Privacy Policy

Effective as of Oct 1, 2020

We at 15Rock, Ltd. (“15Rock,”“we,”“us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of 15Rock in connection with our Platform.

Acceptance of Terms

By visiting our Platform, you are agreeing to the terms of this Agreement. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

The Information We Collect and/or Receive

In the course of operating the Platform and/or interacting with you, 15Rock will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Personal Information

We do not collect any personal information from you, unless you provide such information voluntarily, such as by registering with us, sending us an e-mail, uploading User Content, or interacting with us via our social media pages, such as through Facebook. Any such social media platforms are operated by the social networks themselves and are subject to their terms of use and privacy policies.All information we collect and/or receive under this section is collectively called “Personal Information.”

You are agreeing to share financial information with us including, but not limited to, your account credentials, transactional history, account numbers, and balances/limits as well as general identity data including the name(s) and address(es) of all account holder(s). You are enabling us to interact with and through your financial institutions on your behalf and with your consent.
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2. Geolocational Information

Certain features and functionalities of the Platform are based on your location. In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers. Such information is collectively called the “Geolocational Information.”Collection of such Geolocational Information occurs only when the Platform is running on your mobile device. You may decline to allow us to collect such Geolocational Information, in which case 15Rock may not be able to provide certain features or functionalities to you.



3. Other Information.

In addition to the Personal Information and the Geolocational Information, we may automatically collect or receive additional information regarding you and your use of our Platform, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our Platform (collectively, the “Other Information”). Such Other Information may include:

From Your Activity:

• IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
  
• Browser type and language;
  
• Referring and exit pages and URLs;
  
• Date and time;
  
• Details regarding your activity on the Platform, such as search queries, amount of time spent viewing pages, and other performance and usage data.

About Your Device:

• Type of device;
  
• Advertising Identifier (“IDFA” or “AdID”);
  
• Operating system and version (e.g., iOS, Android or Windows);
  
• Carrier;
  
• Geo-location; and
  
• Network type (WiFi, 3G, 4G, LTE).
  

From Cookies:

We may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them and other technologies to help us collect data and to enhance your experience with the Platform. Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies for various purposes, including to:

• authenticate users;
  
• personalize your experience;
  
• analyze which portions of the Platform are visited or used most frequently; and
  
• measure and optimize advertising and promotional effectiveness.
  

Third-Party Analytics:

We, the Platform, and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (such as Google Analytics) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform. For Google Analytics, please visit https://www.google.com/analytics



From You:

Additional information that you voluntarily provide to us (either directly or via our social media pages), such as ratings and other information that does not identify you personally.

The Information Collected by or Through Third-Party Advertising Companies

We may share Other Information about you with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

Neither we nor any third party acting on our behalf employs behavioral advertising or retargeting in connection with users whom we know to be under 13 years old.

How the Information is Used and Shared

We use the Personal Information, the Geolocational Information, and the Other Information (collectively, the “Information”) to provide our services; to administer our rewards and promotional programs; to maintain and improve our Platform and services to you; to solicit your feedback; and to inform you about our products and services and those of our third-party marketing partners.

We may also use and/or share Information as described below.

• 15Rock will access, use, and share the Information as required to provide services or support to you in connection with your use of the Platform.
  
• In order to provide our services and administer our rewards and promotional programs, we may share the Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
  
• We may, from time to time, share and/or license Information to other companies or third parties, including our partners who may provide you information about the products and services they or their partners offer. However, to the extent required by law, you will be given the opportunity to opt out of such sharing.
  
• With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as LinkedIn, Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
  
• We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
  
• In an ongoing effort to better understand our users, and our products and services, we may analyze Information in aggregate form in order to operate, maintain, manage, and improve the Platform and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
  
• We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
  
• As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of 15Rock or others.

How to Opt Out of Third-Party Interest-Based Advertising

If you wish to opt out of third-party interest-based advertising, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to do so.

Additionally, users of mobile devices can follow the below instructions:

Android Users

For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:

Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising.”

iOS Users

iOS 7 or Higher

Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.

iOS 6

Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting.

Accessing and Modifying Information and Communication Preferences

If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any 15Rock marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the Platform (e.g., requests for support).

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents

The Platform and its servers are operated in the United States and elsewhere. Please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

External Websites

The Platform may contain links to third-party websites. 15Rock has no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Children

The Platform is not directed to children under the age of 13. 15Rock adheres to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not submit any Personal Information to us. If you are under the age of 13, you may use the Platform only with the consent of your parent or guardian.

If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with 15Rock may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to 15Rock via our contact us page on our site with “Privacy Policy” in the subject line.

In addition, 15Rock does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.For instructions on how to opt out of third-party interest-based advertising, please see “How to Opt Out of Third-Party Interest-Based Advertising” above.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Platform. By accessing the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us via our contact page with “Privacy Policy” in the subject line.