Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our platform, register on the platform, subscribe to the newsletter, fill out a form, and in connection with other activities, services, features or resources we make available on our platform. Users may be asked for, as appropriate, name, email address. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain platform related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our platform. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our platform, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
How we use collected information
SprinkleBit Holding, Inc. may collect and use Users personal information for the following purposes:
- To improve customer service Information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize user experience we may use information in the aggregate to understand how our Users as a group use the services and resources provided on our platform.
- To improve our platform we may use feedback you provide to improve our products and services.
- To send periodic emails We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our platform. For more information look at our Privacy Shield Policy below.
Sensitive and private data exchange between the platform and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
No passwords are ever stored in plain text on the servers and is regenerated by every new password request.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers. We may use third party service providers to help us operate our business and the platform or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
Third party websites
Users may find other content on our platform that link to the sites and services of our partners, or other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our platform. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our platform, is subject to that website's own terms and policies.
Compliance with children's online privacy protection act
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our platform from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
Your acceptance of these terms
By using this Site or mobile application, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site or mobile application. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
SprinkleBit Holding, Inc.
This document was last updated on December 2n, 2016
Privacy Shield Policy
SprinkleBit Holding, Inc. ("SprinkleBit") has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that SprinkleBit obtains from Customers located in the European Union and Switzerland.
The Federal Trade Commission (FTC) has jurisdiction over SprinkleBit's compliance with the Privacy Shield.
All SprinkleBit employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Individual Customer Personal Data that SprinkleBit receives in the United States concerning Individual Customers who reside in the European Union and Switzerland. SprinkleBit provides services to businesses and consumers.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
II. RESPONSIBILITIES AND MANAGEMENT
SprinkleBit has designated the Operational Department to oversee its information security program, including its compliance with the EU Privacy Shield program and Swiss Safe Harbor. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to firstname.lastname@example.org
SprinkleBit will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. SprinkleBit personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that SprinkleBit has undertaken to protect Personal Data.
III. RENEWAL / VERIFICATION
SprinkleBit will renew its EU Privacy Shield and US Swiss Safe Harbor certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, SprinkleBit will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, SprinkleBit will undertake the following:
SprinkleBit will prepare an internal verification statement on an annual basis.
- Ensure that this Policy continues to comply with the Privacy Shield and the Swiss Safe Harbor principles
- Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (SprinkleBit may do so through its publicly posted website.)
- Review its processes and procedures for training Employees about SprinkleBit's participation in the Privacy Shield and Swiss Safe Harbor programs and the appropriate handling of Individual's Personal Data
IV. COLLECTION AND USE OF PERSONAL DATA
SprinkleBit provides various services to its Individual Customers who use its platform. SprinkleBit collects Personal Data from Individual Customers when they register with our platform (web, iOS, android), and connect with third-parties. For example, SprinkleBit individual customers may choose to connect with his/her bank to share limited trading data or with Facebook to share their profile picture and name.
The Personal Data that we collect may vary based on the Individual Customer's interaction with our platform and request for our services. As a general matter, SprinkleBit collects the following types of Personal Data from its Individual Customers: user information, including, the person's name, email address, and with social signup we collect the profile picture. Individual customers have the option to log into their accounts online and
When Individual Customers use our platform, we will collect their IP address and browser/device type. We may associate IP address and browser type with a specific customer. For users who connect with their bank, we also collect information on percentage of holdings. We never collect any currency denominated amounts to keep your privacy.
The information that we collect from Individual Customers is used to create the experience on the platform and is the minimum to get you a great experience.
SprinkleBit uses Personal Data that it collects directly from its Individual Customers for:
- maintaining the social network with a real and vivid community;
- calculating virtual portfolios in the stock simulator;
- storing and processing data, including Personal Data, in computer databases and servers located in the United States or Europe (for European users);
- verifying identity (e.g., for online access to accounts);
- for other business-related purposes permitted or required under applicable local law and regulation;
- and as otherwise required by law.
