Privacy Policy

Effective Date: December 6, 2020

THIS IS A WEBSITE PRIVACY POLICY DRAFTED UNDER U.S. LAW. THIS POLICY IS NOT INTENDED TO SATISFY ANY ‘FAIR PROCESSING NOTICE’ OBLIGATIONS THAT YOU MAY HAVE UNDER GDPR OR OTHER APPLICABLE NON-US LAW.

In this Privacy Policy (“Policy”), we describe how Hydrogen (“Company”) collects, uses, and discloses information that we obtain about visitors to our website https://www.hydrogenplatform.com (the “Site”), users of our mobile Application and the services available through our Site (collectively, the “Services”).

By visiting the Site, using or downloading the Applications, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Company Terms of Service are incorporated by reference into this Policy.


The Information We Collect About You. 3

Information We Collect Directly From You. 3

Information We Collect Automatically. 3

How We Use or Disclose Your Information. 3

How We Share Your Information. 4

Our Use of Cookies and Other Tracking Mechanisms 5

Flash Local Storage Objects 5

Clear GIFs, pixel tags and other technologies 5

Third Party Analytics 5

Cross-Device Use 6

Do-Not-Track 6

Third-Party Ad Networks 6

User Generated Content 6

Third-Party Links 7

Security of My Personal Information. 7

Access To My Personal Information. 7

What Choices Do I Have Regarding Use of My Personal Information?. 7

Special Information for California Consumers. 7

Contact Us 12

 


The Information We Collect About You

We may collect information about you directly from you, from third parties, and automatically through your use of our Site or Services.

Information We Collect Directly From You. The information we collect from you depends on how you use our Services. To create an account, you must provide your name, email address, phone number, country of registration, company name, company type/vertical, and information about your company such as EIN, number of employees, and mailing address. We also may collect additional information from you, including a description of what you are trying to build. We use this to gather data for our CRM. If you make a purchase, we will collect your payment information, such as your credit or debit card information, and your billing and shipping address.

The following is a disclosure from one of our service providers, Yodlee, Inc., on the information they collect:

Our service is connected by Envestnet | Yodlee. When you request data from a source connected to our service, Yodlee, Inc. collects that data and provides it to us. Yodlee, Inc. acts on our behalf in this process, which means we share your data with Yodlee, Inc. as one of our service providers. For more information on how Yodlee, Inc. collects, uses, stores, and handles your data, please see Envestnet | Yodlee’s Commitment to its Clients and their Users (www.yodlee.com/clients-consumers). If there is any inconsistency between Yodlee, Inc.’s Commitment and this Privacy Policy regarding Yodlee, Inc.’s activities, then Yodlee Inc’s. Commitment is correct.

 

You provide log-in credentials to your accounts at your own risk.

 

By using our service you agree that the data sources that maintain your accounts and any third parties that interact with your log-in credentials or account data in connection with our service are not liable for any loss, theft, compromise, or misuse whatsoever in connection with our services (including negligence), except to the extent such liability cannot be limited under applicable law.

 

Data sources make no warranties of any kind related to the data provided by our services--whether express, implied, statutory, or otherwise. Except for PDFs of official account documents, we retrieve on your behalf and provide to you without alteration, no data provided by our services is an official record of any of your accounts.

 

Information We Collect Automatically. We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section Our Use of Cookies and Other Tracking Mechanisms below for more information

Site:

·       domain name;

·       your browser type and operating system;

·       web pages you view on the Site;

·       links you click on the Site;

·       your IP address;

·       the length of time you visit our Site and or use our Services;

·       the referring URL, or the webpage that led you to our Site.

App:

·       mobile device ID;

·       device name and model;

·       operating system type, name, and version;

·       language information;

·       activities within the App; and the length of time that you are logged into our App;

·       Use of location information. With your permission, we will collect location information from your mobile device to advertise services which may be of interest to you. You may turn off this feature through the location settings on your mobile device.

 

How We Use or Disclose Your Information

We use your information, including your personal information, for the following purposes:

·       To provide our Services to you and to fulfill your orders;

·       To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes;

·       To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services;

·       To send you email marketing about our products and services;

·       To send you news and newsletters;

·       To send you email marketing about products and services of our affiliated entities;

·       To send you email marketing about products and services of other entities that we think may be of interest to you;

·       To assist us in advertising on third party websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through third party channels (including our online targeted advertising and offline promotional campaigns);

·       To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and App are more (or least) used by users, and we will use this information;

·       For research and analytics purposes;

·       To administer our customer loyalty program;

·       To administer surveys and questionnaires, such as for market research or member satisfaction purposes;

·       To comply with legal obligations, as part of our general business operations, and for other business administration purposes;

·       Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

 

How We Share Your Information

We may share your information, including personal information, as follows:

·       Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include Marqeta, Inc., EML Payments USA, LLC, MX Technologies, Inc., Yodlee, Inc., IDology, Inc., Metabank N.A., Very Good Security, Inc., Dwolla, Inc., The Currency Cloud Ltd., Cross River Bank, Inc., Amazon Web Services, HubSpot, Inc., and Sendgrid, Inc.

