Updated and effective as of: July 14, 2019
When we say, “we,” “our,” or “us,” we’re referring to Money Pages, our employees, directors, officers, affiliates, and subsidiaries.
When we say “you”, “your” or “User” we are referring to the person or entity that is using the Money Pages Websites (defined below).
When we say “Websites,” we mean our websites located at https://www.moneypages.com/, and other websites that we operate now and in the future, and our content and any third-party services as specified herein.
When we say, “Personal Information,” we mean all of the different forms of data that you provide us and that we collect from you from your use of the Website, your software, and your devices by which you may be personally identified. Personal Information does not include data where your identity has been removed (anonymous data).
- Your California Privacy Rights. California Civil Code Section § 1798.83 permits Users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, or to receive information regarding other rights of California residents, please send an email email@example.com.
- Information We Collect.
- Cookies: When you use the Website, we store “cookies,” which are strings of code, on your computer. We use those cookies to collect information about when you visit our Website, when you use the Website, your browser, your operating system, and other similar information. Most browsers allow you to block and delete cookies. However, if you block our cookies, our Website may not work properly.
- Web Beacons: Our third-party partners may employ web beacons to track online user movement to help us better understand what content is effective. Web beacons are tiny graphics with a unique identifier that are embedded in websites and in newsletter emails. With web beacons, our third-party partners may collect information about you, such as your IP address, your browser or email client type, and other similar details. We use the data from our third-party partners to improve our services.
- Transfer of Personal Information.
- Consent for Users located in the European Economic Area (“EEA”): In order to access and use any Money Pages Website, Users in the EEA must agree to the following: To provide this Website and deliver the Website to you, we must transfer your Personal Information outside of the EEA to our affiliated firms and our third-party service providers located in the United States of America (“U.S.”). The European Commission has determined that allowing non-EU data controllers who are not members of the U.S.-E.U. Privacy Shield to transfer Personal Information from the EEA to the U.S. present various risks to the security of that Personal Information. The Commission has assessed this risk based on its determination that the U.S., and non-EU data controllers who are not members of the U.S.-E.U. Privacy Shield, fail to ensure an adequate level of protection and safeguards for Personal Information in accordance with Article 45 of the GDPR. The Company is a non-E.U. data controller who is also not a member of the U.S.-E.U. Privacy Shield. Notwithstanding the risks discussed in this paragraph, you agree to consent to the transfer of your Personal Information from the EEA to the U.S.. You can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, see the “Contact Information” section below.
- Applicability of Policy. This Policy applies to information that is collected from email, text, and other electronic messages between you and Money Pages; and your navigation through our website, or Personal Information shared with us through your interaction with our applications on third-party websites. It does not apply to information collected by Money Pages offline or any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or on our Websites, unless required by law.
- Children Under the Age of 13. Personal Information of a child under 13 may be provided to us with the verifiable consent of the legal parent or guardian of that child. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 without parental consent, please contact us at firstname.lastname@example.org.
- Adherence to GDPR. Money Pages adheres to the following guidelines, required by GDPR, while processing your data:
- Lawfulness, fairness and transparency. Data is processed lawfully, fairly, and in a transparent fashion.
- Purpose limitation. Data is collected for specified, explicit, and legitimate purposes.
- Data minimization. Data collected on a subject should be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy. Data is accurate and, where necessary, kept up to date.
- Storage limitations. Data is kept in a form which permits identification of data subjects for no longer than necessary.
- Integrity and confidentiality. Data is processed in a manner that provides appropriate security of the Personal Information, including reasonable protection against unlawful processing or accidental loss, destruction or damage.
- Accountability. Demonstrate compliance with GDPR principles.
- How We Use Your Information.We only use Users’ Personal Information when allowed by this Policy or applicable law. Please note that we may process your Personal Information without your knowledge or consent, where this is required or permitted by law.
- To create your account.
- To provide customer support.
- To transfer your information in the case of a sale, merger, consolidation, or acquisition.
- To better understand your needs and interests.
- To send newsletters.
- To personalize your experience.
- To improve our Website and our products.
- To send you updates and alerts and to contact you about your account.
- To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
We may also use your Personal Information to contact you about our own goods and services that may be of interest to you. If you do not wish us to use your information in this way, please see the “Advertising and Marketing” section below.
If you no longer wish to receive our newsletters, you may unsubscribe by following the link located within our emails.
We may use the information we have collected from you to enable us 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 or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
- Use of Personal Information When Governed By GDPR.
- Purpose and Legal Basis.For Users located in the European Union, the purposes and activities for which Money Pages will use your Personal Information or data, and the legal basis for which we carry out each type of processing, are as follows:
|Purpose/activity for which Money Pages will process Personal Information||Lawful basis for processing including basis of legitimate interest|
|To enable you to access information including password-protected areas of the Website||It is in our and your legitimate interest to provide services to you and register you on our Website(s) at your request.|
|To manage our relationship with you, which will include, but not be limited to:
(b) asking you to leave a review or take a survey;
(d) enforcing the terms of any contract entered into with you; and
(e) understanding your preferences, usage patterns, and concerns regarding our services.
|It is in our legitimate interests to:
(a) perform pursuant to the terms of a contract with you;
(b) and (e) keep our records updated, to study how customers use our products/services, and to improve the user experience; and
(c)-(e) to comply with a legal obligation and enforce our rights under contract(s) with You.
|To send you newsletters, e-announcements, and other communications concerning Money Pages.||It is in our legitimate interests to promote our services to existing users, and to keep users apprised of changes and news regarding our services.|
|To administer, protect, and improve our business and services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||It is in our legitimate interests to improve and police our site and services to ensure the security of information transmitted on our website(s) and to run our business effectively. This monitoring may also be necessary to comply with a legal obligation.|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, as well as to deliver other marketing communications to you.||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).|
|To use data analytics to improve our website, products, services, marketing, customer relationships and experiences.||Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.|
|To share information with third parties for those third parties’ direct marketing purposes||Necessary for our legitimate interests (to promote relationships of strategic alliances and partners and grow our business)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you.
