Equity Now - The Network: Privacy Policy
Last Updated: September 27, 2024
Introduction
Equity Now, Inc. ("Equity Now," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit and use The Network, our online financial education community and digital course platform. You agree to the practices described in this Privacy Policy by accessing or using The Network. If you disagree with the terms of this policy, please do not use The Network.
Table of Contents
- Information We Collect
- How We Use Your Information
- Legal Bases for Processing (EU/EEA Users)
- How We Share Your Information
- Cookies and Tracking Technologies
- Third-Party Advertising and Analytics
- Data Security
- Data Retention
- International Data Transfers
- Your Rights and Choices
- Children's Privacy
- Third-Party Links and Services
- Changes to This Privacy Policy
- Contact Us
1. Information We Collect
We collect various types of information from and about users of The Network, including:
1.1 Personal Information
Personal information refers to any information that can be used to identify you directly or indirectly. This may include:
- Contact Information: Name, email address, mailing address, phone number.
- Account Credentials: Username, password, profile picture, security questions.
- Payment Information: Credit/debit card numbers, billing address, transaction history.
- Demographic Information: Date of birth, gender, occupation, and education level.
- Identification Documents: Copies of government-issued IDs (if required for verification).
- Communications: Records of your correspondence with us, including emails and chat messages.
1.2 Non-Personal Information
Non-personal information does not identify you individually but may include:
- Device Information: IP address, browser type, operating system, device model.
- Usage Data: Pages viewed, links clicked, time spent on pages, navigation paths.
- Log Files: Error reports, system activity, and hardware settings.
- Location Data: Geographic location inferred from your IP address or GPS (if enabled).
- Aggregated Data: Statistical or demographic data derived from personal information but anonymized.
1.3 Information from Third Parties
We may obtain information about you from other sources, such as:
- Social Media Platforms: When you log in using social media accounts (e.g., Facebook, Google), we may access your profile information.
- Business Partners: Affiliates, marketing partners, or service providers may share information with us.
- Public Databases: Information available from public records or online directories.
2. How We Use Your Information
We use your information for various purposes, including:
2.1 To Provide and Improve Services
- Account Management: To create and maintain your user account.
- Service Delivery: To provide access to courses, webinars, forums, and other features.
- Personalization: To tailor content, recommendations, and resources to your interests.
- Payment Processing: To process transactions and manage billing.
2.2 Communication
- Transactional Messages: Send confirmations, invoices, technical notices, updates, and security alerts.
- Customer Support: To respond to your inquiries, complaints, or feedback.
- Marketing Communications: To inform you about new courses, promotions, events, or other news (subject to your preferences).
2.3 Analytics and Research
- Performance Monitoring: To analyze usage patterns and improve The Network's functionality.
- Product Development: To develop new features, services, or products.
- Quality Assurance: To conduct surveys or polls to gauge user satisfaction.
2.4 Legal and Compliance
- Regulatory Compliance: To comply with legal obligations, such as financial reporting or auditing.
- Enforcement: To enforce our Terms and Conditions, policies, and agreements.
- Protection: To protect the rights, property, or safety of Equity Now, our users, or the public.
3. Legal Bases for Processing (EU/EEA Users)
For users located in the European Union (EU) or European Economic Area (EEA), we process your personal information based on the following legal grounds:
- Consent: Where you have given explicit consent for specific purposes.
- Contractual Necessity: To fulfill our contractual obligations to you.
- Legal Obligation: To comply with legal requirements.
- Legitimate Interests: For purposes that are in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
4. How We Share Your Information
We may share your information under the following circumstances:
4.1 Service Providers
We engage third-party companies and individuals to perform services on our behalf, such as:
- Payment Processors: To handle payment transactions securely.
- Hosting Providers: To host our servers and databases.
- Email Services: To send out communications.
- Analytics Providers: To analyze data and improve services.
- Marketing Partners: To assist in promotional activities.
