Last updated: June 3, 2021
“Personal Information” refers to information that can be used to personally identify you, a specific individual. Different states, countries, and laws define Personal Information (or similar terms, such as “personally identifiable information” and “personal data”) differently, but Personal Information generally includes information such as your name, mailing address, e-mail address, and phone number. It may also include the internet protocol (IP) address of your computer or mobile device if that IP address can be associated with other Personal Information and used to identify a particular person, or geo-location information, again if that information can be used to pinpoint a specific party. It may also mean your financial or account information. The types of Personal Information that we collect are identified in Subsection C., infra.
Except as set forth below, we will collect Personal Information from you only if you voluntarily provide it to us. For example, if you submit information in connection with opening an account, if you decide to contact us, such as through a “Contact Us,” “Request More Information,” or similar links on the Site, if you request information about our services, if you enter your information on our Site, or if you sign up to receive newsletters or other materials, you may provide us with your name, email address, and any other information you include with your submission.
If you choose not to provide certain Personal Information, that choice may make it difficult or impossible for you to access services through the Site. For example, you may not be able to set up an account or access our services. However, it is ultimately your choice whether you want to interact with us. In addition, our site, like most websites, automatically collects certain information from site visitors, such as the IP address or other unique identifier of your computer or other device, and information about the browsing history and website interactions associated with that device. This device and online activity information may be considered Personal Information. However, we do not use this type of automatically-collected Personal Information to identify or to further interact with a particular person unless and until that user voluntarily provides other Personal Information in the manner outlined above. More information about how we use this information on an anonymous and/or aggregate basis is described below under “How We Collect and Use Non-Personally Identifiable Information.”
The Personal Information you may be asked to provide to us, and how we may use that Personal Information, is described below. We present this information based on the categories of Personal Information collected, but please note that similar specific pieces of information may apply to multiple categories. For example, your name and email address may be included within each of the “Contact Information,” and “Communication, Activity and Marketing Information,” described below.
|Category of Information||Why We Collect It||How We Use It|
|Contact/Identity Information Examples:||We collect this information as necessary for us to enter into and/or perform a contract with you and as required or permitted by applicable law. For example, we collect information:|
To help us identify you.
To provide you with information and services you have requested.
To provide relevant information to you while browsing our website or upon your request, to assist you with products and services. Subject to your right to opt out, to market to you by email or other electronic means.
To provide relevant information to you while browsing our website or upon your request, to assist you with products and services.
Subject to your right to opt out, to market to you by email or other electronic means.
|Communication. Activity and Marketing Information Examples: Contact Information, Email communications, Text (SMS) communications, Phone conversations/recordings, Appointment requests, dates and statuses, Public posts made by you, Testimonials and opinions, Images|
We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need to provide you with information about products or services you have purchased. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below. Where legally necessary, we will obtain your consent to collect this information (such as to use your image in photos and videos).
|To allow you to participate in interactive areas of the Site, such as participating in discussion forums or providing comments to others’ posts. To ensure the quality of our services and interactions with you. To provide you with information and services you have requested. To assist you with the products and services that you have purchased. Subject to your right to opt out, to market to you by email or other electronic means. To provide the public with information about the products and services for purposes of marketing.|
|Personal/Demographic Information Examples:||We collect this information as necessary for us to enter into and/or perform a contract with you and as required or permitted by applicable law. For example, we collect information:|
|Application Information Examples:||We collect this information as necessary for us to enter into and/or perform a contract with you and as required or permitted by applicable law. For example, we collect information:||To assist you with the products and services that you have purchased.|
In addition to the Personal Information that we collect directly from you through your interaction with the Site and your participation in services we offer, we may collect some Personal Information from third parties. We collect Personal Information from these third parties as required or permitted by applicable law. In particular, third-party sources may include public databases, credit bureaus, identity verification and due diligence providers, resellers and channel partners, joint marketing partners, and social media platforms. We also receive Personal Information from third parties who you have authorized to disclose information about you and that we need to open your account or to effect transactions and operations for you. We also collect Personal Information about you from third parties to satisfy our KYC and AML obligations.
