Updated: September 1, 2020
CoFi, Inc., ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:
• The types of information we may collect or that you may provide when you complete a form on www.cofimd.com (the "Website").
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect in this Website and, in email, text, and other electronic communications sent through or in connection with this Website.
This policy DOES NOT apply to information that:
• We collect offline or on any other Company apps or websites, including websites you may access through this Website.
• You provide to or is collected by any third party (see Third-Party Information Collection).
• Our other websites and applications, and these other third parties, may have their own privacy policies, which we encourage you to read before providing information on or through them.
Children Under the Age of 16
The Website is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us via the form on the contact us page of the Website.
Information We Collect and How We Collect It
We collect information from and about users of our App:
• Directly from you when you provide it to us.
• Automatically when you use the Website.
Information You Provide to Us
When you complete a form on this Website, we may ask you provide information:
• By which you may be personally identified, such as name, postal address, email address, telephone number, and any other identifier by which you may be contacted online or offline ("personal information").
This information includes:
• Information that you provide by filling in forms in the Website.
• We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Website.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
Automatic Information Collection and Tracking
When you access and use the Website, it may use technology to automatically collect:
• Usage Details. When you access and use the Website, we may automatically collect certain details of your access to and use of the Website, including traffic data, logs, and other communication data and the resources that you access and use on or through the Website, such as web request, Internet Protocol (“IP”) address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Website, domain names, landing pages, pages viewed, mobile carrier, date and time stamp information and other such information.
• Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number. We may associate this device identifier with your Service account and will use data associated with your device identifier to customize our Services to your device and to analyze any device-related issues.
• Stored Information and Files. The Website also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
If you do not want us to collect this information do not download the Website or delete it from your device.
We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
• Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
We do not currently recognize or respond to browser-initiated Do Not Track signals that provide a method to opt out of the collection of information about online activities over time and across third-party websites or online services as there is no consistent industry standard for compliance
Third-Party Information Collection
When you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.
These third parties may use tracking technologies to collect information about you when you use this Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
• Provide you with the Website and its contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account and/or subscription, including expiration and renewal notices.
The usage information we collect helps us to improve our Website and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Recognize you when you use the Website.
We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us. We may use the information we collect to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
In addition, we may disclose personal information that we collect or you provide:
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the Website EULA, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
• Promotion by the Company. If you do not want us to use your email address to promote our own or third parties' products or services, you can opt-out by contacting us. You can also always opt-out by logging into the Website.
• Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by contacting us.
• Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by contacting us. You can also always opt-out by logging into the Website.
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email to request access to, correct, or delete any personal information that you have provided to us.
We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.