Settle Privacy Policy

(Effective November 12, 2018)

 

proveq, LLC, d/b/a Settle Finance and its subsidiaries and affiliates (collectively, “Settle,” “we,” “us,” or “our”) appreciates your interest in our products and services, and we are aware that you are concerned as to how the information you provide to us is used and shared with others. This policy describes the types of information we may collect from you or that you may provide when you visit our platform at https://settle.finance (the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. By submitting Personal Information on or through the Platform, you agree to the terms of this Privacy Policy, and you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and considered a part of the Settle Terms of Use Agreement [LINK] (“Terms”). If any provision in this Privacy Policy is inconsistent or conflicts with any provision in the Terms, this Privacy Policy will control with respect to the subject matter hereof. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms. If you have any questions, please, contact us at: privacy@settle.finance

Our Privacy Policy consists of both this Privacy Policy, and, where applicable, the GDPR Privacy Notice (“GDPR Privacy Notice” or “Notice”). If you are a resident of a country located in the European Union or the European Economic Area (including, for purposes of this Privacy Policy, Switzerland and the United Kingdom), please refer to our GDPR Privacy Notice, which appears below and which applies to Personal Information of EU residents collected by us. If we transfer Personal Information concerning EU residents between the European Economic Area (EEA) and the United States, the GDPR Privacy Notice applies. (See the GDPR Privacy Notice for information on transfers of information from the EEA.)  

We have established a comprehensive privacy program – including the appointment of a Privacy Officer – designed to help us respect and protect your data privacy rights. It describes the types of information we gather, how we use it, and the notice and choices affected individuals have regarding our use of and their ability to correct that information.

What kind of information does Settle collect?

We typically collect two kinds of information about you: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you that we automatically collect when you visit our Platform or that you provide us.

 

  • Personal Information: As a general policy, we do not automatically collect your Personal Information when you visit our Platform. “Personal Information means any information relating to an identified or identifiable natural person. Specifically, Personal Information includes your name, postal address, email address, phone number, date of birth, driver’s license number or other government-issued ID number, financial account information, and similar information. We may request, collect, or provide you an opportunity to submit your Personal Information in connection with certain activities on our Platform, including but not limited to:

 

  • Registering Accounts on the Platform, applying to become an App Developer or Chat Hub Owner, or enrolling as an App Developer or Chat Hub Owner in our subscription-share program
  • Participating in surveys or questionnaires or submitting Feedback
  • Subscribing to our mailing list
  • Registering for a Settle Virtual Hackathon
  • Responding to user inquiries, fulfilling user requests, and providing customer service
  • Sending communications related to changes or upgrades to Platform services, policies, or terms of use
  • Correcting and updating our records (this may involve collecting, e.g., address information from third parties)

Personal Information includes “Sensitive Information,” which is Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual. We do not knowingly collect Sensitive Information when we request Personal Information.

Whether or not you provide Personal Information to us is your choice; however, in many instances this type of information is required to participate in a particular activity, realize a benefit we may offer, or gain access to certain content or services on our Platform.

 

  • Non-Personal Information:Non-Personal Information” is any information that does not personally identify you. Non-Personal Information can include certain Personal Information that has been de-identified; that is, information that has been rendered anonymous. We may obtain Non-Personal Information about you from information that you provide us, either separately or together with your Personal Information. We also may automatically collect certain Non-Personal Information from you when you access our Platform. This information can include, among other things, IP addresses (to the extent not considered Personal Information under applicable law), the type of browser you are using, the third-party website from which your visit originated, the operating system you are using, the domain name of your Internet service provider, the specific apps, Chat Hubs, and other areas of the Platform you engage with and the frequency and duration of such engagement, and related information.

 

We may collect Non-Personal Information through third-party business partners. Currently, we use Google Analytics, which uses cookies and similar technologies (e.g., web beacons) to collect and analyze information about use of the Platform and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. A User can learn about Google’s practices by going to www.google.com/policies/privacy/partners and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

What are cookies and web beacons?

We may automatically receive and store certain types of Non-Personal Information whenever you interact with us. For example, we (or our third-party business partners) may use cookies and web beacons (also called clear gifs or pixel tags) to obtain certain types of information when your web browser accesses our Platform. “Cookies” are small files that are transferred to your computer’s hard drive or your Web browser memory to enable us to recognize your browser and to provide you with convenience and other features, such as recognizing you as a frequent user of our Platform. “Web beacons” are tiny graphics with a unique identifier; they are similar in function to cookies and may be used to track the online movements of users, when an email has been opened, and related information. For more detailed information about cookies, you may wish to visit www.allaboutcookies.org
(unsecure site) or https://www.consumer.ftc.gov/articles/0042-online-tracking.

Examples of the information collected analyzed in this manner include the IP address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; your behavior on our Platform, including the URL you come from and go to next (whether this URL is on our Platform or not); and cookie number.

What does Settle do with the Personal Information you provide?