In addition, all of the Personal Information we collect may be used for the following additional purposes, all of which are related to the operation of our business and our provision of services:
When we use your Personal Information for our business purposes, those business purposes include making our products available, responding to your, our customers’ and potential customers’ comments and complaints, marketing our products and services, improving and developing new products and services, and ensuring the productivity, functionality, and security of the Site.
We will keep your Personal Information as long as we have a business need to do so and/or as necessary to meet the purpose for which the information was collected and used, unless a longer period is required by law. For example, we will keep Personal Information for at least as long as you continue to maintain an account on our Site. Business needs for which Personal Information may be retained include legal, tax, accounting, risk management, and other business purposes.
We are required, moreover, under certain applicable laws and regulatory requirements to retain certain information, including Personal Information of clients, client profiles, identity verification documents, and other information used to satisfy our KYC and AML obligations. We retain these records for the minimum amount of time required by law and as specified in MTI’s document retention policy. Even after you deactivate your account, we can and may retain information about you, your transactions, and services, for a period of time consistent with applicable law and/or as is reasonably necessary to comply with regulations, legal processes, or government requests.
In addition, it is important to note that some information may be made public. For example, with your consent we may use your image and testimonials in promotional materials. Accordingly, your information will be able to be seen and republished for as long as the marketing materials continue to be posted online, or as long as the hard copies remain in existence. In addition, we may make available services that enable you to post information on the Site in public forums and on message boards. In these cases, once posted the information will be able to be seen and republished by others for as long as the web page remains active. Even if web pages are deleted, they may continue to be accessed if they are archived or cached. Therefore, you should think carefully before giving your consent to the use of your name, image, and comments in any materials and, if applicable, before posting anything in any public area of the Site.
Non-personally identifiable information refers to information that is not and cannot be used to identify a specific individual. This may include information about the statistical characteristics of the visitors to the Site or persons who purchase our products or services. While this information may define how you fit into a particular group of people, it is not unique to you, and it cannot be used (without other information) to specifically identify you. This section describes how we collect and use non-personally identifiable information.
When you visit the Site or interact with us electronically (such as through email), we may automatically collect standard internet and website log information, and details of patterns about how the Site visitors behave. This information includes your internet service provider name, your operating system, your browser type and browser language, the IP address of your computer or other device (unless such IP address can be used to identify you), your access times, the website that referred you to the Site, the specific web pages you visit and the date and time of those visits, and links clicked as you visit the Site. We use this information to evaluate the Site, to find out which parts of the Site are popular or that may need improvement, and to enhance your and others’ Site experiences.
The Site may use analytics tools and services to collect information about use of the Site, such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to visiting the Site. We use the information we collect from the analytics services to maintain and improve the Site and our services. The analytics services we use include Google Analytics, Facebook Ads, and others.
Anonymous information refers to information that does not enable identification of an individual user, such as aggregated or demographic information. We may use anonymous information or disclose it to third party service providers to improve the Site and our services. We may also disclose anonymous information to third parties, including market research firms.
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing when you visit a website. Some cookies are deleted once you close your browser or application (session cookies), while other cookies are retained even after you exit so that you can be recognized when you return (persistent cookies). Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.
Most web browsers automatically accept cookies, but you can usually change your settings to prevent that, such as by having your device warn you each time a cookie is being sent or choosing to turn off all cookies. On the Site, you will be able to disable all cookies other than mandatory cookies. This can be done through your web browser settings, and because each browser is different, you should look at your browser’s “Help” menu to learn how to modify your cookie settings. There are also online resources that may help you learn more how to opt out of targeted behavioral advertising from many major third-party network advertisers. If you do disable cookies from your browser you may not be able to access certain sections of the Site that use essential cookies, and this may make your experiences on the Site less efficient.
