July 23, 2019
Enrollment and Profile Information: When you enroll as a User or update your information in the Site, we collect personal information from you, such as your name, postal address, email addresses, mobile numbers, your photograph or video (if available), name of the financial institution where you hold accounts, and financial account numbers.
In addition, we may collect and analyze personal information from third party services in order to process your registration, verify your identity, verify your financial account information, and protect against or prevent actual or potential fraud or unauthorized use.
Visitors Seeking Employment (“Applicants”): When you apply for a job with us, we collect personal information from you, including the position(s) sought, name, email address, telephone number, background information sufficient to perform background checks, and other information contained on resumes, cover letters, and other related documentation.
Visitors Who Are Registered As or Are Seeking to Become Investors (“Investors”): We collect personal information from you such as name, phone number, mailing address, email address, accredited investor status, credit information, social security number, personal financial information (e.g., assets and income), and login credentials (e.g., username and password) from Visitors to the Site who register to become Investors of Emergent Technology and who create online accounts on the Site. We also collect information contained on any documents voluntarily uploaded or emailed by Investors, as well as any information voluntarily provided by Investors for the purposes of accessing various financial data and requesting services via the Investor page of the Site. We use any non-public personal information, such as personal financial information, solely for the purposes of providing services to Investors.
Information About Your Transactions: When you use the Site, we collect information such as when and where the transaction occurs, the names of the transacting parties, the mobile phone numbers or email addresses of the transacting parties, a description of the transactions (including text you put in the memo field), the transaction amount, and the devices and payment methods used to complete the transactions.
Information to Respond to Your Requests: You may give us your personal information when you contact us for assistance and to sign up for our newsletters and for other communications. Please review Section 4 “Your Choices” for information on how you can opt-out of receiving communications from us.
Information from Other Sources: The information we collect may be combined with information from outside records (e.g., demographic information, additional contact information) that we have acquired in accordance with the law.
Content You Associate with Your Profile: We collect or access information you enter into your User profile. This includes your contact information, your financial account information, your profile photograph or video, and any other information that you associate with your profile.
Mobile Information: When you access the service through one or more of our mobile apps, we may collect or use information from your mobile device such as:
- your unique device identifier;
- location or GPS/geo-location;
- Wi-Fi base identifier (BSSID);
- mobile phone number;
- mobile device name;
- contacts and photos paired with your contacts (we access, but do not store, contact information to facilitate your transaction);
- apps downloaded or used;
- biometric verification information (e.g., fingerprint or facial recognition) (we access, but do not store, this information when you use this method of authentication on your mobile phone); and
- passwords (e.g., passwords you create to access the mobile app, and those that may be associated with your banking credentials with your permission (see Section 2a for more information)).
Geolocation Information: When you use our mobile apps, we may collect and use geo-location information for security and fraud detection purposes.
Our goal is to collect only that information that we believe is required for our legitimate business interests, to operate the Site, to authenticate and verify your identity, to prevent fraud, and to improve your experience of using the Site.
USING PERSONAL INFORMATION
To Operate Our Site: We use information we collect or access about you to:
- respond to your requests and to comply with your stated communication preferences;
- notify you, by text or email, of a pending transaction;
- verify changes you have made to your personal information;
- facilitate your enrollment in the Site as a User and to resolve issues relating to your enrollment;
- research and resolve issues related to a transaction you sent or received;
- verify your identity;
- provide customer service and obtain your feedback regarding the Site (e.g., to resolve disputes, problems with your User profile or the Site);
- enforce our terms and conditions;
- provide other services you request;
- guide decisions and improve the Site, including using Site analytics;
- maintain or give you information about your profile;
- create and deliver targeted marketing and advertising tracked to what we believe may potentially interest you;
- provide you with a safe, efficient, and customized experience; and
- contact you or perform other duties as authorized by law.
To Provide and Improve Our Services: We use information we collect or access about you to help us create, develop, operate, deliver, and improve our products and services. We may share non-public personal information about you with Emergent Technology’s affiliated companies, which is a group of companies related to us by common control or ownership.
To Prevent Fraud and Prohibited or Illegal Activities: We use information we collect or access about you to prevent, detect, investigate, and report fraud, security breaches, potentially prohibited or illegal activities, or otherwise to protect our services, our rights, and/or our Users. Information may also be used to respond to subpoenas or other legal processes, as permitted or required by law. In exceptionally rare circumstances where national, state or company security is at issue, we reserve the right to share our entire database of Visitors, Applicants, and Investors with appropriate governmental authorities.
