Privacy Policy

LAST REVISED: September 1, 2021

This Privacy Policy describes how FundOf and its affiliates (“we,” “us,” or “Fundof”) process personal information that we collect through our Services.

Undefined terms in this Privacy Policy have the same definition as in our Terms & Conditions.

1. PERSONAL INFORMATION WE COLLECT

We only collect, use, share, store or otherwise process your personal information when we have a legal basis to do so. For example, we may process your personal information to comply with legal obligations or to protect our legitimate interests, preventing and detecting fraud or misuse of the Services and maintaining the security of the Services. We may also process your personal information as necessary to provide the Services, subject to our Terms & Conditions or other written contract to which you have agreed.

We collect the following types of personal information when you provide it to us or our service providers:

Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

Identity Verification and Payment Information. Such as images of your government-issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.

You can decide not to provide certain personal information to us. However, if you choose not to provide it, you may not be able to use all, or any, of the features of our Services.

You can choose to provide us with additional personal information. This information may include:

Address Book Contact Information. Address book contacts you import or enter manually.

Other Information. Such as when you fill in a form, add information to your account, respond to surveys, participate in promotions, communicate with our customer care team, or share your experience with us.

The following information is automatically collected by using the Fundof Platform and our Payment Services:

Usage Information. Such as the pages or content you view, searches for Creators, Tips you have made, and other actions on the Fundof Platform.

Log Data and Device Information. Such as details about how you’ve used the service (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our Services. We may collect this information even if you haven’t created a Fundof account or logged in.

Cookies and Similar Technologies. Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us to improve our Services and your experience. You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Services but your access to some functionality and areas of our Services may be restricted. We may use Google Analytics or similar analytics tools to enhance our Services.

Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, your address and other related transaction details.

We collect personal information from third parties, such as:

Third-Party Services: If you link, connect, register or login to Fundof with a third party service (e.g. Google, Apple), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

Referrals: If you are invited to Fundof by another User, the person who invited/referred you can submit personal information about you such as your email address or other contact information.

Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, or information to help detect fraud and safety issues from third-party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts.

2. HOW WE USE PERSONAL INFORMATION

We use personal information for the following purposes:

To enable us to provide our Services (e.g., to process your Tips, enable you to receive Tips, or to send you Tip confirmations via email).

To monitor and analyze how you use our Services, for example, how long you spend on our Platform, how you use our Services, and usage and trends related to your use of the Services.

To personalize and improve our Services, and our users' experiences with our Services (such as providing content or features that match interests), and to increase our Services' functionality and user-friendliness.

To request feedback and to otherwise contact you about your use of our Services.

To respond to your emails, questions, comments, requests and complaints, and to provide customer service and technical support.

To enforce our Terms & Conditions and other policies

To provide you with marketing messages, news and information about events, offers, promotions and services we think will be of interest to you (if you do not wish to receive these messages, you can unsubscribe by following the instructions at the bottom of the message).

To investigate and protect our users from fraudulent, abusive, inappropriate, or unlawful use of our Services.

To comply with legal obligations (such as anti-money laundering regulations).

To send you confirmations, updates, security alerts and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, our Services.

To notify you about important changes to our Services.

For other purposes which are explained to you at the time we collect your personal information, as applicable.

3. WHEN AND WHY WE SHARE PERSONAL INFORMATION

FundOf does not rent or sell your personal information to third parties. We share your personal information in the following limited circumstances:

Service providers - From time to time, we may need to share your personal information with certain service providers so that they can perform services on our behalf as needed for us to provide the Services. This may include payment-related information, your name and address, details about your invoice, details of your account with us, location, and information about the device you are using to access our Services (such as your device ID, operating system and browser, application and service logs, and information about how you use and interact with our Platform). Service providers include among others payment processing companies, open-banking partners, ID verification service providers, and others.

Third-party investigators, authorities, or law enforcement bodies - We may share your personal information to investigate and protect our users from fraudulent, abusive, inappropriate, or unlawful use of our Services.

If Fundof is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets. In this event, we will notify you before your personal information is transferred and becomes subject to a different Privacy Policy.

4. HOW LONG WE KEEP PERSONAL INFORMATION

In general, Fundof will only keep your personal information for as long as it is necessary to achieve the above-mentioned purposes or for our legitimate purposes or as required by law.

5. LINKS TO OR INTERACTIONS WITH OTHER WEBSITES

Our Services may contain links to other websites, including social media sites. Any personal information you provide on the linked pages is provided directly to that third party and is subject to that third party's Privacy Policy. Fundof is not responsible for the content or privacy and security practices and policies of these websites or any other websites that are linked to or from our Services.

6. YOUR RIGHTS

You may "opt-out" of receiving marketing or promotional messages from us by following the instructions in those messages. If you opt-out, we may still send you non-promotional emails, such as emails about your account or our on-going business relations.

7. NOTE ON THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are located in the EU or EEA, you may have the following rights:

To have access to any personal information we hold about you and request portability.

To ask us to correct, update or erase the personal information we hold about you.

To ask us not to use your personal information for direct marketing purposes.

To ask us to restrict the way that we process your personal information.

To ask us to have your personal information transferred.

To object to our processing of your personal information.

You have the right to withdraw your consent to us processing your personal data at any time; the withdrawal will not affect our processing activities conducted prior to your withdrawal.

You can request any of your aforementioned rights by contacting us at request@fundof.com. Please note, however, that personal information may be exempt from such requests in certain circumstances, which may include the need to keep processing your personal information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with the information necessary to confirm your identity before responding to your request.

8. CHANGES TO THIS PRIVACY POLICY

Fundof may amend this Privacy Policy at any time. If we make changes to this Privacy Policy, we will publish the revised policy in the Services and update the “Last Revised” date. Please review this Privacy Policy periodically so that you understand how your personal information will be used. Your continued use of the Services indicates you agree with the Privacy Policy as updated.

9. CONTACT

If you have any questions about this Privacy Policy, or about how we use your personal information or would like to exercise any of your rights under this Privacy Policy, you may contact us at request@fundof.com.

10. OUR CORPORATE ADDRESS

Hyperstandard SA

Via Dufour 1

6900 Lugano

Switzerland

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