We use the Personal Information you submit to us to:

  • Respond to your requests
  • Customize marketing and sales initiatives to your specific needs
  • Communicate product or service information that might be useful or urgent in nature, including promotional information, information regarding Platform issues or features, or information regarding your Account, Application, or Chat Hub
  • Communicate significant Platform changes or upgrades
  • Provide future service and support

What does Settle do with Non-Personal Information?

We use Non-Personal Information in a variety of ways, including to help analyze traffic, understand user needs and trends, carry out targeted promotional activities, and to improve our services. We may use your Non-Personal Information by itself or aggregate it with information we have obtained from others.

Non-Personal Information regarding users’ usage of apps and Chat Hubs is collected in order to calculate attention scores, which are used to determine what amount of subscription-share App Developers and Chat Hub Owners are entitled to.

We may share your Non-Personal Information with our affiliated companies and third parties – including App Developers and Chat Hub Owners on Settle through Settle’s API – to achieve these objectives and others. But remember that aggregate information is anonymous information that does not – and cannot be used to – personally identify you.

If we are required to treat Non-Personal Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

Children under the age of 18.

Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to the Platform. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Platform or on or through any of its features, register on the Platform, use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected]

Do you use preference-based advertising?

We do not currently share Personal Information that we collect for preference-based advertising purposes, and we do not currently have any plans to do so through this Platform.

What are Settle’s security measures?

Settle takes steps we consider reasonable to protect Personal Information collected via this Platform from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Settle has put in place appropriate physical, electronic and managerial procedures designed to safeguard and secure the Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Settle runs on Amazon Web Services (“AWS”) cloud infrastructure. All User data is stored on Settle’s servers hosted on AWS Region us-west-1 in Northern California, USA. You can read more about Amazon AWS data privacy at https://aws.amazon.com/compliance/data-privacy-faq. By virtue of Settle’s agreement to AWS’s Customer Agreement (https://aws.amazon.com/agreement), Settle is party to and bound by the AWS GDPR Data Processing Addendum (https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf), ensuring GDPR compliance as to any European Users of Settle.

Keep in mind, however, that despite such reasonable safeguards, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. In the unfortunate event that your Personal Information is compromised, we may notify you by email (at our sole and absolute discretion except where required by law) to the last email address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time, we evaluate new technology for protecting information, and, when appropriate, we upgrade our information security systems.

Under what circumstances does Settle share information?

Settle does not sell, trade, or rent your Personal Information to others. Unless we have your permission or are required by law, we will only share the Personal Information you provide online with our affiliated entities, App Developers and Chat Hub Owners on Settle, and business partners acting on our behalf to complete the activities described above.

You will be given the opportunity to opt out: (i) if we decide to share your Personal Information with a third party (unless that third party is acting as an agent to perform tasks on behalf of us and under our instructions); or (ii) if your Personal Information is to be used for a purpose that is incompatible with the purposes for which it was originally collected or subsequently authorized by you. We do not share Sensitive Information with anyone under any circumstances.

Our business partners and subcontractors (including App Developers and Chat Hub Owners on Settle) who receive Personal Information are required to maintain the confidentiality of any data we provide or that they access in providing their services to us or making services available on the Platform and to apply security protection measures that are consistent with our promises under this Privacy Policy. We will ensure that any third party to whom Personal Information may be disclosed agrees in writing to provide an adequate level of privacy protection and to share Personal Information only with those in their organizations with a need to know. These companies are authorized to use your Personal Information only for the purposes that we originally instructed, or as authorized by you.

Email Communications: We may share your email contact information with our partners to assist with marketing our products and services. You may unsubscribe from receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of any marketing emails we send, or by emailing us as provided in the “Contact Us” section below. However, we reserve the right to send you transactional emails such as customer service communications in connection with services you have purchased. For security reasons, we do not recommend that you send personally identifiable information, such as passwords, private keys, social security numbers, or bank account information to us by email.

Transfer of Assets: We do not sell or lease Personal Information or provide a list of our users to third parties, except as described above. However, as we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the information we have about you will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Necessity: Notwithstanding anything herein to the contrary, we reserve the right to disclose any information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property or the Platform; or (d) in an emergency to protect the health and safety of the Platform’s users or the general public.

Links to Websites Outside Settle

This Privacy Policy may contain links to other websites that may be of interest to you. These links are provided as a courtesy, and it is likely that the owners of these sites have their own privacy policies separate from those of Settle. We suggest that you review these privacy policies before providing Personal Information. Settle will have no responsibility or liability for any of these links.

Your Consent

BY VISITING THE PLATFORM, YOU ARE ACCEPTING THE POLICIES THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND CONSENTING TO THE COLLECTION AND USE OF INFORMATION BY SETTLE. WE WILL POST ANY CHANGES TO THIS POLICY THAT WE MAY MAKE FROM TIME TO TIME ON OUR PLATFORM. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY OR TO ANY CHANGES THAT WE SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR PLATFORM.

