Previsio Privacy Policy

Updated November 25, 2019

General

Previsio, Inc. ("Previsio"), its affiliates, and subsidiaries (collectively, "we", "us" and "our") provide this Privacy Policy to the website visitors, users, and businesses that access services provided by or through Previsio (collectively, "you" or "your"). This Privacy Policy applies when you access or use www.previs.io (the "Site") and describes how we collect, store, use, share, and protect information about you to operate the Site and make available to you certain services (collectively with the Site, the "Services").

This Privacy Policy also describes your choices regarding certain information we collect about you. The terms of this Privacy Policy are incorporated into the Previsio Terms of Use.

If you apply for or obtain a financial product or service where we function as a service provider

Information Collected

In connection with your use of the Services, we collect two types of information about you:

1. User Personal Information, and
2. General Information.

User Personal Information. User Personal Information includes information about you, such as: name, user name(s), mailing address, email address, and primary telephone number. In addition, if you acquire any Services via the Site that require payment, we may obtain certain financial information, solely for the purpose of processing such payments.

General Information. General Information includes technical information such as information regarding your use of and interactions with the Site. This General Information includes, but is not limited to, information about (i) your Internet connection, (ii) the equipment you use to access the Site and usage details, (iii) your operating system, browser version and internet protocol (IP) address, (iv) your mobile device type, your device's unique identifier, and your mobile network information, and (v) web pages, content, communications, or advertisements that you view or otherwise interact with, and (vi) referring/exit pages, clickstream data, and information that you search for using the Services.

How We Collect Your Information

Information Provided by You. We collect any information you provide when you use the Services. For example, we collect User Persona; Information from you when you (i) register an account on the Site or (ii) fill out forms or fields on the Site. We also collect any information you may submit through communications with us by email, mail, text, telephone, facsimile or other means.

Information We Collect When You Use Our Services. We automatically collect General Information from your computer, mobile device or other device you use when you access the Services (including downloading and using a mobile application or accessing a mobile optimized Site), view content about the Services on a third-party website or open emails or links in emails from us.

We, our business partners, or our service providers may use cookies or similar technologies to collect information. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Please review your web browser "Help" file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

We also use cookies and similar technologies hosted by third parties on the Services. For instance, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ regarding Google Analytics' cookies. We may receive reports based on the use of these technologies by such companies on an individual and aggregated basis.

Use of Information

Service-Related Usage. We use the information we collect about and from you, both in a personally-identifiable form and in an aggregated or anonymized form, for a number of purposes, including for providing, supporting, promoting, and improving the Services. Such uses include:

Enabling users to obtain products and services through the Services;
Facilitating marketing, processing, servicing, and collections activities;
Providing customer support;
Understanding, customizing, and enhancing user experience;
Providing targeted marketing and advertising;
Determining your eligibility for the Services;
Verifying your identity, conducting appropriate diligence, and keeping your information current;
Creating an account connection between your account and a third-party account or platform;
Sending notifications and information regarding the Services;
Measuring and improving the performance and functionality of the Site;
Managing and protecting our information technology infrastructure;
Administering and managing the security of the Site;
Developing new products and services; and
Compiling, using, researching, analyzing, and generating data analytics reports to better understand our Customers and to improve the Services;

Communications. We may communicate with you using the information collected (i) for customer service, (ii) to provide you with updates or information relating to the Services, or (iii) to conduct surveys and collect feedback about the Services.

Marketing and Advertising. We may use the information we collect for marketing and advertising purposes, such as providing you with promotional materials that may be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications. To learn more about your choices regarding interest-based advertising and cross-device tracking, please see the Third-Party Information Collection section below.

Compliance with Law and Our Own Obligations. We may use the information we collected, to the extent permitted or required under applicable laws (i) to enforce our Terms of Use or other legal rights, including intellectual property infringement, (ii) to detect and protect against potentially prohibited or illegal activities, including fraud and unauthorized access, (iii) in response to lawful requests for information or legal process, (iv) to establish, exercise, or defend a legal claim, and (v) to comply with our contractual obligations, our policies, industry standards, and applicable laws.

Other Purposes. We may use the information we collect for other purposes for which we provide notice to you at the time of collection or for which we obtain your consent.

Aggregate Data. We may process your information in an anonymized or aggregated form for purposes other than described above.

Information Sharing

We may share User Personal Information and General Information as follows:

Service Providers. We may engage service providers to assist us in providing Services. We may share any information we receive with such parties as is necessary for the provision of the Services.

As Required By Law and Similar Disclosures. We may disclose your information if we believe doing so is required or appropriate to (i) comply with applicable laws and regulations, (ii) comply with regulatory investigations, enforcement requests, and legal process, such as subpoenas, court orders, and bankruptcy notices, (iii) respond to your requests or resolve disputes or inquiries, (iv) detect, prevent, or otherwise address fraud, confidentiality, security or technical issues, (v) respond to regulatory authorities jurisdiction over us for examinations, compliance, or other purposes and (vi) protect your, our, or others' rights, property, or safety, or the security or integrity of our Services.

Business Partners. We may disclose information about you with business partners in connection with jointly offered products and services, as well as products and services offered by these partners and made available through the Services or which we believe may be of interest to you or your business. These business partners are subject to contractual obligations entered into with us restricting how they may use this information.

Corporate Changes. We may disclose your information in connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets; equity or debt financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

Consent. We may disclose your information to any third party with your consent. For example, we may disclose information at your direction, as described at the time you agree to share, or when you authorize a third-party application or website to access your information.

Other Purpose. To fulfill the purpose for which you provide such information to us or any other purpose disclosed by us when you provide the information to us.

Third-Party Information Collection

We may work with third-party advertising partners (e.g., Facebook) to display advertisements on the Site and other websites and mobile applications and third-party analytics partners (e.g., Google Analytics) to evaluate and provide us with information regarding your use of the Site. We may also utilize framing techniques to serve you content from third-party providers, while preserving the look and feel of the Services. In such cases, you will be providing information to these third-parties.

These third parties may use cookies, Web beacons, pixel tags and similar technologies to collect information about your activities on the Site and other Web Site to provide you personalized advertising based on your interests and browsing activity.

Push Notifications

If you are a user of our applications, we may send push notifications or alerts to your mobile device even when you are not logged in. We may use push notifications to send you notifications related to the Services and various triggers based on your selections. You can manage your push notification preferences or deactivate these notifications by turning off notifications under settings for your mobile device. If you choose not to receive push notifications, you may still receive in-app notifications.

Your Access

If you are a registered user of the Services, you may review or modify certain User Information we have collected about you by logging into your account for the Services and updating your profile. This section of the Site is password protected to better safeguard your information. If you would like to change any other information that you cannot independently correct, you may submit a request for such updates by contacting us at the address or phone number at the bottom of this Privacy Policy. Under certain circumstances we may not be able to fulfill your request, such as if it restricts our ability to comply with applicable laws and regulations or legal process, or we cannot verify your identity. In such instances, we will respond to your request within a reasonable timeframe and provide you an explanation of our decision.

Your Choices

You may choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails. You may also request that we do not call you for marketing-related purposes. In addition to following the unsubscribe instruction in relevant email communications, you may make these requests by contacting us at support@previs.io, Subject: Opt-Out Requests. We will respond to your request within a reasonable timeframe. In addition, if you no longer wish to receive marketing notifications through our mobile applications you can adjust your device's privacy preferences by visiting the settings page of the device. Opting out of marketing emails or notifications will not stop your receipt of non-marketing emails and notifications related to the Services.

Various browsers may offer their own tools to manage cookies. If you disable cookies, you can still use the Services, but your ability to use some features of the Services may be limited.

Links to Third Party Websites

The Site may include links to other websites or mobile applications whose privacy practices may differ from ours. We are not responsible for any practices employed on third-party websites or applications, including the information and content contained on the website or application. If you submit information to a third-party website or application, your information is governed by the third party's privacy policy. We encourage you to carefully read the privacy policy of any website or application you visit, access, or use.

Security of Information

We take reasonable measures, including administrative, technical, and physical safeguards to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. Your information is securely sent to us with at least 128 bit-encryption over the Transport Layer Security (TLS) protocol. This creates an encrypted connection between your browser and us so that any sensitive information you provide can be securely transmitted. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

If you link your bank account information as a part of applying for or receiving the Services, we will have read-only access to such information. We do not have access to change, edit, or modify your bank account information. We also cannot see your banking credentials (i.e., username and passwords). You are responsible for securing and maintaining the privacy of your banking credentials and account information. We are not responsible for protecting any information we share with a third-party based on an account connection that you have authorized.

Children Under 13

This Site and products or services available through this Site are not intended for children under the age of 13. We do not knowingly solicit or market online to children under the age of 13. If we knowingly receive a child's personally identifiable information, we will immediately delete it from our system. Contact us at the address or phone number at the bottom of this Privacy Policy if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

Social Media Widgets

The Services may include social media features and widgets, such as the Facebook "Like" button, or interactive mini-programs that run on the Services. These features may collect information such as your IP address and which page you are visiting on the Site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Data Retention

We will retain your information for (i) as long as reasonably necessary to provide you Services, (ii) as long as reasonably useful for commercial purposes, or (iii) as long as necessary to comply with applicable laws and internal policies regarding recordkeeping, reporting, audits, and litigation holds. If you wish to request that we no longer use your information to provide you Services, you may contact us at the address or phone number at the bottom of this Privacy Policy. We will nonetheless retain your information to the extent that we deem necessary to comply with our legal or contractual obligations, resolve disputes, as needed to provide you Services, or for other business purposes.

Changes to Privacy Policy

By visiting the Site or using the Services, you accept the practices described in this Privacy Policy. We may update this Privacy Policy from time to time by making available a revised, dated version on the Site. If the revised version includes a substantial change, we will provide a more prominent notice prior to the change becoming effective. Your continued use of the Site shall constitute your acceptance of such updated Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy above an applies solely to all visitors an users of the Site and others who resident in the State of California (" consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

The Site collects information that identifies, relates to, describes, references, capable of being associated with or could reasonably be linked, directly or indirectly, with a consumers or device ("personal information"). In particular, the Site has collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our website.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose (or sell your personal information, subject to your right to opt-out of those). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may 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 a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site 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, please send us an electronic message through our website or write us at our address listed on our webpage.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice's effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Us

Any questions or concerns regarding this Privacy Policy, our practices, the Site or the Services, the ways in which we collect and uses your information described this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us by at email support@previs.io or with a letter by postal mail to:

Previsio, Inc.
118 Zamora Ave #206
Coral Gables, FL 33134