These service providers only have access to your personal information to perform these tasks and are obligated not to disclose or use it for other purposes.
4.2 Business Transfers
In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred to a successor or affiliate as part of that transaction.
4.3 Legal Obligations
We may disclose your information to:
- Comply with Laws: Respond to subpoenas, court orders, legal processes, or government requests.
- Enforce Agreements: Enforce our Terms and Conditions and other agreements.
- Protect Rights: Protect the rights, property, or safety of Equity Now, our users, or others.
4.4 With Your Consent
We may share your information with third parties when you have provided consent.
4.5 Aggregated or De-Identified Information
We may share aggregated or anonymized data that cannot reasonably be used to identify you.
5. Cookies and Tracking Technologies
5.1 Types of Cookies We Use
- Essential Cookies: Necessary for the operation of The Network (e.g., authentication).
- Performance Cookies: Collect information about using The Network to improve performance.
- Functional Cookies: Remember your preferences to enhance your experience.
- Targeting Cookies: Deliver relevant advertisements and track ad campaign effectiveness.
We may also use web beacons, pixels, and similar technologies to collect usage data.
5.2 Managing Cookies
You can control cookies through your browser settings. However, disabling cookies may affect the functionality of The Network.
- Browser Controls: Most browsers allow you to refuse cookies or alert you when cookies are being sent.
- Opt-Out Tools: Some third-party services offer opt-out mechanisms (e.g., Google Analytics Opt-out Browser Add-on).
6. Third-Party Advertising and Analytics
We may use third-party advertising networks and analytics providers to:
- Serve Ads: Deliver targeted advertisements on The Network or third-party sites.
- Measure Effectiveness: Analyze the performance of ad campaigns.
- Collect Data: Use cookies and similar technologies to collect information about your online activities over time and across different websites.
These third parties may collect information about your visits to The Network and other websites to provide relevant advertisements.
7. Data Security
7.1 Security Measures
We implement a variety of security measures to protect your information, including:
- Encryption: SSL/TLS encryption for data transmission.
- Access Controls: Restricted access to personal data on a need-to-know basis.
- Firewalls and Intrusion Detection: Protecting our systems from unauthorized access.
- Regular Audits: Security assessments and vulnerability scans.
7.2 User Responsibilities
- Password Protection: Keep your password confidential and not share it with others.
- Secure Devices: Ensure your devices are protected against unauthorized access.
- Vigilance: Be cautious of phishing attempts and report any suspicious activities.
Despite our efforts, no method of transmission over the internet or electronic storage is entirely secure. We cannot guarantee absolute security.
8. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:
- Active Accounts: Your account is active for the duration.
- Legal Obligations: To comply with legal, accounting, or reporting requirements.
- Dispute Resolution: To resolve disputes and enforce agreements.
When your information is no longer needed, we will securely delete or anonymize it.
9. International Data Transfers
Your information may be transferred to, stored, or processed in countries outside your own, including the United States. These countries may have different data protection laws from those in your country.
- EU-U.S. Privacy Shield: While the Privacy Shield framework is no longer a valid transfer mechanism, we ensure adequate safeguards are in place.
- Standard Contractual Clauses (SCCs): We may use SCCs approved by the European Commission to transfer data from the EU/EEA to third countries.
- User Consent: By using The Network, you consent to the transfer of your information as described.
10. Your Rights and Choices
10.1 Access, Correction, and Deletion
You have the right to:
- Access: Request a copy of the personal information we hold about you.
- Correction: Request correction of inaccurate or incomplete data.
- Deletion: Request deletion of your personal information, subject to certain exceptions.
To exercise these rights, please get in touch with us at [email protected]
10.2 Opt-Out of Marketing Communications
- Email Marketing: Click the "unsubscribe" link in promotional emails or adjust your preferences in account settings.
- SMS Marketing: Follow the opt-out instructions provided in the messages.
10.3 Do Not Track Signals
Our systems do not recognize "Do Not Track" signals from browsers. However, you can manage cookies as described above.
