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Privacy Policy

Last updated: 2020-06-28

Our Philosophy

This Privacy Policy (the “Policy”) is posted by SavvyShares LLC (“we,” “us,” or “SavvyShares”), and governs our collection and use of Member Data (as defined below) from individuals (“you,” “your,” or “member”) via the SavvyShares application (the “App”) or SavvyShares website (the App and the website are referred to collectively as the “Platform”) or any other means in connection with your membership in SavvyShares. We’ve developed this Policy to describe (1) how we collect, use, transfer, and store your Member Data; (2) your choices regarding your Member Data; and (3) how we ensure your privacy.

As used in this Policy, “Member Data” means information about our members, in whatever form. “Personal Data” is Member Data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular member or that member’s household.

The privacy and security of your Member Data, and your Personal Data in particular, is of the utmost importance to us. We understand and respect the sensitive nature of the information that our members provide to us, and we strive to be transparent in our collection, use and disclosure of this information, as described in this Policy.

We are committed to providing a secure, private, and safe environment, and our policies are designed to conform to the standards of the Insights Association Code of Standards and Ethics for Market Research and Data Analytics, the ICC/ESOMAR International Code on Market, Opinion and Social Research and Data Analytics, the Children’s Online Privacy Protection Act of 1998 (“COPPA”), and the California Consumer Privacy Act (“CCPA”).

Please note that other products or services are governed by separate privacy policies. This Policy only applies to the Platform, and to the Member Data that we collect through the Platform or in connection with your membership in SavvyShares. It does not apply to any personal data that we collect via other websites or applications where this Policy is not posted.

This Policy is incorporated into and forms a part of the SavvyShares Purchaser Consent and Terms and Conditions. By participating in SavvyShares, you consent to the Purchaser Consent and to the Terms and Conditions, including this Policy, which forms a binding agreement between you and SavvyShares. If you do not become a member of SavvyShares, your use of the Platform constitutes acceptance of the applicable terms in the Terms and Conditions and this Privacy Policy. If you do not agree with the Purchaser Consent, Terms and Conditions or this Policy, do not use the Platform or otherwise participate in SavvyShares. Continued use of the Platform or participation in SavvyShares constitutes your freely given, specific, and informed consent and agreement to the terms herein.

Description of Services

SavvyShares seeks to build and offer customers access to a database of Member Data owned by a community comprised of its members, which we refer to as our “Database,” and also seeks to build a business focused on growing and developing the Database.

Our Database will be comprised of various types of data captured or delivered depending on the methodology and submitted into the Database, including behavior data tracked through our Platform, data obtained from self-reported surveys and interviews, behavior data obtained from third parties with a member’s consent, and any other social or related data satisfying our requirements.

Through community participation, we aim to create a dynamic, secure, and longitudinal database along with a supporting ecosystem geared towards the compilation of behavioral insights. By making the Database available to third parties, we aim to facilitate insights which lead to greater predictive power of behavioral information for client applications. Third-party access to the Database is only granted with our members’ consent, as detailed in this Privacy Policy and otherwise as we may notify members from time-to-time.

Your acquisition of shares in SavvyShares constitutes a purchase of securities under the United States Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder. Your rights as a member are further explained in the SavvyShares Terms and Conditions, Purchaser Consent, Offering Circular, and the SavvyShares Operating Agreement.

Collection and Use of Member Data

In connection with your use of the Platform and your membership in SavvyShares, we collect the following categories of Personal Data and use them in the following ways:

  • Registration Information: We collect Personal Data such as your name, address, email address, and IP address during the registration process. This allows us to verify your eligibility, to determine which surveys are appropriate for you, and to contact you regarding participation in surveys. Subject to your settings, we may collect, use, and store additional information about your location, including your current precise position, to operate or personalize our services including with more relevant surveys and additional research opportunities. You can opt out of receiving survey notifications by unsubscribing your email address as provided in a given communication or by contacting us as provided in the “Contact Us” section below.
  • Survey Participation: For members who provide Member Data via surveys or other methods of participation, we may collect information such as, but not limited to, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or data concerning your sex life or sexual orientation. This data will vary from survey to survey, but in such cases you know what data we’re collecting because you provide it to us during the survey. You must explicitly consent to any specific terms and conditions associated with an individual survey, including any terms relating to Personal Data, prior to starting the survey. Member Data from surveys is included, in deidentified form, in the Database, and our clients and affiliates may access that deidentified information in connection with services provided by us or our affiliates.
  • Behavioral Data: Our App tracks web behaviors and browsing activities, including the types of entertainment you watch or advertisements you see or the searches you conduct. We use the information we collect through the App to identify online trends, and this data is included in deidentified form in the Database. Member Data will be passively collected as long as you keep the App installed and active on your device. The App will continually send us data in real-time as you use the device. The App will periodically send surveys that must be attempted in order to be deemed active for validation. If the App is installed, but you do not use your device, the App may still collect limited data, such as traffic from web pages in open browser windows or background traffic on a mobile device, such as background checks for updates when the device is sleeping. Member Data collected this way is included in the Database, and our clients and affiliates may access that deidentified information in connection with services provided by us or our affiliates. In addition to data collected by the App, SavvyShares may allow third parties, subject to agreements with SavvyShares, to independently track a member’s web behaviors and browsing activities (for example, through the use of a tracking cookie), but only with a member’s consent. The scope of such third-party data collection will not exceed the scope described in this Privacy Policy.
  • Live Participation: Members may also participate in in-person focus groups, one-on-one or other personal interviews or other in-person methodologies, such as “shopalongs” (where a professional accompanies a member to a store to observe behaviors) or ethnographic observation in the home where a professional observes behavior in usage of a product or habits in the home. Prior to participation, a telephone call with screening questions is administered to ensure qualification for the project. If the member qualifies, an invitation is sent followed by a reminder to participate. A member must explicitly consent to our data policies associated with each live participation opportunity.
  • Social Networks and Social Media: We may provide optional integrations into social networks to provide better services to SavvyShares members. This integration may require authentication and linking of certain Personal Data from these social networks. Please note however that we do not have control over those social networks’ use of your Personal Data, and strongly urge you to review their privacy policies.
  • Improvement of the Services: We will also use your Member Data as necessary to improve our operational services and your experience as a member.
  • Data Augmentation: In some cases, we may use secondary data sources to augment Member Data collected through our Platform.
  • As Required by Law: We may use or disclose Member Data, including Personal Data, as required by law or legal process, for example, in responding to a court-issued subpoena. Where allowed by law and where reasonably possible, we will notify you in advance of any such proposed use or disclosure of your Member Data.
  • Enforcement of Agreements: We may use your Member Data to enforce the SavvyShares Terms and Conditions, any member Subscription Agreement, or our Operating Agreement, including, in each case, investigations of potential violations.

Cookies

We use cookies and similar technologies to collect website usage data and to operate our services. Cookies are required for most parts of our services such as taking surveys, accessing your member portal and requesting payment. We use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage patterns, and to personalize and otherwise operate our services such as by providing account security, preventing fraud, and remembering your website preferences. Some of these cookies (analytics cookies, for example) may be placed on your device if you visit the SavvyShares website, even if you do not register as a member.

Sharing of Member Data

In connection with your use of the Platform and your membership in SavvyShares, we may also share your Member Data in the following ways:

  • Clients: We share deidentified Member Data about you in connection with our clients’ access to the Database, or as part of research results we deliver to our clients, to help our clients get insights into how better to deliver their goods and services. With your consent, we may also share certain Personal Data with such clients.
  • Affiliates: We may also share Member Data, including Personal Data, with our manager, SavvyShares PBC (“Manager”) or our affiliates, as necessary to operate the SavvyShares business.
  • Third Party Service Providers: We may also share Personal Data, subject to confidentiality agreements, with third-party service providers who help us make SavvyShares available to you and our services available to our clients. Such service providers include, for example, Amazon Web Services, Google Analytics, Melissa Data (for address verification), third-party data matching services, service providers who facilitate payment, and other third parties who help us deliver our services and manage our relationship with you.

Information Retention

We make efforts to ensure that Personal Data we receive, process, or maintain is accurate, complete, and reliable. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the Personal Data collected. In general, we keep Personal Data only as long as we need it to provide the services you requested. For example, we may keep your registration information indefinitely to allow you to sign in for as long as you remain a member. You can request deletion of information as provided in the “Deletion of Member Data” section below.

We may also process information on behalf of third parties who have engaged us. We keep Personal Data processed on behalf of third parties for as long as needed to provide services to the third party in question. However, we reserve the right to retain Personal Data for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Protection

We take the security and privacy of your Personal Data very seriously. We will use reasonable technical, physical, and administrative controls to protect member Personal Data from unauthorized access or disclosure and to ensure the appropriate use of this information, and no Personal Data will be associated with survey responses or provided to clients without a member’s prior consent. Please note we cannot guarantee the security of information on or transmitted via the Internet.

Third Party Websites and Services

The Platform or other communications in connection with SavvyShares may contain other links to external websites or other third-party services. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any Personal Data you provide in such areas, and on such linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third parties before providing them with Personal Data.