The following statements are disclosures from some of our service providers:

·       During the term of this agreement Yodlee, Inc. may use an individual end user of their service’s account information, account access information and registration information, as provided by an individual end user of their service and/or retrieved by Yodlee, Inc. from a third-party information source where the individual end user of their service holds an account from which Yodlee, Inc. retrieves information (for example: bank, broker, lender, or other financial service provider) and/or provided by your company to solicit individual end users of their service to provide and improve their service;

·       During and after the term of this agreement Yodlee, Inc. may use, sell, license, distribute, and disclose individual end user of their service’s account information, account access information and registration information, as provided by an individual end user of their service and usage information from which all direct and known indirect identifiers have been removed, and on which technical, organizational and legal controls prevent employees, researchers or other third parties from re-identifying individuals as permitted by law;

·       Yodlee, Inc. shall not use an individual end user of their service’s account information, account access information and registration information, as provided by an individual end user of their service and/or retrieved by Yodlee, Inc. from a from a third-party information source where the individual end user of their service holds an account from which Yodlee, Inc. retrieves information (for example: bank, broker, lender, or other financial service provider) and/or provided by your company to solicit individual end users of their service and/or provided by your company to solicit individual end users of the Yodlee, Inc. technology.

·       Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.

·       Company Users. our username and any information that you post to our Site, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and Services.

We also disclose information in the following circumstances:

·       Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.

·       In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

·       To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

·       Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

 

Our Use of Cookies and Other Tracking Mechanisms

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

·       Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.

·       Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Flash Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Use. We and our third party service providers, including Google, may use the information that we collect about you (whether directly from our Site, from our mobile applications, through your device(s), or from a third party) to help us and our third party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We, and our third party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third Party Ad Networks section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.

 

Third-Party Ad Networks

We use third parties such as network advertisers to serve advertisements on our Site, App, and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

 

User Generated Content

We invite you to post content on our Site and Services, including your comments, pictures, and any other information that you would like to be available on our Site or Services. If you post content to our Site or Services, all of the information that you post will be available to all registered users on our Site. If you post your own content on our Site or Services, your posting may become public and Company cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

 

Third-Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

 

Security of My Personal Information

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

 

Access To My Personal Information

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Application for a period of time.

 

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

 

Special Information for California Consumers

Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act ("CCPA"). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.


A.        Categories of Personal Information Under the CCPA (Last Updated: January 1, 2021)

 

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated date above).

 

Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about consumers. For more information about the business or commercial purposes for which we collect and use personal information, please see the Use of Information section above.

 

Categories of Personal Information

Description

Identifiers

Includes direct identifiers, such as name, alias, user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; SSN, driver’s license number, passport number, tax ID and other government identifiers; and other similar identifiers.

Customer Records

Includes personal information, such as name, account name, user ID, contact information, education and employment information, SSN and government identifiers, account number, and financial or payment information, that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual register for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services.

Commercial Information

Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.

Usage Data

Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads.

Geolocation Data

Includes precise location information about a particular individual or device.

Professional information

Includes professional and employment-related information such as current and former employer(s) and position(s), business contact information and professional memberships.

Education Information

Information about an individual’s educational history, such as the schools attended, degrees you were awarded, and associated dates.

Biometric information

Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity. For example, we collect and process voiceprints for fraud detection and authentication purposes when you contact us by phone about your application or account, or if you choose to set and use facial recognition or fingerprints to login to your account.

Inferences

Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.

 

Sources of Personal Information. As further described in the Collection of Personal Information section above, we may collect personal information from the following sources:

 

      directly from the individual;

      advertising networks;

      data analytics providers;

      social networks;

      internet service providers;

      operating systems and platforms;

      government entities;

      data brokers;

      business customer/client.

 

Disclosures of Personal Information. In the table below, we identify the categories of personal information we have disclosed for a business purpose, as well as the categories of third parties to whom we may disclose such personal information. For more information about the business and commercial purposes for which we may disclose personal information, please see How We Use or Disclose Your Information.

 

Categories of Personal Information

Do We Disclose for a Business Purpose?

Do We Sell?

Categories of Third Parties to Whom Information is Sold or Disclosed

Identifiers

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Customer Records

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Commercial Information

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Usage Data

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Geolocation Data

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Professional information

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Education Information

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Biometric information

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

Inferences

YES

NO

  service providers

  advisors and agents

  government entities and law enforcement

  affiliates and subsidiaries

  advertising networks

  data analytics providers

  social networks

  internet service providers

  operating systems and platforms

  data brokers

  business customer/client

 

B.         California Residents Rights

 

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

 

·       Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than 16.

 

·       Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.

 

·       Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

 

        categories of personal information collected;

        categories of sources of personal information;

        categories of personal information about them we have disclosed for a business purpose or sold;

        categories of third parties to whom we have sold or disclosed for a business purpose their personal information;

        the business or commercial purposes for collecting or selling personal information; and

        a copy of the specific pieces of personal information we have collected about them.

 

·       Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.


Submitting CCPA Requests. California residents may submit CCPA requests through one of the following methods:

 

·       Online at www.hydrogenplatform.com/contact

·       By phone at +1 800-315-9554

 

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records or database. You must complete all required fields on our webform, or otherwise provide us with this information via the above toll-free number, to verify your request. In some cases, we may request additional information in order to verify your request, or where necessary, to verify your identity or process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us by phone or online at the above link; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

 

Your Privacy Rights Under California Shine the Light Law. Under Californias Shine the Light law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a Shine the Light request, email us at [email protected], and include in your request a current California address and your attestation that you are a California resident.

 

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at [email protected] or +1 800-315-9554.

Changes to this Policy. This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Application. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and Application.

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