V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
SprinkleBit store Personal Data with Amazon Web Services a Third Party that act as an agent to perform tasks on behalf of and under our instructions. As such, Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by SprinkleBit and they must either:
SprinkleBit also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that SprinkleBit may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. SprinkleBit is liable for appropriate onward transfers of personal data to third parties.
- comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
- or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;
VI. SENSITIVE DATA
All records containing personal or financial information are considered to be our property and are afforded confidential treatment at all times. We work hard to protect against the unauthorized access, use, alteration or destruction of personal or financial information. All such electronic information is stored on restricted database servers, and is generally kept until such time as you may ask us to edit or delete it, as described below. We only disclose such information to our employees, contractors or affiliates that a) need to know that information in order to process it for us or to provide other services, and b) have agreed not to disclose it to others.
VII. DATA INTEGRITY AND SECURITY
All interactions with our Services use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. We use a third-party, industry-accepted Payment Gateway to securely process credit card transactions.
Data Integrity — In addition to assuring you that we will protect your personal information, we also want to make sure that it is reliable, accurate, and up-to-date. In order to do that, we provide:
Access — Upon request, we will provide you with reasonable access to the personal information we collect about you. Because personal information—for example, your email address—is required to use The Services, we retain personal information as long as your account is active. You will have the opportunity to correct, update, modify or delete this information updating your information in The Services. Please note that some information may remain in our records even after you request deletion of your information as permitted by the Safe Harbor Principles. Additionally, there may be limits to the amount of information we can practically provide. For example, we may limit an individual's access to personal information where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy or where doing so would violate others' rights.
SprinkleBit uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. SprinkleBit has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to SprinkleBit's electronic information systems requires user authentication via password plus additional means. SprinkleBit also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
IX. ACCESSING PERSONAL DATA
SprinkleBit personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
- Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which SprinkleBit collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and SprinkleBit policies. Upon reasonable request and as required by the Privacy Shield principles, SprinkleBit allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting SprinkleBit by email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a request to delete their data.
- Requests for Personal Data. SprinkleBit will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If SprinkleBit receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, SprinkleBit will refer such Data Subject to the Individual Customer.
- Satisfying Requests for Access, Modifications, and Corrections. For any request regarding data outside of edit limitation on the platform, SprinkleBit will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
- Choice. SprinkleBit does not share personal data. However, we still offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, SprinkleBit will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. SprinkleBit shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
XI. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy through email. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XII. QUESTIONS OR COMPLAINTS
EU Individual customers may contact SprinkleBit with questions or complaints concerning this Policy at the following address:
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
XIV. DEFINED TERMS
"Individual Customer" means an Individual customer or client of SprinkleBit from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of SprinkleBit and all employee of SprinkleBit where SprinkleBit has obtained his or her Personal Data from such Individual Customer as part of its business relationship with SprinkleBit.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of SprinkleBit or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
"Europe" or "European" refers to a country in the European Union.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither SprinkleBit nor an SprinkleBit employee, agent, contractor, or representative.
Statement of Rights and Responsibilities
This Statement of Rights and Responsibilities ("Statement," "Terms," or "SRR") s our terms of service that governs our relationship with users and others who interact with SprinkleBit, as well as SprinkleBit brands, products and services, which we call the “SprinkleBit Services” Or “Services”. By using or accessing the SprinkleBit Services, you agree to this Statement, as updated from time to time.
Anyone not abiding to these policies will have their account disabled and if criminal actions have been made we will cooperate with the corresponding agency.
- Sharing Your Content and Information
You own all of the content and information you post on SprinkleBit, and you can control how it is shared through your privacy and application settings In addition:
- For content that is covered by intellectual property rights, like photos and videos (IP content), you specifically give us the following permission, subject to your privacy and application settings: you grant us a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with SprinkleBit (IP License). This IP License ends when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it.