Children’s Privacy

SavvyShares is not designed for, intended to attract, or directed toward children under the age of 18, and we do not accept Personal Data from children under the age of 18. If we become aware a user of SavvyShares is under 18, we will use reasonable efforts to delete any information submitted by that child as soon as possible and to ensure such information is neither transferred to anyone else nor used by us. Please let us know as soon as you become aware a child under 18 has submitted information to us, as provided in the “Contact Us” section below.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will however treat any “do not sell” or similar signals as opt-out requests under CCPA.

Modification

We may update the Policy as it applies to our use of Member Data from time-to-time by notifying you of the proposed changes at least 30 days before their effectiveness to provide you with the opportunity to terminate your Purchaser Consent or remove some or all of your Member Data if you do not want your Member Data to be bound by the revised terms. If you do not take one of those actions after receiving notice of those proposed changes, to the maximum extent permitted by applicable law, you will be bound by the Policy when it becomes effective.

Deletion of Member Data

You may opt out of participation at any time by uninstalling the App from your device. This will not result in removal from the Database of any Member Data previously collected or a redemption of shares previously earned. If you wish to remove Member Data previously provided through the Platform, you must follow the redemption procedures as outlined in the Terms and Conditions and the SavvyShares Operating Agreement. Please note however that deletion of your Member Data may not extend to data we’ve already sent to clients, or to data we keep for backup/archiving and legal compliance purposes.

Your Rights

Under certain circumstances, you may have rights under applicable data protection laws in relation to your Personal Data, including the right to request access to your Personal Data, to request correction of the Personal Data that we hold about you, or to withdraw your consent to our processing of your Personal Data. If you wish to inquire further about any of the potential rights set out above, please contact us as provided in the “Contact Us” section below.

Notice to California Residents

If you are a California resident, you also have the following special rights under CCPA.

Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of Personal Data we have collected about you. You have the right to know the categories of sources from which the Personal Data has been collected, the business or commercial purpose for collecting or selling Personal Data, and the categories of third parties with whom we share Personal Data.

You also have the right to request deletion of Personal Data we’ve collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.

To exercise these rights contact us as provided in the “Contact Us” section below. We may ask you to provide additional information in order to verify who is making the request. Please note that any requests to know will only apply to the 12-month period preceding the request, and you are entitled to submit a request to know twice in any 12-month period.

Your Right to Opt Out of the “Sale” of Your Information

The term “sell” is broadly defined under CCPA. Its meaning includes “…renting, releasing, disclosing, disseminating, making available, [and] transferring… for monetary or other valuable consideration.” We may sell your Member Data to our affiliates or to our Manager. Also, in certain scenarios, information we share with our clients may be considered a “sale” under CCPA. You have the right to opt out of this “sale” of your Personal Data. For more information on how to opt out, please click here https://www.savvyshares.com/do-not-sell-my-personal-information .

Personal Information Sold and Disclosed

You also have the right to what categories of Personal Data we’ve sold or disclosed for a business purpose, and the third parties to whom that information was sold or disclosed. We’ve “sold” to our Manager, affiliates, and clients survey participation information, behavioral data, and live participation information, as described in the “Collection and Use of Member Data” section above. We’ve otherwise disclosed for a business purpose the following categories of information to the following parties: IP addresses to Google Analytics; mailing addresses to our address verification service providers; raw network traffic from devices to Amazon Web Services or similar web services providers; names, email addresses, postal addresses, and on rare occasions IP addresses to third-party data matching services; and names, addresses, and payment card information to payment service providers.

Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services.

Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in the “Contact Us” section below. In order to verify you have authorized an agent we will first verify your identify and then require notification of the agent you have authorized. This may take the form of email or written authorization from you.

Verification Process

If you make a request to access or delete your information, or to opt out of the sale of your Personal Data, we may ask you for additional information to verify your identity. This information may include your full name, phone number, email address, or other basic Personal Data about you that we already have on file.

Financial Incentive Notice

In addition to providing you with the opportunity to share your opinions, we also provide you with financial incentives in the form of shares in SavvyShares LLC as consideration for your participation in surveys and other data collection activities. By accepting the incentive, along with the value associated with the sharing of your opinions, you agree that this consideration represents fair value for your participation.

Contact Us

If you have any questions or concerns about your Member Data, Personal Data or the contents of this Policy, contact us as follows:

SavvyShares

1365 Fourth Avenue

San Diego, CA 92101

privacy@savvyshares.com

Phone: 1-800-492-4982