Galileo Privacy Policy

Last modified March 2024

ATTENTION: PLEASE READ THIS GALILEO FINANCIAL TECHNOLOGIES, LLC (“GALILEO”) PRIVACY POLICY (“PRIVACY POLICY”) CAREFULLY. THIS PRIVACY POLICY PERTAINS TO YOUR ACCESSING, DOWNLOADING, OR USING THE HTTPS://WWW.GALILEO-FT.COM/ WEBSITE (THE “WEBSITE”), AND YOUR ACCESSING ANY ASSOCIATED CONTENT, INCLUDING THE GALILEO SANDBOX, AND ANY INFORMATION COLLECTED IN PERSON BY GALILEO PERSONNEL (TOGETHER THE “SERVICE”).

You may have specific rights under state and international privacy and data protection laws. Please review the sections below.

Colombia Privacy Rights
State Privacy Rights

The Service is operated by Galileo, 9800 South Monroe Street, 7th Floor, Sandy, Utah 84070 (“We”). This Privacy Policy describes the information collected through your (“Your”) use of the Service, how We use it, how We share it, how We protect it, and the choices You can make about Your information.

ATTENTION: PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICE. ACCESSING OR USING THE SERVICE INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE SERVICE. You acknowledge (a) that You have read and understood this Privacy Policy; and (b) that this Privacy Policy shall have the same force and effect as a signed agreement.

Unless explicitly stated otherwise, any new features that augment or enhance the current Service shall be subject to this Privacy Policy.

Please review the Privacy Policy each time You use the Service. BY USING THE SERVICE, YOU AGREE TO BE BOUND BY THE MOST RECENT VERSION OF THE PRIVACY POLICY.

I. Information We Collect

We collect information from You when You use the Service, contact or interact with us, and voluntarily provide us with Your information in connection with using the Service. We may collect both business and personal information. When We say “business information” We mean information related to your current or potential business, some of which is collected due to regulatory requirements and applicable law. When we say “personal information,” we mean information that specifically identifies You. We collect business and personal information in a number of ways. You are asked to provide personal information to us when You log in to our sandbox, when You request access to our newsletter, and when You request information about job openings. Examples of personal information include:

• Your Name
• Your Address
• Email Address
• Telephone Number
• Password
• Job Title
• IP Address
• Your Resume

Examples of business information include:

• Company Name
• Company Information
• Product Information
• Company Bank Information

Website Use & Logging Data

We automatically collect information regarding each user of our Service, including Your IP address, the domain name of Your Internet service provider, the Service features You use and the time of Your use, Your device information (e.g., device model and operating system version), and aggregated information that cannot be used to specifically identify You when You use the Service. Additional information collected is described in the Analytics and Cookies sections below.

Information We Get from Others

Like other companies, We contract with third-party service providers to place advertisements for our products and services on websites that are not our own. We place these ads where We think they are likely to be most relevant for prospective and current customers. These advertisements on third-party websites allow us to track responses to our ads. We use this information to track the performance of our advertising and marketing campaigns by using tools like cookies, web beacons, and similar technologies. We use these tools to collect and store information about Your visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site.

We may combine all of the information We collect from You and use it in the manner described in this Privacy Policy.

II. How We Use Information

We use the information that We collect for several purposes, including:

• The purposes for which it was provided;
• To provide information and respond to requests for products and services;
• To process and respond to customer inquiries and comments;
• To provide access to and facilitate Your use of the sandbox;
• To collect and process applications for employment;
• To create or add to Your registered account;
• To display relevant advertising;
• To administer, operate, and improve the Service;
• To personalize and enhance Your experience using the Service;
• To send periodic emails. If email recipients choose, the email address they provide may be used to send them occasional news, updates, related product or service information, etc. Note: If at any time email recipients would like to unsubscribe from receiving future commercial emails, We include unsubscribe instructions at the bottom of each email;
• To generate and review reports and data about our user base and Service usage patterns;
• To analyze the accuracy, effectiveness, usability, or popularity of the Service;
• To compile aggregate data for internal and external business purposes;
• To prevent fraud and abuse of the Service and to otherwise protect You and our business;
• To assist law enforcement and respond to subpoenas; and
• To perform other business activities as needed, or as described elsewhere in this Privacy Policy.
• As explained elsewhere in this Privacy Policy, personal information We collect may be processed by our partners in providing services related to the Service (such as administration services, technical services relating to the maintenance, servicing, and upgrading of software, hosting services, customer service, data migration services, and analytical services, among others).

III.How Information is Disclosed

Information may be disclosed to third parties in accordance with our Privacy Policy.