- When you delete IP content, it is deleted in a manner similar to emptying the recycle bin on a computer. However, you understand that removed content may persist in backup copies for a reasonable period of time (but will not be available to others).
- When you use an application, the application may ask for your permission to access your content and information as well as content and information that others have shared with you. We require applications to respect your privacy, and your agreement with that application will control how the application can use, store, and transfer that content and information
- When you publish content or information using the Public setting, it means that you are allowing everyone, including people off of SprinkleBit, to access and use that information, and to associate it with you (i.e., your name and profile picture).
- We always appreciate your feedback or other suggestions about SprinkleBit, but you understand that we may use your feedback or suggestions without any obligation to compensate you for them (just as you have no obligation to offer them).
- Code of Conduct
We do our best to keep SprinkleBit safe, but we cannot guarantee it. We need your help to keep SprinkleBit safe, which includes the following commitments by you:
- You will not post unauthorized commercial communications (such as spam) on SprinkleBit.
- You will not collect users' content or information, or otherwise access SprinkleBit, using automated means (such as harvesting bots, robots, spiders, or scrapers) without our prior permission.
- You will not engage in unlawful pump-and-dump of stocks, on SprinkleBit.
- You will not upload viruses or other malicious code.
- You will not solicit login information or access an account belonging to someone else.
- You will not bully, intimidate, or harass any user.
- You will not post content that: is hate speech, threatening, or pornographic; incites violence; or contains nudity or graphic or gratuitous violence.
- You will not use SprinkleBit to do anything unlawful, misleading, malicious, or discriminatory.
- You will not do anything that could disable, overburden, or impair the proper working or appearance of SprinkleBit, such as a denial of service attack or interference with page rendering or other SprinkleBit functionality.
- You will not facilitate or encourage any violations of this Statement or our policies.
- Registration and Account Security
SprinkleBit users provide their real names and information, and we need your help to keep it that way. Here are some commitments you make to us relating to registering and maintaining the security of your account:
- You will not provide any false personal information on SprinkleBit, or create an account for anyone other than yourself without permission.
- You will not create more than one personal account.
- If we disable your account, you will not create another one without our permission.
- You will not share your password to let anyone else access your account, or do anything else that might jeopardize the security of your account.
- Protecting Other People's Rights
We respect other people's rights, and expect you to do the same.
- You will not post content or take any action on SprinkleBit that infringes or violates someone else's rights or otherwise violates the law.
- We can remove any content or information you post on SprinkleBit if we believe that it violates this Statement or our policies.
- If you repeatedly misuse the service, we will disable your account when appropriate.
- You will not post anyone's identification documents or sensitive financial information on SprinkleBit.
- You will not tag users or send email invitations to non-users without their consent.
If you make a payment on SprinkleBit, you agree to our Payment Terms unless it is stated that other terms apply. If you pay through iTunes or Google Play, you agree with their payment terms.
If you violate the letter or spirit of this Statement, or otherwise create risk or possible legal exposure for us, we can stop providing all or part of SprinkleBit to you. We will notify you by email or at the next time you attempt to access your account.
- Disputes (Outside of EU)
- You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Statement or SprinkleBit exclusively in the U.S. District Court for the Southern District of New York, and you agree to submit to the personal jurisdiction of such courts for the purpose of litigating all such claims. The laws of the State of New York will govern this Statement, as well as any claim that might arise between you and us, without regard to conflict of law provisions.
- If anyone brings a claim against us related to your actions, content or information on SprinkleBit, you will indemnify and hold us harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to such claim. Although we provide rules for user conduct, we do not control or direct users' actions on SprinkleBit and are not responsible for the content or information users transmit or share on SprinkleBit. We are not responsible for any offensive, inappropriate, obscene, unlawful or otherwise objectionable content or information you may encounter on SprinkleBit. We are not responsible for the conduct, whether online or offline, of any user of SprinkleBit.