Contact Us

Questions or comments regarding this Privacy Policy should be submitted to our Privacy Officer by email as follows: [email protected]

You can also reach us by U.S. mail:

Settle Finance Privacy Officer

c/o Proveq, LLC

901 Woodland St.

Nashville, TN 37206 USA

Changes to Privacy Policy

This Privacy Policy may be amended from time to time in our sole discretion. The effective date of the Privacy Policy may be found at the top of the Privacy Policy.

Settle Finance

GDPR PRIVACY NOTICE

Effective November 12, 2018

Introduction

This GDPR Privacy Notice is a supplement to our Privacy Policy and concerns certain personal data (“Personal Information”) we have collected about residents of the countries in the European Union, the countries in the European Economic Area, Switzerland, and, to the extent that the United Kingdom is no longer a member of the European Union, the United Kingdom. This Notice explains why we have that information, how we use and handle it, and your rights to that information, all as required by the European Union’s General Data Protection Regulation (EU) 2016/679 (“GDPR“).

What Personal Information do we hold?

Information you provide to us

We may collect your personal contact information such as name, email address, mailing address, phone number, country of residence. In connection with Account creation, you must provide your email address, a password, and, depending on the subscription level you choose, a username that you select (your username need not be your real name). You may also provide a profile image. In connection with applying to become an App Developer or Chat Hub Owner on Settle, you must provide the above information plus your name (or organization name) and an email address or Discord handle for a technical contact.  

Information we collect from others

We may receive information about you, such as your personal contact information including your name, email address, phone number, mailing address, and country of residence, from our vendors or affiliates or in the context of providing to servicing and support to our users.

We also may receive information about you from App Developers or Chat Hub Owners on Settle. In addition to your IP address and other Non-Personal Information, this may include your name, email address, phone number, country of residence, password, username, and profile image.  

Where did we get your Personal Information?

We collect your Personal Information when you register for an Account on the Platform, register for a hackathon, register for our mailing list, or apply to become an App Developer or Chat Hub Owner on the Platform, enroll as an App Developer or Chat Hub Owner in our subscription-share program, or ask us to contact you. Your failure to provide this information means we cannot fulfill your request. We may also collect your contact information when you provide it by using our Platform (including third-party apps and Chat Hubs). We may, directly or through third-party business partners such as Google Analytics, collect your IP address and other information about your activity on our Platform, such as what areas or pages you visit and what apps and Chat Hubs you use. We may also receive Personal Information when we are working on the resolution to our users’ problems.

What is our purpose for holding your Personal Information?

Our lawful basis for holding your information depends on the circumstances under which we acquired it:

Type of Information Lawful Basis for Processing
User and prospective user contact information collected in connection with a registration, order, or inquiry Consent or for fulfillment of a contract
User and prospective user contact information collected for use in marketing additional products and services Consent or Legitimate Interest

 

What we do with your Personal Information

We use your details so that we can communicate with you by email or phone and inform you of our services, the status of your order, information regarding your Account, information regarding any Chat Hub you operate, information about Applications or your status as Chat Hub Owner or Developer, or questions about payment of your invoice. We may also collect your IP address and details concerning your activity while on our Platform in order to understand your interests and preferences.

The Personal Information we hold is stored and processed securely in line with the information security measures and guidance standard in our industry. We have implemented appropriate technical and organizational measures designed to prevent the unauthorized disclosure of your Personal Information, taking into account the level of risk associated with the processing of your Personal Information.

If we receive your Personal Information in the context of providing problem solving services to our users, we will securely accept that data, segregate it from other user data, and limit access to the data. We will delete the data once the issue is resolved.

Cross-border transfers of Personal Information

Your Personal Information may be transferred to and stored at our servers hosted on AWS Region us-west-1 in Northern California, United States. The United States has Personal Information privacy laws that are different from your country. While the United States has not received an adequacy decision from the European Commission, we will ensure that your Personal Information is protected in a manner that is consistent with how it would be protected if it were processed in your country.

What we don’t do with your Personal Information

We do not pass your information to anyone else apart from our affiliated entities, App Developers and Chat Hub Owners on Settle, and business partners as necessary to provide you with the products and services you have requested. We do not use any automated systems relating to your Personal Information. We do not use your Personal Information for profiling.

How long do we keep your Personal Information?

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, or we have obtained your consent.

What are your rights regarding your Personal Information?

You have the following rights concerning your Personal Information that we hold and process (whether directly or through a third-party) that you can exercise at any time:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct Personal Information that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the Personal Information we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
  • Right of portability – you have the right to have the Personal Information we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to judicial review – in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the process below.

All of the above requests will be forwarded on to other parties holding and processing your Personal Information where appropriate.

Who do you contact if you have an issue with your Personal Information that we hold?

Please contact our Privacy Officer at [email protected]

How do you make a complaint about how your Personal Information is being held or processed?

If you wish to raise a complaint on how we handle your Personal Information, you can contact our Privacy Officer as follows:

By Email: [email protected]

By Mail: Settle Finance Privacy Officer

c/o Proveq, LLC

901 Woodland St.

Nashville, TN 37206 USA

 

If you are not satisfied with our response, you can complain to the data protection authority in the country in which you reside.

This GDPR Privacy Notice was last updated on November 11, 2018.