This Privacy (“Policy”) portrays and administers the data assortment, use, and sharing acts of Fellow Funding LLC (“Fellow Funding LLC,” “we,” “us,” and “our”) concerning your utilization of Fellow Funding LLC sites, items, apparatuses, advancements, and whatever other services that reference this Policy (all things considered, the “Services”).
Before you utilize or present any data through or regarding the Services, it would be ideal if you cautiously audit this Policy. By utilizing any piece of the Services, paying little heed to how you access the Services, you agree to the assortment, use, and revelation of your data as further plot in this Policy. On the off chance that YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES. We will keep on assessing this Policy as we refresh and grow the Services and our contributions, and we may make changes to the Policy as needs be. Any progressions will be posted here and you should check this page occasionally for refreshes. In the event that we roll out material improvements to this Policy, we will give you notice as legally necessary. Your proceeded with utilization of the Services will imply acknowledgment of the particulars of the refreshed Policy.
Fellow Funding LLC and its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors — (collectively, “Fellow Funding LLC,” “we,” or “us“, “our“) is an online crowd funding platform for Users to seek to raise funds for their own Campaigns and to contribute to the Campaigns of others. Campaign Owners can offer perks to Contributors in thanks for the Contributors’ donation of funds. We are based in Sugar Land, Texas.
We collect information you provide directly to us, information from 3rd parties, and information that we collect through automated means. As described below in more detail, we may collect the following categories of information about you or your use of the Service: (1) identifiers (such as name, email address); (2) commercial information (such as transaction data); (3) financial data (such as credit card information); (4) Internet or other network or device activity (such as browsing history; (5) device identifiers (such as IP address); (6) Geolocation information; (7) professional or employment related data (such as when you identify employers in a Campaign); (7) inference data about you; (8) legally-protected classifications (such as if you reveal gender in public forums); (9) physical characteristics or descriptions (such as if you provide us with a photograph); (10) sensory information (such as if you call us and leave a voicemail); and (11) other information that identifies or can be reasonably associated with you.
More specifically, we collect:
You may decline to provide us with your information. However, this will limit your ability to register for an account or use our Services. You may contribute to a Campaign without creating an account to use our Services, but we will still need to collect required information for compliance purposes in order to process your Contribution. However, to adjust your Contribution, save payment details for future Contribution, comment on a Campaign, and take most other actions on our Site, you will need to finish creating an account. You may review, change or remove certain types of your information through your account settings.
Consistent with applicable law and choices and controls that may be available to you, we may use information collected (including the categories set forth above) from you, or from devices associated with you:
We may share the categories of information identified above for the following business and commercial purposes:
Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services, and
directing us to share your personal information with third-party sites or platforms, such as social networking sites.
The laws in some jurisdictions require us to provide you with the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Information for residents of certain jurisdictions is below. To the extent that those laws apply to you, your controls and choices may include any of the following:
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our Services may not be able to take account of your interests and preferences. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact us.
The GDPR applies to individuals in the European Economic Area (“EEA”). If you are not sure whether the GDPR section applies to you, please refer to the text of the regulation on the internet or consult with an attorney as Fellow Funding LLC is not able to give you legal advice.
Fellow Funding LLC is the “data controller” of personal data collected by all of Fellow Funding LLC, and we are responsible for deciding how personal data is collected, used, and disclosed. Campaign Owners may also be data controllers of certain data that you provide to Campaign Owners when you make a Contribution to a Campaign or through any of our other Services.
The laws in the European Economic Area (“EEA”) and some other jurisdictions require us to provide Users; to the extent those laws apply to such Users, with the following information:
The legal grounds for use and disclosure of personal information include any of the below reasons:
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect User information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.