SHARING PERSONAL INFORMATION
- The Emergent Technology Corporate Family: We may share information about you with the Emergent Technology corporate family, including our subsidiaries.
- Our Service Providers and Other Third-Parties: We may share your information with our service providers and other trusted third parties such as customer support service centers, advertising networks, analytics tools providers, and software development kit providers we hire to help with our business operations (including, but not limited to, providing customer service, verifying your identity, preventing and detecting fraudulent activity, analytics, marketing as permissible, operations, and enforcing of our terms and conditions).
- Other Entities with Your Consent: We may share your personal information with other third-parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Site, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third-parties, or parties working on their behalf, to facilitate your request.
- Law Enforcement, Government Agencies and Other Authorized Third Parties: We may share information about you, as permitted by law, with law enforcement, governmental agencies, and other authorized third-parties.
- Companies in the Mobile App Industry: When you access the Site through a mobile device, we may share your information with mobile carriers, operating systems, and platforms.
You can control how and when you want to receive notifications from us by following instructions within the notices you receive from us and by updating your preferences in the Site.
To opt out of marketing communications from us, use the options in the communications we send, send an email request to firstname.lastname@example.org and/or visit Ad Choices as explained in Section 3 above.
You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your enrolled profile.
You may request to cancel your Site profile and enrollment by speaking to a customer service representative at 1-877-959-7027 or email@example.com. However, doing so will immediately terminate your ability to use the service.
ACCESSING, REVIEWING, AND UPDATING YOUR PERSONAL INFORMATION
You can access, review, and update your personal information, User profile, or registration information at any time by accessing your profile in the Site. Keeping this information up-to-date is very important. If this information is incomplete, inaccurate or not current, please update your information by looking into your profile.
OUR DATA RETENTION PRACTICES
We generally retain information for as long as it is necessary and relevant for our operations and to comply with applicable law.
You may request to cancel your Site profile and enrollment by speaking to a customer service representative at 1-877-959-7027 or firstname.lastname@example.org. Information from closed or suspended profiles will only be retained as necessary to comply with law, prevent fraud, prevent re-registration, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our terms and conditions, or take other actions permitted by law.
- Operationally Necessary. We may use tracking technologies required for system administration, to prevent fraudulent activity and improve security. We are not required to obtain your consent for tracking technologies that are operationally necessary.
- Functionality-Related. We may use tracking technologies to tell us, for example, whether you have visited the website before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
- Targeting-Related. We may use tracking technologies to deliver content, including ads, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content as well as track the content you access (including video viewing).
During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages, and page interaction information.
A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):
- We offer certain features that are available only through the use of tracking technologies.
- We use both persistent and temporary tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
- You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Site that assist us with various aspects of our Site operations and services, such as Google Analytics.
To learn more about limiting the collection of tracking technology/cookie data, please visit Ad Choices at http://optout.aboutads.info/.
SECURING YOUR DATA
To help us protect the privacy of your information, we maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and profile registration information are secure and not shared with third-parties. Additionally, we use security features that are built into the hardware and software of your device to help protect your transactions, such as facial or fingerprint recognition. We do not collect or store your biometric verification information.
Emergent Technology uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Site. Although Emergent Technology and its licensors own the code, databases, and all rights to the Site and any feedback you provide, you retain all rights to your data.
You understand that information provided by, sent to, or stored about Visitors, Applicants, and Investors will be sent via the internet or received or stored on Emergent Technology’s computer systems (including backup systems) or on mobile storage devices or by or on email (collectively “E-Media”); each of which has associated risks, such as risks of interception, invasion, hacking, breach of confidentiality, theft, alteration, forgery, distortion, loss, or delay in transmission (“E-Transmission/Storage Risks”). By transmitting information to and from Emergent Technology hereunder and doing business with Emergent Technology, you accept E-Transmission/Storage Risks and irrevocably and unconditionally waive any claim against Emergent Technology that may result from E-Transmission/Storage Risks by either you or Emergent Technology, except that in the case of information received, held or transmitted by Emergent Technology which has been so transmitted or so stored or both, Emergent Technology utilizes commercially reasonable procedures and methods to diminish such risks. If you created an account on the Site, Emergent Technology has no responsibility or liability for unlawful, unauthorized, or fraudulent use of your login credentials (e.g., username and password) to access and instruct Emergent Technology with regard to your account.