A. Third-Party Service Providers and Business Partners. We may use third-party service providers and business partners to perform functions in connection with the Service, such as social sharing, marketing, site analytics, relationship management, functions related to analyzing and improving the Service usefulness, reliability, user experience, operation, storing data, and as otherwise described in this Privacy Policy. Third parties We disclose information with may include, but are not limited to:

• Advertising & Marketing Partners
• Instant Messaging Providers
• Social Media Platforms
• Job Application Aggregation Services
• Financial Institution Partners
• Law Enforcement, Regulators, and Government Agencies

If You are interested in pursuing career opportunities, You can review and apply for job openings listed in an online job board. If You elect to proceed, You may be seamlessly linked to a website maintained by a third party. We encourage You to read the third party’s privacy policy before providing any personal information. Click here for additional information on our treatment of job applicant information.

When You submit an application for employment, the third party may collect Your contact information, application information, resume information, IP address, geolocation information, browser type, operating system type, device type, session data, and information related to the pages You visit.

The personal information that You submit to the third party while online may be accessed and downloaded by Galileo professionals and used for evaluating Your qualifications for the job for which You have applied and other jobs that may suit Your experience and qualifications.

B. Business Changes. If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third party or parties in connection therewith.

C. Affiliates. We may also share Your information with our family of companies for purposes consistent with this Privacy Policy.

D. Analytics. We use third-party analytics tools and services to better understand who is using the Service and how people are using it. These tools and services may use cookies and other technologies to collect information about Your use of the Service and Your preferences and activities. These tools collect information sent by Your device or the Service and other information that assists us in improving the Service and monitoring activity for fraud prevention. This information may be used to analyze and track data, determine the popularity of certain content, and better understand Your online activity, among other things.

We may deliver advertisements to You, including through the use of third party advertising companies. We may also work with third-party advertising companies that help deliver these advertisements to You. To learn more about third-party online advertising and to opt out of certain types of advertising, please see: http://optout.networkadvertising.org/?c=1.

F. Cookies and Other Tracking Technologies

We, along with third parties, use cookies, local storage objects, Web beacons, and other technologies. These technologies are used for tracking, analytics, and personalization and optimization of the Service.

Cookies are small files that are transferred to and stored on Your computer through Your Web browser (if You allow it) that enable the website’s or service provider’s system to recognize Your browser and capture and remember certain information. You can instruct Your browser to stop accepting cookies. But, if You do not accept cookies, You may not be able to use all portions of all functionality of the Service.

• Persistent cookies remain on the visitor’s computer after the browser has been closed.
• Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when he/she closes the browser software.

Flash cookies (also known as local shared objects) are data files that can be created on Your computer by the websites You visit, and are a way for websites to store information for later use. Flash cookies are stored in different parts of Your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit: http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. You can disable the ability of web beacons to capture information by blocking cookies.

We use cookies and other tracking technologies on the Service to help us understand and save Your preferences and interests, so We can personalize Your future visits and compile aggregate data about Service traffic and Service interaction to offer better Service experiences and tools in the future.

Some of our business partners, such as our analytics providers and advertising networks, also use cookies and other tracking technologies on our Service, some of which may track users across websites and over time.

IV. Security

We take the privacy and security of your personal and business information seriously. We maintain administrative, technical, and physical safeguards designed to protect your information’s security, confidentiality, and integrity. We implement a variety of security measures to protect the safety of Your personal information when You enter, submit, or access Your personal information in connection with Your registration to use the Service. To the extent you have a user ID and password to access the Services, this password is encrypted while transmitted from your browser to our servers and while stored on our systems. To protect the security of your personal and business information, never share your password with anyone and please notify us immediately if You believe Your password has been compromised by emailing privacy@galileo-ft.com.

While We take reasonable measures to protect the information You submit via the Service against loss, theft, and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Service may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding with which information You provide us.

We cannot guarantee that transmissions of Your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

We urge Your caution when using public computers or networks, like at a coffee shop or library. To best protect Your information, including username and password, do not use such computers to access Your Pro or Instant accounts, and if You must, ensure that You logout of Your account entirely.
Any information collected through the Service is stored and processed in the United States in facilities and servers that only selected Galileo personnel and our contractors have access to. If you use our Service outside of the United States, You consent to having Your data transferred to the United States.

V. Links to Other Services or Applications

This Privacy Policy applies only to the Service. The Service may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Policy does not apply. The links from the Service do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, We seek to protect the integrity of our Service and welcome any feedback about these linked websites and mobile applications.

VI. Your Choices Regarding Your Information

You have choices regarding the use of information by the Service.

• Changing Your Information – To change Your information, You may log in to Your account, or You may email us at info@galileo-ft.com.
• Closing Your Account – You may close Your account by contacting us at info@galileo-ft.com.. If the email account associated with Your email address is not active, We may close Your account without notice.

VII. Children

Our Service is not intended for children under 18 years of age. We do not knowingly collect personal information from an individual under age 18. If You are under the age of 18, please do not submit any personal information through the Service. If You have reason to believe that We may have accidentally received personal information from an individual under age 18, please contact us immediately at privacy@galileo-ft.com.

VIII. