Effective as of March 8, 2019
1. INFORMATION WE COLLECT OR RECEIVE
In the course of operating Benjamin, we will collect and/or receive the following types of information. You
authorize us to collect and/or receive such information.
a. Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. We do not collect any Personal Information from you when you use Benjamin unless you provide us with the Personal Information voluntarily.
c. Geolocational Information. Certain features and functionalities of Benjamin are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when Benjamin is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.
e. Other Information. In addition to the Personal Information and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of Benjamin; your interactions with us; and information regarding your computer and mobile devices used to access Benjamin (collectively, the “Other Information”). Such Other Information may include:
i. From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.
ii. From Your Activity. We may collect or receive information regarding:
A.IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;
B.browser type and language;
C.referring and exit pages and URLs;
D.date and time; and
E.details regarding your activity on Benjamin, such as search queries and other performance and usage data.
iii.About Your Mobile Device. We may collect or receive information regarding: A.type of mobile device;
B.advertising Identifier (“IDFA” or “AdID”);
C.operating system and version (e.g., iOS, Android or Windows);
E.network type (WiFi, 3G, 4G, LTE).
A.type of mobile device;
B.personalize your experience;
C.analyze which portions of Benjamin are visited and used most frequently; and D.measure and optimize advertising and promotional effectiveness.
If you do not want us to deploy cookies in Benjamin, you can opt out by setting your mobile device to reject cookies. You can still use Benjamin if you choose to disable cookies, although your ability to use some of the features may be affected.
2. THIRD-PARTY ADVERTISING
Our current Policy is not to share your Personal Information, Geolocational Information or Other Information with
third parties for any third party interest-based ad distribution. 3. HOW INFORMATION IS USED AND SHARED
a.You authorize us to use the Personal Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:
i.provide and improve Benjamin; ii.provide our services;
iii.administer our promotional programs; iv.solicit your feedback; and
v.inform you about our products and services.
b.We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional
programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law
c.In an ongoing effort to better understand our users, Benjamin, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve Benjamin and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe Benjamin and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
d.We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us (“our Affiliates”); provided however, that any of your Information shared with our Affiliates may be shared only for the sole purposes of improving your experience in using Benjamin in connection with the permissions set forth in this Section 3. We nor our Affiliates will use any of your Information to solicit your customers or clients.
e.As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
f.To the extent permitted by law, we may also disclose the Information:
i.when required by law, court order, or other government or law enforcement authority or regulatory agency; or
ii.whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
4. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES
If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to Benjamin (e.g., requests for support).
We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.
5. HOW WE PROTECT YOUR INFORMATION
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail and in selecting your passwords.
California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please contact us at www.getwela.com with “California Privacy Rights” in the subject line.
6. IMPORTANT NOTICES TO NON-U.S. RESIDENTS
Benjamin and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use Benjamin, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.
Benjamin is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use Benjamin. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.
9. HOW TO CONTACT US