At Gainy Inc., we take privacy and security seriously. This Privacy Policy outlines how Gainy, Inc., a Delaware corporation with its mailing address 1160 Battery Street East, Suite 100, San Francisco, CA 94111, company file number 5045873 and its affiliates (collectively, the “Company,” “Gainy,” “we,” “our,” or “us”) process the information we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels.
I. TYPES OF INFORMATION COLLECTED AND HOW WE COLLECT THEM
Personal Information You Provide:
We may collect the following personal information you provide when you use our Services, like when you sign up for an account, request a transaction, enroll in a promotion or program, or otherwise engage or communicate with us:
1. Identity Data includes your full name, date of birth, gender and other data on government-issued identification documents.
2. Contact Data includes your email address.
3. Profile Data includes your job title, investment approach, investment amount and your interests, preferences, feedback, and survey responses.
II. HOW WE USE YOUR INFORMATION
We use and process the information we collect for purposes described in this Privacy Policy or as otherwise described to you on our Services or in connection with our Services. For example, we use your information to:
1. Communicate with you such as deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, conduct surveys, notify you about upcoming events, or for any other purposes in connection with the Services;
2. Conduct research and analytics to understand our visitors and customers and tailor our product offerings;
3. Provide you with updates about products and services, as well as facilitate new contests, sweepstakes, promotions, and rewards;
4. Make suggestions and recommendations to you about things that are similar to those about which you have inquired or that may otherwise be of interest to you, such as providing you with advertisements based on your interests and activity on the Services;
5. Monitor, administer, and enhance our Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
6. Enhance the safety and security of our Services, business, and users, and investigate or provide notice of fraud or unlawful or criminal activity;
7. Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
8. Comply with applicable laws and legal obligations.
III. DISCLOSURES OF PERSONAL INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information we collect. We may share your personal information in the instances described below. For further information on your choices regarding your personal information, see the “Control Over Your Information” section below. We do not sell or rent your personal information to third parties, aside from substantial corporate transactions (described below).
1. Legal purposes. We disclose personal data to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Gainy, our affiliates, users, or the public.
2. With your consent. We share personal data for any other purposes disclosed to you with your consent. We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
IV. CONTROL OVER YOUR INFORMATION
How to control your communications preferences. You can stop receivingpromotional emails from us by clicking on the provided “unsubscribe” link. You may not opt-out of service-related or other non-promotional communications (e.g., account verification, transactional communications, changes/updates to features of the Services, and technical and security notices).
V. LOCATION OF DATA STORAGE AND PROCESSING
The personal information we collect from you will be stored in the United States and may be stored in other countries that may have different privacy laws and standards than those in your country of residence. Your personal information may be transferred to or processed in the United States by us or by a third-party service provider working for us. If you are located outside of the United States, the transfer of personal information is necessary to provide you with the requested information, products, and services and/or to perform any requested transaction. When we transfer or disclose your personal information to other countries, we will protect that information as
described in this Privacy Policy. By submitting personal information via our website or other means, you agree to such storage, transfers, and processing.
VI. THIRD PARTY SERVICES
Please be aware that third-party websites accessible or recommended through our Services may have their own privacy and data collection policies and practices. These links and features are provided for your reference and convenience only and do not imply any endorsement of the information provided through these third-party links and features, nor any association with their operators. We are not responsible for any actions, content of websites, or privacy policies of such third parties. We urge you to read the privacy and security policies of these third parties.
Gainy uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Gainy and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.
VII. NOTICE TO CALIFORNIA RESIDENTS
This section provides additional details about the personal information we collect about California residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”). CCPA provides California residents the right to request more details about the categories and specific elements of personal information we collect, to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. We do not sell information about you to third parties. In order to help Gainy deliver advertising and marketing on other platforms, we do allow third parties to collect information through our Services. Please see the “Third-Party Tracking and Online Advertising” section above for more details, including choices available to you.
California residents may make a consumer rights request for access to certain personal information subject to the CCPA by sending an email to support@gainy.app. We may verify the request by asking you to provide information that matches the information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.
VIII. TRANSFER OF PERSONAL INFORMATION
Our Services are currently designed for use only in certain select markets. If you are using our Services from another jurisdiction, your information collected through our Services may be stored and processed in the United States or any other country in which Gainy or its parent, subsidiaries, affiliates, or service providers maintain facilities or conduct business activities. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, 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.
IX. CHILDREN’S PRIVACY
We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at support@gainy.app.
X. CHANGES TO THIS POLICY
This Privacy Policy may be updated from time to time, and when we update it, we will revise the "Effective Date" above and post the new Policy on our Site and App. You will receive a copy of our Privacy Policy on an annual basis through the App. To stay informed throughout the year of any updates to our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.
IX. HOW TO CONTACT US
If you have any questions about this Privacy Policy or the Services, please contact us at support@gainy.app.