Privacy Policy

Privacy Policy

CodeFi Solutions, LLC
PRIVACY POLICY
Last Updated December 08, 2022

One of CodeFi’s key values is educating its users and empowering them with information. Our goal is to educate and empower you with this privacy policy (this “Privacy Policy,“) to explain how CodeFi Solutions, LLC d/b/a Boots Technologies (“CodeFi“, “we“, “us“, or “our“) collects, uses, discloses, and applies the information collected when you use or access our website and any of our related websites, services, and applications that link to this Privacy Policy (the “Services“).

By using the Services or interacting with us, you are agreeing to this Privacy Policy. Please read the following carefully to understand how we collect, use, disclose, and maintain the information that can be associated with, or which relates to you and/or could be used to identify you (“Personal Data“) In addition, this Privacy Policy describes your choices for use, access, and correction of your Personal Data. If you do not agree to be bound by this Privacy Policy, please stop using the Services.

  1. Changes to this Privacy Policy. We may change this Privacy Policy from time to time. In the event we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. If there are significant changes to this Privacy Policy, we will attempt to notify you directly by email or provide information via our home page prior to such changes becoming effective. We encourage you to review our Privacy Policy whenever you use the Services to stay informed of ways you can protect your privacy.

  2. Information We Collect and Receive. We collect Personal Data from you from various sources and through various methods. Below are the types of Personal Data we may collect and from where we may collect it.

    1. Information You Provided to Us. We collect information that you decide to share with us. At times, we may require you to provide certain information in order to use certain parts of our Services, fulfill your requests, or provide you with certain services.

      1. Account Information. When you create an account, you may provide us with your name, email address, phone number, physical address, and any other information you choose to upload to your account.

      2. Financial Information. To receive and/or authorize payments, you may provide us with certain sensitive Personal Data, such as your social security number or employer identification number, bank name, account number, routing number, and type of bank account.

      3. Social Media Data. We have pages on social media services such as YouTube, Instagram, and LinkedIn (“Social Media Pages“). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details and messages sent. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

      4. Contacting Us. You may interact with us through our Services, including through an online contact form, email, or any other communication mechanism. When using these channels, you typically provide your account information and any other information you choose to provide to us at your option.

      5. Surveys. When you complete any forms or respond to a survey or questionnaire, we collect the Personal Data that you provide.

    2. Information We Obtain from Others. We may obtain information about you from other sources, including third party services and organizations (such as social networks), and publicly available sources.

      1. ID Verification. In accordance with applicable law, we, or our service providers, may obtain information about you from public databases, credit bureaus and ID verification service providers for the purpose of verifying your identity. Such information may include name, address, publicly available information, credit history, status on any sanctions’ lists maintained by public authorities, and other relevant data.

      2. Third-party Social Media and Websites. If you decide to visit our page on a social media website, we may collect Personal Data about you from that website that you have made available via your privacy settings.

    3. Information We Automatically Collect. We automatically collect certain information from you when you use the Services, including internet or other network activity information such as your Internet Protocol (“IP”) address, unique device identifiers, browsing and search history within the Services, and cookies and other technologies.

      1. Log Information. We retain information about you when you access and use the Services. This information can include the following: IP address, timestamps, browser information, Internet Service Provider “ISP”, webpages visited, and the URL of the webpage you visited before navigating to our Services.

      2. Device Information. We monitor user activity in connection with the Services and may collect information about the applications and features you use, websites you visit, as well as types and amount of Services you use.

      3. Crash and Error Information. If the Services crash or return an error, we may collect data to determine the cause of the error using first- or third-party services. The crash or error information collected may include the following: Device IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.

      4. Cookies. Like many online services, we use “cookies” to collect technical information. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Services. We may use cookies to collect information about your IP address, browser type, operating system, device type and identifiers, platform type, as well as your usage of and activity on the Services and the performance of the Services. We may also use analytics service providers such as Google Analytics to help analyze how people use our Services (“Analytics Companies”). Analytics Companies use cookies and similar technologies to collect information pertaining to how people use our Services, what pages they visit, and what other sites they may have used prior to using our Services. To learn more about how Google Analytics uses your information, please review Google’s Privacy Policy.

  3. How We Use Your Information

    1. We may use your Personal Data for our legitimate interests and the limited purpose of providing the Services and related functionality and services, as described in this Privacy Policy, and as permitted by applicable laws. These purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent. We may use your Personal Data as follows:

      1. To provide the information, products, and services you request, including financial services such as disbursement of funds;

      2. To provide you, if you have an active account, with effective customer service;

      3. To provide you with a personalized experience when you use our Services;

      4. To contact you with special offers, promotions, and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);

      5. o contact you with information and notices related to your use of the Services;

      6. To invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);

      7. To better understand your needs and interests;

      8. To improve our products and services and develop new products and services;

      9. To improve our marketing and promotional efforts;

      10. To improve the content, functionality, and usability of the Services;

      11. To enforce our policies or other agreements;

      12. To promote security; to protect against and prevent fraud, claims, and other liabilities;

      13. To verify your identity; to authorize your account;

      14. To use for any other purpose for which we provide notice at the time of collection; and

      15. To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

    2. In an effort to understand and serve our users better, we may conduct research on our customer demographics, interests, and behaviors using aggregated and/or de-identified information collected through the Services and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information“).

  4. How We Share and Disclose Information.

    1. Other Boots Users. We may share your Personal Data with other users of the Services, including lenders and/or financial institutions that you are connected with via the Services.

