CIVEX PRIVACY POLICY

Last updated: March 2022

Civex LLC (“Civex”, “we”, “us”, or “our”) respects the privacy of our users. This Privacy Policy explains the type of personal information that we collect and how we collect, use, access, disclose, safeguard, store and otherwise process personal information of our users (i.e., any information that personally identifies you, such as your name and contact information), when you use the Civex products and services including, but not limited to, the Civex Website Application, Civex Mobile Application (collectively the “App”) and related software applications, mobile software applications, use of our websites (“Site”) collectively referred to herein as the “Civex System”, and any services, including subscription services, made available to you via the Civex System (“Services”).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use the Civex System. By clicking to accept these terms in our App, you acknowledge and agree (i) to the terms of our Privacy Policy and any other applicable agreement that may be provided together with the Services; and (ii) that we have your permission to collect and process your personal information as described in this Privacy Policy. If you are agreeing to this Privacy Policy on behalf of an organization or entity, you represent and warrant that you are authorized to agree to this Privacy Policy on behalf of that organization or entity and to bind them to these provisions (in which case, the references to “you” and “your” in this Privacy Policy, except for in this sentence, refer collectively to you personally and to that organization or entity).

We may need to make changes to this Privacy Policy as privacy laws change, our Services evolve, or we add or change service providers among other things. As a result, we reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. We will also attempt to notify you via email or through the App should a material change occur. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on our website at www.civex.io, and you waive the right to receive specific notice of each such change or modification. Your continued use of the Civex System following the posting of changes to these terms means you accept the updated Privacy Policy.

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;
Comply with a legal, regulatory or relevant industry standard obligation, including this Privacy Policy, intellectual property infringement, or enforcing our Terms of Service or other contracts you have entered into with 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;
Third Party Service Providers for Website and App Analytics, including automated technology to collect and analyze your information, including personal information to help us understand your use and optimize your customer experience (please see our section on Cookies and our separate Cookie Policy to learn more);
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.

Note: Our Privacy Policy does not cover any information that you provide to a third party. Such third party’s use of your personal information will be covered by its own privacy policy.

Any data that Civex receives from third parties will be processed and stored by Civex in accordance with the terms of this Privacy Policy.

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.
In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy or such retention period as required by law, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.

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.

USE OF COOKIES AND OTHER DATA COLLECTION TOOLS

Cookies are small text files placed on a user’s computer, smartphone or tablet and are commonly used to collect personal information. Cookies are sent to your browser from a website and stored on your device. To enable our systems to recognize your browser or device and to provide and improve the Services, we use cookies and other data collection tools and similar technologies, such as pixels. These data collection tools measure and track customers’ visits to and browsing activities as part of the Services and to compile sales and statistical data.

For example, beacons let us know when a subscription to our Services is initiated by an advertisement that we placed on a third party’s website. This information assists us in marketing and managing our Services and enhancing your experience. For more information about cookies and how we use them, please read our Cookie Policy which can be found at www.civex.io.

WEB BROWSER SETTINGS

You can opt out of our use of cookies to recall information about you by setting your browser not to accept cookies or to disable cookies. Most browsers also offer additional built-in tools to help you manage, control, and delete cookies, including cookies used for advertising.

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.

MINORS

You must be at least 18 years old to use the Services. Any use or access to the Services by individuals under the age of 18 is strictly prohibited and is a violation of this Privacy Policy.

CONTACT US

If you have any questions about this Privacy Policy or if you would like us to update information we have about you, change your preferences or exercise applicable data protection rights, please contact us by e-mail at privacy@54.204.212.119 or write to us at:

For Authorized Users in the United States:

Civex LLC
9 West Broad Street, Suite 320
Stamford, CT 06902