To assist law enforcement or other regulatory bodies or legal process in any investigations relating to suspected illegal or wrongful activity, and to protect our rights, property, and safety, or the rights, property, and safety of third parties.
|Necessary for our legitimate interests (to develop our products/services and grow our business).
It is in our legitimate interests to cooperate in any investigations relating to illegal or wrongful activity and to protect our rights or the rights and remedies of third parties.
In instances where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. For information regarding updating your details or changing your privacy preferences, see the “Correcting and Updating Information” section below.
- Change of Purpose.The Company will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or as otherwise required by law. If we need to use your Personal Information for an unrelated purpose, we will notify you in a timely manner, if we are legally permitted to do so, and we will explain the legal basis which allows us to do so.
- Advertising or Marketing.
- Communications. We may use your Personal Information to deliver marketing or advertisement communications relating to our own products and services if you have filled out forms on which we collected your Personal Information (the “Contact Us” form or a contest submission) on our Website. If you do not want us to use information that we collect or that you provide to us to deliver those communications to you, you can opt-out or object by [clicking here] clicking on the appropriate link on the “Contact Us” form or on the contest submission form, as applicable, or by sending us an email stating your request to email@example.com, but without affecting the lawfulness of our processing of your data in that way prior to your opt-out or objection. For this opt-out to function by clicking on any forms, you must have your browser set to accept all browser cookies.
- Third Party Communications.We may provide your Personal Information to our strategic partners or third parties if you have provided Personal Information on the Contact Us or contest submission forms on our Website, as applicable. If you do not wish to have your Personal Information provided to any of our strategic partners or other third parties so that those strategic partners or third parties may promote each of their own products or services to you, you can opt-out or object by clicking on the appropriate link located on the “Contact Us” form or on the contest submission form, as applicable, by clicking [HERE], or by sending us an email stating your request to firstname.lastname@example.org, but without affecting the lawfulness of our processing of your data in that way prior to your opt-out or objection. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience or other transactions.
- How We Share and Disclose Your Personal Information.
- We may share your Personal Information in the following ways:
- We may share information with service providers who provide necessary services to Money Pages and to strategic partners who help us market Money Pages.
- With our strategic partners, who may use that information for their own direct marketing purposes.
- We may share your Personal Information in the following ways:
- To provide customer support.
- When we have your permission to share your information.
- When we have given you prior notice that the information will be shared.
- When we are required by law, or legal process to disclose that information – such as a valid court order or a valid subpoena. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a valid governmental request.
- To enforce our terms and conditions or to protect our operations or users.
- If a transfer of your information is required under the terms of a reorganization, merger, or sale of the company.
- When we determine that information is aggregate information or other information that does not identify you.
If you do not wish for your information to be shared with our strategic partners for their direct marketing purposes, see the “Advertising and Marketing” section above.
- Public Information and Third Parties
- TheWebsite may offer the option to post or share information publicly on the Website or with other users, (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot guarantee User Contributions will not be viewed by unauthorized persons.
- 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.
- We take precautions — including administrative, technical, and physical measures — to safeguard your Personal Information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction.
- We follow generally accepted industry standards to protect your information, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
- The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
- Correcting and Updating Information
- We retain your information and data that we process on your behalf as long as necessary to fulfill the purpose for which it was provided as set forth in the table above, as needed to provide our Website, and as necessary to comply with our legal obligations and resolve disputes.
- Data Rights For EU Users.Users located in the European Union have the following rights:
- Request Access To Your Personal Data. You have the right to access your Personal Information. You may do so in your account, or by contacting us email@example.com. You may also have the right to receive Personal Information you provided to us in a commonly used and structured format in order for it to be transferred to another data controller. This right applies if your Personal Information is processed by us with your consent. It also applies for the performance of a contract and when processing is carried out by automated means.
- Request Correction Of Your Personal Data. You may ask us to correct or remove any data that is inaccurate by contacting us as at firstname.lastname@example.org. Please keep us informed if your Personal Information changes during your relationship with us.
- Request Erasure Of Your Personal Data. In certain circumstances, you may request the erasure of your Personal Information, which is referred to as the right to be forgotten. Note that erasure of your Personal Information may make it impossible for you to access or use one or more Money Pages services.
- Object To Processing Of Your Personal Data. You may object to processing your Personal Information for direct marketing purposes. You also have the right to object at any time to processingof your Personal Information which is based on our legitimate interests, pursuant to grounds relating to your particular situation. If you object on this ground, we shall no longer process your Personal Information unless we can demonstrate compelling legitimate grounds for such processing, and those grounds override your interests, rights, and freedoms; or, to establish, exercise, or defend legal claims. Note that our inability to process your Personal Information may make it impossible for you to access or use one or more Money Pages services.
- Request Restriction Of Processing Your Personal Data. You may restrict the processing of your Personal Information to processing in certain circumstances. Note that our inability to process your Personal Information may make it impossible for you to access or use one or more Money Pages services.
- Request Transfer Of Your Personal Data. You may request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent. You have the right to withdraw consent to process your data at any time where we are relying on consent to process your Personal Information. You may also withdraw your consent to the international transfer of your data at any time. However, this will not affect the lawfulness of any processing or data transfers carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Not Be Subject To Profiling Or Automated Decision making. You have the right not to be subject to a decision based solely on automated data processing, including profiling, where the decision has a legal or other significant effect, subject to certain exceptions.
- What We May Need From You. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.