Currently, certain browsers, including Firefox, Google Chrome, Safari and Internet Explorer, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. However, we do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.
We will never sell your Personal Information.
We use a variety of industry-standard security measures to maintain the safety of your Personal Information, including measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. We store the Personal Information you provide on secure (password- and firewall-protected) servers. Unfortunately, no electronic data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we believe that we use reasonable measures to protect Personal Information, we cannot ensure or warrant the security of any information transmitted or otherwise provided to us or received from us. If any portion of the Site allows you to create an account, it will be your responsibility for keeping your account and password confidential. We will never ask for your password (except, if applicable, when you create your account and log into the Site).
Currently, we do not sell your personal information
Depending on the jurisdiction in which you reside, you may have certain rights over the Personal Information that we collect about you. You may exercise these rights by contacting us at email@example.com.
The Vermont Financial Privacy Act limits what we can do with your financial information and gives you the right to limit our sharing of your financial information. Under this Act, Vermont residents have the right to receive notice and opt-in to us sharing non-public personal information with non-affiliated third parties. In addition, residents must consent to us sharing information regarding credit worthiness. Please contact us at firstname.lastname@example.org to opt-in to, or opt-out of, sharing your non-public personal information.
The CCPA went into effect on January 1, 2022. It affords California residents with specific rights over their Personal Information, which are described in more detail in the following paragraphs.
We collect personal information as defined in the CCPA, which generally means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Please note that personal information does not include the following:
We use the information for one or more of the following purposes:
In addition to the business and commercial purposes of collection of personal information described above, we may use any of the personal information we collect for the following purposes:
We will not use the personal information we have collected for any materially different, unrelated, or incompatible purposes not disclosed in this California Privacy Notice without providing you notice and, if required by the CCPA, the opportunity to consent to such use
With respect to the personal information we collect, we may share information in the following categories with third parties, in each case for a business or commercial purpose:
We may share the personal information in the categories identified above with our corporate partners, such as Genesis Capital, and our service providers, such as companies who handle our data management and/or email distribution, parties who provide us with data enrichment services, our website and infrastructure hosting providers and our managed information technology support service provider, and also to third parties to whom you authorize us to disclose your personal information in connection with our services.
We do not sell personal information to third parties.
The CCPA provides California residents with specific rights regarding their personal information. If you are a California resident, this section describes your CCPA rights, and explains how to exercise them.
You have the right to ask up to provide you with information about our collection and use of your personal information over the past 12 months. You may request the following information:
You have the right to ask us to delete any of your personal information that we collected from you and have retained. However, there are certain exceptions to our obligation to delete the information, which we describe below. We may deny your deletion request if we or our service providers need to keep the information to:
To exercise any of the rights described above, you must submit a verifiable consumer request to us by emailing us at email@example.com. Only you, or a person registered with the California Secretary of State that you expressly authorize to act on your behalf, can make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within any 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with information if we cannot identify you or confirm your authority to make the request. We will only use any personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will confirm receipt of a verifiable consumer request within 10 days, and with that confirmation, we will include a description of our verification process and will provide an expected response timeframe. Generally, we will respond to each verifiable consumer request within 45 days of receipt. If we require more time, subject to the limitations imposed by the CCPA, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically using the contact information you have provided. Any disclosure we provide in response will only cover the 12-month period preceding our receipt of the request. If we cannot comply with your request, we will explain why. If you request that we provide you with a copy of your data, we will select a format in which to provide your personal information that is readily usable, and should allow you to transmit the information from one entity to another without undue difficulty. We do not generally charge a fee to process or respond to requests, unless the request is excessive, repetitive, or manifestly unfounded. If we determine that a fee is warranted by the circumstances, we will tell you why, and will provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. This means that unless we are permitted to do so by the CCPA, we will not:
The Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Information from children under the age of 13. If you are a parent or a legal guardian who believes that your minor child provided us with any Personal Information, please contact us at firstname.lastname@example.org.