January 7, 2022
OUR COMMITMENT TO PRIVACY
Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal
information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
THE INFORMATION WE COLLECT
When you visit the website or use one of our mobile applications or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service.
If you open a getGFTD account, we collect the following information from you:
● Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID, and other similar information.
● Identification Information - your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
● Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language preference, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
● Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to share your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available on your device.
● Social Web Information - including but not limited to your Instagram and Facebook Connect credentials and email account information. If you authorize Instagram and Facebook Connect, the plug-in allows us access to your email address, Facebook friends list, and public profile (including profile picture). We also allow you to import data from other social web services, including but not limited to Twitter, FourSquare, and email service providers. Social and e-mail contact information help you connect to friends and contacts for invitation and
payment transmission purposes (as well as helping us improve the Services and fight fraud). Additionally, another getGFTD user may mention you in a transaction to which you are not a party by “tagging” your username in a transaction note or comment. When you are mentioned in a transaction note or comment into which you have visibility (e.g., a public transaction, a “friends only” transaction by one of your contact friends, or a comment on either such transaction), a link to your getGFTD profile will appear in the transaction note or comment and, if your push notifications are turned on, you will receive a push notification about the mentions. You may manage certain contact preferences and notifications in your account settings.
● Financial Information - bank account online login information, bank account, and routing numbers, and debit & credit cards linked to your account. Our company does not share financial information with third-party social networking services such as those listed in the prior bullet.
We are committed to providing a safe, secure, and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address, or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention, and similar services.
When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or other access devices for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.
Electronic Fund Transfers (EFTs) and Account Balances. getGFTD, LLC partners with financial services software company Sila Inc. (Sila) and banking services provider Evolve Bank & Trust (Evolve), member FDIC, to offer you electronic fund transfers (EFTs). When you create a getGFTD account, link a bank account, or initiate an EFT, you are authorizing us to share your identity and banking information with Sila and Evolve to support your account. You are also agreeing to the terms
INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
INFORMATION PERTAINING TO CHILDREN
A feature that a user may activate is the family feature. This feature allows a parent to create a WishList for his or her child and permit access to those contacts granted permission. A parent must actively grant access to a child’s WishList, and the child’s WishList may not be accessed merely by viewing a parent or adult’s WishList. Your privacy is important to us. A parent or adult may update, add to, or subtract from a child’s WIshList, but a non-authorized adult may not.
Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.
HOW WE PROTECT & STORE PERSONAL INFORMATION
We store and process your personal information using third-party servers located in data centers in the United States. This information is protected by physical, electronic, and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your getGFTD password with anyone.
If the getGFTD tech team learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that getGFTD may communicate with you electronically. GetGFTD may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice
of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun, and customized experience. We may use your personal information to:
● provide the services and customer support you request;
● process transactions and send notices about your transactions or your network activity; ● resolve disputes, collect fees, and troubleshoot problems;
● prevent potentially fraudulent, prohibited, or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information, and Geolocation Information;
● create an account connection between your getGFTD account and a third-party account or platform;
● customize, personalize, measure, and improve our services and the content and layout of our website;
● send you updates about new products and services that we are offering to customers; ● compare information for accuracy and verify it with third parties;
● perform other duties as required by law; and
● if you elect to share your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.
California Privacy Rights. If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:
● Exercising the Right to Know. You may request, up to twice in a 12-month period, the following about the personal information collected on you in the past 12 months:
o the categories and specific pieces of personal information we have collected; o the categories of sources from which we collected the personal information; o the business or commercial purpose for which we collected it;
o the categories of third parties with whom we shared the personal information; and
o the categories of personal information about you that we disclosed for a business purpose.
● Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
● Exercising the right to opt-out from a sale. You may request to opt-out of any “sale” of your personal information that may take place.
● Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
To submit a request to exercise any of the rights described above, you may contact getGFTD, LLC either via email at email@example.com or contact us via postal mail, proper postage prepaid, at:
Attn: Your California Privacy Rights
7101 Rich Hill Rd. Baltimore, MD 21212
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly or do not have complete information.
HOW WE SHARE PERSONAL INFORMATION WITHIN THE getGFTD NETWORK
To process payments on getGFTD, we may need to share some of your personal information. Your contact information, date of sign-up, the number of payments you have received, and other verification metrics like social graph activity may be provided to users or companies you transact with.
We work with vendors to enable them to accept payments from you using the digital-wallet account. In doing so, a vendor may share information about you with us, such as your mobile phone number, when you attempt to pay that vendor. We use this information to confirm with that vendor that you are a digital-wallet customer and that the vendor should accept this form of payment for your purchase.
Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.
HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
getGFTD does not share your personal information with third parties for any promotional or marketing purposes.
Some personal information is public information, such as the public transactions in which you've been involved, and may be seen by anyone on the internet, whether or not they have a getGFTD account. Public information may also be seen, accessed, reshared, or downloaded through getGFTD’s APIs or third-party services that integrate with our products. In addition to any public information, your getGFTD friends’ lists accessed through their contacts may be seen by any logged-in getGFTD user.
We may share your personal information with:
● Law enforcement, government officials, or other third parties if compelled to do so by a subpoena, court order, or similar legal procedure, when it is necessary to do so to comply with the law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the User Agreement, or as otherwise required by law.
● Third-party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendor’s behalf.
● The other user participating in the transaction and, depending on the privacy setting of each account transaction, or the public, through the been GFTD feed on our website and mobile application and elsewhere on the internet.
● Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
● Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
non-getGFTD account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, getGFTD and the third party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your beenGFTD account to a social media account or social messaging service; connecting your getGFTD and beenGFTD account to a third-party data aggregation or financial services company, if you provide such company with your getGFTD account log-in credentials; or using your account.
○ Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection. For example, personal information that getGFTD shares with a third-party account or platform such as a social media account may, in turn, be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
○ If you choose to use Siri or iMessage to send payments via getGFTD or to otherwise use the Services, such use is subject to Apple’s terms and conditions for use of iMessage and/or Siri, as applicable, and the terms of the getGFTD or beenGFTD User
Agreement. By using Siri or iMessage, you authorize us to share some of your getGFTD account data (including your friends' list, list of persons you have transacted with most recently and most frequently, transaction instructions, and transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data shared with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to getGFTD on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You can review and update your personal information in your account settings at any time by logging in to your account.
LINKS TO OTHER SERVICES OR SITES
The Services may contain links to (or allow you to link to) other third-party services or websites. GetGFTD, LLC does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information.
HOW TO CONTACT US