- WE TRY TO KEEP SPRINKLEBIT UP, BUG-FREE, AND SAFE, BUT YOU USE IT AT YOUR OWN RISK. WE ARE PROVIDING SPRINKLEBIT AS IS WITHOUT ANY EXPRESS OR IMPLIED WARRANTIES INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT GUARANTEE THAT SPRINKLEBIT WILL ALWAYS BE SAFE, SECURE OR ERROR-FREE OR THAT SPRINKLEBIT WILL ALWAYS FUNCTION WITHOUT DISRUPTIONS, DELAYS OR IMPERFECTIONS. SPRINKLEBIT IS NOT RESPONSIBLE FOR THE ACTIONS, CONTENT, INFORMATION, OR DATA OF THIRD PARTIES, AND YOU RELEASE US, OUR DIRECTORS, OFFICERS, EMPLOYEES, AND AGENTS FROM ANY CLAIMS AND DAMAGES, KNOWN AND UNKNOWN, ARISING OUT OF OR IN ANY WAY CONNECTED WITH ANY CLAIM YOU HAVE AGAINST ANY SUCH THIRD PARTIES. IF YOU ARE A NEW YORK RESIDENT, YOU WAIVE NEW YORK CIVIL CODE §1542, WHICH SAYS: A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR. WE WILL NOT BE LIABLE TO YOU FOR ANY LOST PROFITS OR OTHER CONSEQUENTIAL, SPECIAL, INDIRECT, OR INCIDENTAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH THIS STATEMENT OR SPRINKLEBIT, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. OUR AGGREGATE LIABILITY ARISING OUT OF THIS STATEMENT OR SPRINKLEBIT WILL NOT EXCEED THE GREATER OF ONE HUNDRED DOLLARS ($100) OR THE AMOUNT YOU HAVE PAID US IN THE PAST TWELVE MONTHS. APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU. IN SUCH CASES, SPRINKLEBIT'S LIABILITY WILL BE LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.
- By "SprinkleBit" or” SprinkleBit Services” we mean the features and services we make available, including through (a) our website at www.SprinkleBit.com and any other SprinkleBit branded or co-branded websites (including sub-domains, international versions, widgets, and mobile versions); (b) our Platform; SprinkleBit reserves the right to designate, in its sole discretion, that certain of our brands, products, or services are governed by separate terms and not this SRR.
- By "Platform" we mean a set of APIs and services (such as content) that enable others, including application developers and website operators, to retrieve data from SprinkleBit or provide data to us.
- By "information" we mean facts and other information about you, including actions taken by users and non-users who interact with SprinkleBit.
- By "content" we mean anything you or other users post, provide or share using SprinkleBit Services.
- By "data" or "user data" or "user's data" we mean any data, including a user's content or information that you or third parties can retrieve from SprinkleBit or provide to SprinkleBit through Platform.
- By "post" we mean post on SprinkleBit or otherwise make available by using SprinkleBit.
- By "use" we mean use, run, copy, publicly perform or display, distribute, modify, translate, and create derivative works of.
- By "application" we mean any application or website that uses or accesses Platform, as well as anything else that receives or has received data from us. If you no longer access Platform but have not deleted all data from us, the term application will apply until you delete the data.
- This Statement is an agreement between you and SprinkleBit Holding, Inc.
- This Statement makes up the entire agreement between the parties regarding SprinkleBit, and supersedes any prior agreements.
- If any portion of this Statement is found to be unenforceable, the remaining portion will remain in full force and effect.
- All of our rights and obligations under this Statement are freely assignable by us in connection with a merger, acquisition, or sale of assets, or by operation of law or otherwise.
- Nothing in this Statement shall prevent us from complying with the law.
- This Statement does not confer any third party beneficiary rights.
- We reserve all rights not expressly granted to you.
- You will comply with all applicable laws when using or accessing SprinkleBit.