    2. Service Providers and Third-Parties. We may share your Personal Data with third-party vendors that perform tasks on our behalf and under our instruction. For example, we may share your Personal Data with data storage and hosting providers, email service providers, analytics providers, network and system management providers, communications tools, IT support providers, CRM providers, incentive providers, and accounting services. These third-party vendors may use your Personal Data only in connection with the services they perform on our behalf, and they are bound to protect your Personal Data in a manner consistent with our own policies and practices. In addition, you may choose to use certain features on our website for which we partner with other entities. These features are operated by third parties that are not affiliated with us. These third parties may use your Personal Data in accordance with their own privacy policies. On websites on which these features are offered, the relevant third parties are identified. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.

    3. Aggregate/De-Identified Data. From time to time, we may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.

    4. Legal Reasons. We may also disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data to prevent or investigate a possible crime, such as fraud or identity theft, to protect the security of our Services, to enforce or apply our policies or other agreements, or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.

    5. Sale, Merger, or Other Business Transfer. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, your Personal Data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

  5. Your Choices.
    1. If you have registered for an account, you may access, review, update, or delete certain Personal Data that you have provided to us by logging into your account and using available features and functionalities or by contacting us in accordance with the “Contact Us” section below. You may also contact us to delete your account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy. Please also note that due to tax and client obligations, we may not be able to delete all Personal Data associated with your account. To the extent that we cannot delete your Personal Data, we will promptly provide you with our decision and rationale.

    2. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In addition to adjusting the appropriate settings in your browser, many advertising companies that may collect information for targeted advertising purposes are also members of the Digital Advertising Alliance or the Network Advertising Initiative. Both of these organizations provide directions on how individuals can opt-out from targeted advertising by their members. You can find more information on these opt-out capabilities on www.aboutads.info and www.networkadvertising.org.

    3. You have a choice at any time to stop us from sending you emails for marketing purposes by following the “unsubscribe” link included in these messages. Please note that despite any indicated email marketing preferences, we may continue to send you administrative emails, including, for example, notices of updates to our policies including this Privacy Policy, if we choose to provide such notices to you in this manner.

    4. In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. We will tell you what Personal Data that you must provide in order to receive the Services.

    5. Some browsers offer a “do not track” (“DNT“) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

  6. Retention of Personal Data. We will retain Personal Data required to comply with privacy requests, to manage active accounts, as required by law, in order to resolve disputes, assist with the fulfillment of tax obligations, or to enforce our agreements. We will retain the Personal Data we process on behalf of our users as directed by them. We may also retain copies of your Personal Data for disaster recovery purposes, to prevent fraud or future abuse, or for legitimate business purposes.

  7. Information Security. The security of your information is important to us. We use reasonable administrative, technical, and physical procedures, practices, and safeguards designed to protect Personal Data we collect from unauthorized access, use, alteration, exfiltration, or destruction. Although we work hard to ensure the integrity and security of our systems, it must be recognized that no information system is 100% secure and, therefore, we cannot guarantee the security of such information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time.

  8. International Users. The Services are hosted in the United States and are intended for and directed to users in the United States. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing Personal Data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Services, which are governed by U.S. law, this notice and our other policies that govern your use of the Services, you are transferring your Personal Data to the United States and you consent to that transfer. The Services are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

  9. Links to Third-Party Websites. The Services may contain links to other websites not operated or controlled by us, including social media services (“Third-Party Websites”). The information that you share with Third-Party Websites will be governed by the specific privacy policies and terms of service of the Third-Party Websites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these websites. Please contact the Third-Party Websites directly for information on their privacy practices and policies.

  10. Children’s Information. The Services are directed to individuals at the age of 13 and over. We do not knowingly collect Personal Data from individuals under the age of 13. If we become aware of individuals who have provided us with Personal Data and are under the age of 13, we will take steps to deactivate the account and delete the Personal Data. If you become aware of information from individuals under the age of 13 which has been provided to us, please contact us in accordance with the “Contact Us” section below.

  11. US State Specific Provisions.

    1. California Residents.

      1. If you are a resident of the State of California, you have certain rights afforded to you under the California Consumer Privacy Act or the “CCPA”. When we say “Personal Data” in this Section, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Data does not include information that is aggregated or information that cannot be reasonably linked to you.

      2. We collect Personal Data and non-Personal Data for the business and commercial purposes described in the Section above titled “How We Use Your Information”, and we share Personal Data with the categories of third-parties described in the Section above titled “How We Share and Disclose Information”. We do not currently sell (as such term is defined in the CCPA) the Personal Data we collect (and will not sell it, in the future, without providing a right to opt-out). Please note that we may use third- party cookies for our advertising purposes as further described in the Section above titled “Information We Automatically Collect”.

      3. Subject to certain limitations, the CCPA provides California residents the following rights:

        1. You have the right to request that we disclose to you the Personal Data we collect, use, or disclose, and information about our data practices;

        2. You have the right to request that we delete your Personal Data that we have collected from you;

        3. You have the right to request that we no longer sell your Personal Data to third-parties; and

        4. We will not discriminate against you for exercising any of these rights.

      4. California residents may make a request pursuant to their “right to know”, “right to request deletion”, and/or “right to opt-out” under the CCPA by contacting us in accordance with the “Contact Us” Section below. In order to verify your request to know or delete information, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.

      5. Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

    2. Nevada Residents. Under State of Nevada law, certain Nevada consumers may opt-out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt-out of any potential future sales under Nevada law by contacting us in accordance with the “Contact Us” Section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

  12. Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via email at support@bootsusa.io.

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