To bring you the Services, we operate globally. Fellow Funding LLC complies with the EU-US and Swiss-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal information from the European Union, United Kingdom, and Switzerland, as described in our EU-US Privacy Shield certification and Swiss-US Privacy Shield certification. If you have a Privacy Shield-related complaint, please contact us. As part of our participation in Privacy Shield, if you have a dispute with us concerning our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process and under certain conditions, through the Privacy Shield arbitration process.
Residents of the European Union, United Kingdom, or Switzerland may elect to arbitrate unresolved complaints but prior to initiating such arbitration, you must: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal information from the EU, United Kingdom, or Switzerland to third parties outside the EU, United Kingdom, and Switzerland. As required under the principles, when we receive information under the Privacy Shield and then transfer it to a third-party service provider acting on our behalf, Fellow Funding LLC has certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by taking control of your data by contacting us. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
The following section on CCPA, Cal. Civ. Code § 1798.100 which is effective January 1, 2020, applies to California residents who have certain rights regarding the personal information (as defined in the CCPA) collected by Fellow Funding LLC. It does not cover personal information not subject to the CCPA rights identified below, such as personal information we collect from our employees or job applicants. Likewise, the CCPA does not extend all the rights identified below to personal information collected from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.
For sharing with third parties to send you relevant offers and promotions and opportunities, such as when you sign up for an event or to receive more information and provide categories of information to us: identifiers, professional or employment related data (such as your job title or current company), and physical characteristics or descriptions (such as if you provide a picture of yourself).
Complying with Fellow Funding LLC’s legal or compliance obligations,
Detecting fraudulent behavior or security incidents, and other reasons that are in connection with our lawful internal uses that are consistent with your relationship with us and the context in which the information was collected.
You can exercise any of your rights under CCPA by contacting us.
We will take reasonable steps to verify your identity before responding to a request, which may include the following:
If you are not writing to us from the email address associated with your Fellow Funding LLC account or the Contributions that Fellow Funding LLC has on file for you, then to complete the verification process, we will ask you to provide 3 specific pieces of data that we have on file for you, such as email address you used when making a Contribution or billing information such as the last 4 digits of the credit card used or the billing address for a Contribution.
2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made.”
If you are not writing to us from the email address associated with your Fellow Funding LLC account or the Contributions that Fellow Funding LLC has on file for you, then to complete the verification process, we will ask you to both: 1) provide 3 specific pieces of data that we have on file for you, such as email address you used when making a Contribution or billing information such as the last 4 digits of the credit card used or the billing address for a Contribution and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made.”
Fellow Funding LLC will not discriminate against you if you exercise your rights under CCPA. However, if your request requires us to delete, restrict or not share information, please be advised that this will inhibit some functionality of the Site. Any subsequent interaction with the Site after deletion will require new requests for action on your data.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your personal information with third parties’ direct marketing use unless you elect that we do so.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please contact us with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
People under 18 (or the legal age in your jurisdiction) are not permitted to use Fellow Funding LLC on their own. Fellow Funding LLC does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services. If you believe that a child has provided us with personal information please contact us as soon as possible. If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as quickly as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
If you would like to exercise a right under a different privacy law, please contact us.
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Similar Technologies” section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. We may also use Adobe Analytics to analyze and optimize the performance of our websites, advertising, and content. To learn more about Adobe’s privacy practices and to make choices regarding Adobe’s tracking activities, please click here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
We may use third-party advertising technologies that allow for the delivery of relevant content and advertising on our Services, as well as on other websites you visit. We also work with website analytics and advertising partners, including Google, Double click Campaign Manager, and Face book, to deliver Fellow Funding LLC ads on third party publisher websites, and these partners may set cookies on your device’s web browser. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
We may also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, Double Click and others) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We may provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to target or “retarget” you with ads when you visit other websites and mobile applications. (You may opt out of many of these service providers as described in the next paragraph.)
Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
The Services may contain links to or “frame” third-party websites, applications and other services (e.g., including websites related to Campaigns and their Campaign Organizers). Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Services and to read the privacy statements of each and every site they visit that collects their information.