10.4 California Privacy Rights
Under the California Consumer Privacy Act (CCPA), California residents have the right to:
- Know: Request disclosure of categories and specific pieces of personal information collected.
- Delete: Request deletion of personal information.
- Opt-Out: Opt out of the sale of personal information.
We do not sell personal information as defined under CCPA.
To exercise your rights, contact us at [[email protected].
10.5 EU/EEA Privacy Rights
Under the General Data Protection Regulation (GDPR), EU/EEA residents have the right to:
- Access and Portability: Obtain a copy of your data in a commonly used format.
- Rectification: Correct inaccurate or incomplete data.
- Erasure: Request deletion of your data.
- Restriction: Limit the processing of your data.
- Objection: Object to processing based on legitimate interests.
- Withdraw Consent: Withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal).
To exercise your rights, please get in touch with our Data Protection Officer at [email protected].
11. Children's Privacy
The Network is not intended for individuals under 13 (or the minimum age in the relevant jurisdiction). We do not knowingly collect personal information from children without verifiable parental consent.
- Parental Controls: Parents or guardians may contact us to request the deletion of a child's personal information.
- COPPA Compliance: We comply with the requirements of the Children's Online Privacy Protection Act (COPPA).
12. Third-Party Links and Services
The Network may contain links to third-party websites or services not owned or controlled by Equity Now.
- No Endorsement: Inclusion of a link does not imply endorsement.
- Privacy Practices: We are not responsible for the privacy practices of third parties.
- User Responsibility: Review the privacy policies of any third-party sites you visit.
13. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements.
- Notification: Significant changes will be communicated via email or a prominent notice on The Network.
- Effective Date: The "Last Updated" date at the top indicates when the policy was last revised.
- Continued Use: Your continued use of The Network after changes are posted constitutes your acceptance of the revised policy.
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please get in touch with us:
Equity Now, Inc.
Attn: Privacy Team
Email: [email protected]
Address: 9700 Philadelphia Ct, Lanham, MD 20706
- Data Protection Officer (DPO): For EU/EEA residents, you may contact our DPO at [email protected]
- Complaints: If you believe we have not addressed your privacy concerns, you can complain to a supervisory authority in your jurisdiction.
Additional Provisions
A. Data Processing Agreements (For EU/EEA Users)
We have entered into Data Processing Agreements (DPAs) with our service providers who process personal data on our behalf, ensuring compliance with GDPR requirements.
B. Privacy Shield Framework
Although the EU-U.S. Privacy Shield has been invalidated, we continue to honor our commitment to protect personal data transferred from the EU/EEA to the U.S.
C. Biometric Information
We do not collect biometric data. Should this change, we will update this policy and obtain necessary consents.
D. Sensitive Personal Information
We generally do not collect sensitive personal information (e.g., health data, religious beliefs). If you provide such information, you consent to its processing per this Privacy Policy.
E. Automated Decision-Making
We do not use automated decision-making processes that produce legal effects concerning you or similarly significantly affect you.
F. Data Breach Notification
In a data breach, we will notify affected users and regulatory authorities as applicable laws require.
G. User Forums and Public Areas
- Public Posting: Information you post in public areas (forums, comments) may be visible to others.
- Caution Advised: Do not share personal or sensitive information in public areas.
H. Email and Text Message Communications
- Security Limitations: Emails and text messages may not be secure; avoid sending sensitive information via these channels.
- Consent: By providing your contact information, you consent to receive communications from us.
I. International Users
If you are accessing The Network from outside the United States, please be aware that your information may be transferred to, stored, and processed in the U.S.
J. Governing Law
This Privacy Policy is governed by the State of Maryland, USA laws, without regard to its conflict of law principles.
Conclusion
Your privacy is important to us, and we are committed to safeguarding your personal information. We encourage you to review this Privacy Policy periodically to stay informed about our data practices. Thank you for trusting Equity Now with your personal information.