Privacy Policy

Last Updated: June 14, 2024

This Privacy Policy (“Privacy Policy”) describes how Valid8 Financial, Inc. and its subsidiaries and affiliates (“Valid8,” “us,” “we,” or “our”) may collect, use, and share your personal information in connection with our website at www.valid8financial.com and any other websites we own and operate that link to this Privacy Policy (collectively, the “Site”) together with our products, services, social media pages, events, emails, and other electronic communications (collectively, the “Service”), and the choices you have with respect to your personal information.

Valid8 is based in the United States, but where Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("General Data Protection Regulation" or "GDPR") applies under the provisions of Article 3(1) of the GDPR, we ensure compliance with all the principles and provisions of the GDPR. If you are a user within the EEA and UK, please refer to the "NOTICE TO EUROPEAN USERS" section of this Privacy Policy.

This Privacy Policy does not apply to personal information that we may store, maintain, or process as a data processor/service provider on behalf of Valid8 customers. For more information about the privacy practices of Valid8 customers, please contact the relevant customer.

Where we act as a processor for our customers and we process personal data of data subjects in the EEA and UK, we will ensure compliance with the GDPR and other applicable EU data protection laws.

Valid8 reserves the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as sending you an email notification). In all cases, your continued use of the Service following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices.

This Privacy Policy covers the following topics:

COLLECTION OF PERSONAL INFORMATION

USE OF PERSONAL INFORMATION

SHARING OF PERSONAL INFORMATION

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

YOUR CHOICES

CHILDREN’S PRIVACY

SECURITY OF PERSONAL INFORMATION

THIRD PARTY WEBSITES AND SERVICES

NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT LAW)

NOTICE TO NEVADA RESIDENTS

NOTICE TO EUROPEAN USERS

CONTACTING US

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COLLECTION OF PERSONAL INFORMATION

Personal Information You Provide. We collect personal information when you provide it to us, which may include the following:

• Contact information, such as first and last name and company email address, phone number, and mailing address.
• Professional information, such as company name, job title, company location, and other details we may collect about your business or profession.
• Account information, such as information you provide during registration or agreement submission, records of products and services you have purchased from us, and other details about your use of the Service.
• Payment information, such as bank account number, credit or debit card number, or financial account details used for payments. All payment processing services connected with your use of the Service are provided to you by third-party payment processors.
• Preferences, such as any marketing or communications preferences.
• Survey responses, such as the information you provide in response to our surveys or questionnaires.
• Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us. We and our service providers may also record or monitor any call or chat you have with us for quality control or training purposes, or to enforce our rights.

Personal Information from Third Parties. We may obtain personal information about you from third parties, such as social media platforms and other public sources, third parties that help us advertise our services and find new customers, joint marketing partners, event co-sponsors, and other third parties.

Personal Information Collected Automatically. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your activity over time on our Service and other sites and online services, such as:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state, or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Like many online services, we use the following technologies to facilitate some of our automatic data collection:

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
• Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Service, and remember your preferences.
• Session-replay technologies, which are third-party software programs that we may use on the Site to record a video replay of user’s interactions with the Site. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Site, understand how users interact with and use the Site, and identify areas for improvement.

Referrals. Customers and other users of the Service may have the opportunity to refer friends, colleagues, or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

USE OF PERSONAL INFORMATION

Valid8 uses personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.

To Provide the Service. We may use personal information to provide our Service and to operate our business. For example, we use personal information to:

• process your transactions, including granting access to our online products and technology;
• establish, manage, monitor, and maintain your account;
• improve and personalize your experience on or with the Service;
• verify your identity or determine your eligibility for offers or promotions;
• communicate with you, including providing notices about your account or transaction (e.g., confirmations, technical notices, updates, and security alerts) and responding to any of your requests, feedback, or questions;
• contact you by phone, email, or other form of communication;
• provide any contests, surveys, sweepstakes, or other promotions you participate in;
• provide maintenance and support; and
• fulfill any other purpose for which you provide personal information.

Research and Development. We may use your personal information for research and development purposes, including to study and improve the Service and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.

Direct Marketing. We may send you Valid8-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below.

Interest-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our Service. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above in the section called “Personal Information Automatically Collected”) over time across our Site and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “YOUR CHOICES” section below.

Customer Testimonials. We may display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name.

For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Service, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Service; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. We will also use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

SHARING OF PERSONAL INFORMATION

In addition to the sharing described elsewhere in this Privacy Policy or at the point of collection, Valid8 may share your personal information as follows:

Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies.

Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform website hosting, maintenance services, database management, analytics, payment processing, marketing, email marketing, customer relationship management, finances, and other purposes.

Advertising Partners. We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Service for the purposes described in the “Interest-Based Advertising” section above.

Contest and Joint Marketing Partners. We may also share your personal information with other partners in order to provide you with content and other features through the Service, and such partners may send you promotional materials or otherwise contact you regarding products and services that they offer. When you choose to enter a contest or sign up for a promotion, if applicable, we may share the personal information you provide as part of the offer with the named co-sponsors or other third parties affiliated with such offer.