CROSS-BORDER DATA TRANSFERS
In addition, personal information that you submit for publication on the Site will be published on the internet and may be available around the world.
You agree to such cross-border transfers of personal information.
TRANSFERS OF CUSTOMER INFORMATION
Customer lists and information are properly considered assets of a business. Accordingly, if we merge with another entity or if we sell our assets to another entity, our customer lists and information, including personally identifiable information you have provided us, would be included among the assets that would be transferred and we would request that the entity treat your information in accordance with these terms.
Our Site is not intended for children under the age of 13. For information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.
NOTICE TO CALIFORNIA RESIDENTS
How California Residents Can Request a List of Third Parties that Received Personal Information: California residents may request a list of all third-parties to which our Site has disclosed certain personal information (as defined by California law) during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at email@example.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
How We Respond to Do Not Track Signals for California Residents: California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing: If you are in the EEA, when we process your personal data we will only do so in the following situations:
- We need to use your personal data to perform our responsibilities under our contract or agreement with you (e.g., processing payments for and providing the products or services you have requested).
- We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our products and Services, and to provide, secure, and improve our products and Services.
- We find such processing is necessary to comply with our legal obligations.
- We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.
Data Subject Requests: You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account. Alternatively, you may contact us as indicated below.
Data Retention: We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Questions or Complaints: If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your Data Protection Authority, please see:
|FACTS||WHAT DOES EMERGENT TECHNOLOGY HOLDINGS LP “EMERGENT TECHNOLOGY ” DO WITH YOUR PERSONAL INFORMATION?|
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include:
■ Social Security number and financial account information
■ Transaction history and account balances
■ Credit history and other nonpublic information related to your enrollment
When you are no longer our customer, we continue to share your information as described in this notice.
|How?||All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Emergent chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Emergent Technology share?||Can you limit this sharing?|
|For our everyday business purposes— |
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
|For our marketing purposes— |
to offer our products and services to you
|For joint marketing with other financial companies||Yes||No|
|For our affiliates' everyday business purposes— |
information about your transactions and experiences
|For our affiliates' everyday business purposes— |
information about your creditworthiness
|For our affiliates to market to you||Yes||Yes|
|For nonaffiliates to market to you||Yes||Yes|
|Questions?||Call 1-877-959-7027 or send us email to firstname.lastname@example.org. Our Legal Department is located at G-Wallet Corp Legal Department, 109 N. Post Oak Lane, Suite 435, Houston, TX 77024|
|Who we are|
|Who is providing this notice?||This privacy notice is provided by Emergent Technology.|
|What we do|
|How does Emergent protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.|
|How does Emergent collect my personal information?||We collect your personal information, for example, when you
■ open an account or provide account information
■ initiate a transaction or receive funds
■ provide us your contact information
|Why can’t I limit all sharing?||Federal law gives you the right to limit only
■ sharing for affiliates’ everyday business purposes—information about your creditworthiness
■ affiliates from using your information to market to you
■ sharing for nonaffiliates to market to you
State laws and individual companies may allow you to further limit sharing. See below for more information regarding your rights under state law.
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.
■ Our affiliates include: Emergent Payments, G-Responsible Gold, G-Coin, and TrustStamp
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.
■ Nonaffiliates include service providers performing services or functions on our behalf.
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
■ Our joint marketing partners include companies that provide financial products and services.
|Other Important Information|
|We may transfer personal information to other countries, for example, for customer service or to process transactions.
Special Notice for California Residents: If your account has a California mailing address, we will not disclose information we collect about you with nonaffiliated third parties, except as permitted by California law, such as to process your transactions or to maintain your account
Special Notice to Vermont Residents: If your account has a Vermont mailing address, we will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.
As a convenience to our Visitors, the Site may contain links to third party sites that we believe may offer useful information. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
Emergent Technology Holdings LP
1900 St. James Place, Suite 125
Houston, TX 77055
You may access, amend, or alter the information we collect about you by contacting the individual listed above for so long as such information is retained by Emergent Technology. This access may be subject to a fee to cover our costs.