and order information, handling claims, troubleshooting, system maintenance, hosting and providing customer support services;
- Set up and manage your Civex account and profile, including to maintain your use and/or subscription of any Services and contact you regarding your account;
- Provide, develop and improve the Services and products we may offer to you, including delivering our Services to you and for additional purposes that help us to develop and improve the quality of such Services and products (including as part of the development of any new products and services);
- Facilitate communication between you and us;
- Protect against, identify and prevent fraud or other criminal activity, claims and other liabilities that we may notice based upon any activity on your account or your use of the Services;
- Monitor your use of the Civex System as part of our operations in maintaining the Services, provided you understand Civex is not obligated to monitor your use of the Civex System;
- Improve the security and other related system and network functions, including preventing misuse;
- Perform analytics, including trend and financial analysis, market and consumer research, anonymization and aggregation of personal information; and
- Conduct marketing activities in accordance with applicable laws. Depending on your jurisdiction, you will either be required to opt in to receive marketing communications or opt out by using the unsubscribe link in any marketing materials you receive via email from us or by contacting us at the link provided on our website.
HOW WE SHARE YOUR INFORMATION
- We share your personal information in the following limited situations with:
- Authorized Users that you invite;
- Our Third Party Business Partners, such as Finicity, when you choose to link your accounts at a brokerage firm or financial institution to the Civex System;
- Our Service Providers, who provide some of our Services to you, including processing, storage, and technical assistance whereby we have entered into contracts with such service providers which include limitations on their use of certain of your information and only as necessary to provide these Services to us/you;
- Professional Advisors and Governmental Authorities if we believe in good faith that disclosure, access, use or preservation of such information is necessary to (i) meet any applicable law, regulation, legal process or governmental request; (ii) enforce or investigate your compliance with the terms of any of our contracts or policies we have with you for potential violations; (iii) protect against physical, financial or other harm against the rights, safety or property of you, us, or any third party; and (iv) investigate fraud, technical, security or other operational issues; and
- In connection with Corporate Transactions, meaning changes to our corporate structure due to sale, transfer, merger or other reorganization of our company during which your personal information may be among the items sold or transferred.
- We may share your non-personal information with:
- Our Third Party Business Partners;
- Our Clients and Customers with whom we have a relationship; and,
- Other Users, including aggregated or anonymized customer data related to, for example, use and consumption of the Services, to help us improve the Civex System or raise awareness about safety issues.
Third Party Data Sharing
In order to optimize and enhance your experience on our Sites and App, Civex offers aggregation services that allow you to share and consolidate your account data from third party sources (e.g., your brokerage firm or financial institution) so that you may access and view the data in one location and perform certain actions related to your accounts (e.g., shareholder voting).
You may link, as part of the Services, your accounts at brokerage firms and financial institutions you have a relationship with, which would include information about yourself and your relationship with the brokerage firm or financial institution, including any account information at such brokerage firm or financial institution.
Civex will use such account information for the sole purpose of providing aggregation services on our Sites and App. For greater certainty and the avoidance of doubt, Civex has access to information only and does not have access to (and will not access) your brokerage firm or financial institution account(s) for any reason.
If you decide to remove such account information associated with your brokerage firm or financial institution account(s), you may no longer have full functionality of our Sites and App.
We are not responsible for the use or disclosure of any personal information accessed by your brokerage firm or financial institution.
HOW WE SECURE YOUR INFORMATION
The security of your information is important to us. We practice industry standard security methods, including building defense in depth in our Services to address appropriate technical, administrative, electronic, and organizational safeguards to protect your information from unauthorized use, disclosure, and loss. Encryption technology, including current industry-standard encryption protocols, is used to protect personal information. We also use a variety of physical and infrastructure protection measures that comply with applicable regulations to protect and store your personal information. However, despite our efforts to secure your information, we cannot be responsible for the security of the information you transmit over networks that we do not control, including the Internet and wireless networks whether they are yours or others.
WHERE YOUR PERSONAL INFORMATION IS USED OR ACCESSIBLE INCLUDING ANY INTERNATIONAL TRANSFERS
Civex is located in the United States, and as such, all personal information will be accessed by us and stored there, and will be transferred there should you live in another country. By using the Civex System, you consent to the transfer of your personal information to the United States, if applicable.
RETENTION OF YOUR PERSONAL DATA
We retain your personal information as follows:
The period during which we store your personal information varies depending on the purpose for the processing:
- For the provision of our Services and products, for so long as you are a customer or subscriber to the Services.
- For marketing purposes, until you have opted out of receiving further direct marketing communications in accordance with applicable law.
The applicable information, and location and infrastructure where your personal information is stored or can be accessed is as follows:
- Within Civex’s infrastructure, such as on our or our service provider’s servers or cloud environment, where we may store your personal information, including but not limited to photos, videos, audio, email address, account profile information, until you delete it, edit it, or for as long as you remain a customer or for such period for us to meet a business operational need, resolve disputes, mount a legal defense, enforce agreements, conduct audits and comply with laws. Further, you can request that we provide you with access, amend or delete your personal information on our servers in certain cases.
WEB BROWSER SETTINGS
We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we will review the feature and determine whether the functionality may work with our Website accordingly.
For Authorized Users in the United States:
9 West Broad Street, Suite 320
Stamford, CT 06902