Professional Advisors. We may share personal information with persons, companies, or professional firms providing Valid8 with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

Law Enforcement, Government Authorities, and Private Parties. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We may also disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”

Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Valid8 is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.

YOUR CHOICES

Review and Request Changes to Your Account Personal Information. If you have a Valid8 account, you can log into your account to review, delete, and make changes to certain personal information stored in your account. If you need to make a change and are unable to do this through your account settings, please email us using the contact information at the end of this Privacy Policy. We rely on you to update and correct the personal information contained in your account. Note that we may keep historical information in our backup files as permitted by law.

Marketing Emails. You may opt-out of marketing-related emails by clicking the “unsubscribe” link at the bottom of the email or by contacting us as described below. You may still receive service-related communications, such as those relating to your account.

Text Messages. We may offer communications via text messages sent by Valid8 or any of our service providers. To stop receiving text messages from us, reply STOP to any text message you receive from us, or send your request and mobile telephone number to the email address listed at the end of this Privacy Policy. Note that we may send you a message to confirm receipt of your STOP request.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Site and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Analytics. We use Google Analytics to help us analyze how our Site is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.

Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the Digital Advertising Alliance (https://optout.aboutads.info), or the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.

Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Site currently does not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

CHILDREN’S PRIVACY

The Service is not intended for use by anyone under the age of 18, and we do not knowingly collect personal information from minors under 18.

SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.

THIRD PARTY WEBSITES AND SERVICES

The Service may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT LAW)

This section applies only to California residents. The  California Consumer Privacy Act (CCPA) is a data protection law that ensures you have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Valid8 are entitled to ask us for a notice describing what categories of personal information we share with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like a copy of this notice, please submit your request to the email address listed at the end of this Privacy Policy with “Shine the Light” in the subject line.

In addition, you also have the following rights:

• Right of Access: you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
• Right of Deletion: you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.

NOTICE TO NEVADA RESIDENTS

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.

NOTICE TO EUROPEAN USERS

The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Valid8, Inc., 1425 Pearl Street, 2nd Floor, Boulder, CO 80302 USA.

Legal Basis for Processing. The applicable legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us using the contact information at the end of this Privacy Policy.

Processing Purpose (as described above in the “Use of Personal Information” section)

Purposes & Legal Basis

To Provide the Service

Processing is necessary to enter into a contract with you as per your request, to perform the contract governing our operation of the Service, or to take steps that you request prior to engaging us or our services. Where we cannot process your personal information as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interests (for example, to provide our services, to respond to your requests) as further described in this Privacy Policy.

The collection and processing of certain information may be required by contract or necessary to enter into a contract with us or to provide our services to you (for example, identity, contact details, signature, bank account or payment details, etc.). Failure to process the data required in this context may make it impossible to conclude or perform a contract with you.

Research and Development

Processing is based on our legitimate interests in performing research and development as described in this Privacy Policy.

Direct Marketing

Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or via the relevant Service.

Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.

Interest-Based Advertising

As detailed in this Privacy Policy, we may use cookies and similar technologies to collect information about you (including the online activity information and device information) using the third-party advertising companies and social media companies we work with to help us advertise our business and to display ads for our Service. Processing is based on your consent where that consent is required by applicable law.

For Compliance, Fraud Prevention, and Safety

Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.

In such cases, processing of certain personal information about you could be a statutory requirement for us and the provision or processing otherwise of such data would be mandatory. Failure to process the necessary data in this context may lead to non-compliance with certain legal requirements or obligations that would be incumbent on us by law.

With Your Consent

Processing is based on your consent in principle for direct marketing and personalized advertising, where that consent is required by applicable law. 

Where we ask for your consent to process data for specific purposes under applicable law, you are under no obligation to provide such data and there are no consequences if you choose not to provide your consent.

Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or via the relevant Service. The withdrawal produces effects for future and does not affect the previous processing activities.

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Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

For more specific information of the applicable retention periods, contact us at info@valid8financial.com.

Recipients

For information about the recipients to whom we may share your personal information depending on the interaction you have with us, please see the SHARING PERSONAL INFORMATION section of this Policy.

Automated individual decision-making, including profiling

We do not use algorithms or profiling to make any decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We will notify you accordingly if we engage in such processing in the future.

Your Rights. European data protection laws may give you certain rights regarding your personal information, under certain conditions. You may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Rectify. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information on grounds relating to your particular situation or for direct marketing purposes.

You can find more information regarding the data subjects rights under GDPR here. You may also write us using the information provided at the end of this Privacy Policy to ask for more details on your rights.

You may submit these requests by contacting us using the information provided at the end of this Privacy Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. 

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us.

You also have the right to submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. 

If you provide your personal information directly to us or to our processors or sub-processors, knowing that we are based in the United States, you understand and agree that your personal information will also be processed in the United States.

Please contact us using the information provided at the end of this Privacy Policy for further information about any such transfers or the specific safeguards applied.

CONTACTING US

If you have any questions or concerns about our Privacy Policy or any other privacy matters, please contact us at info@valid8financial.com.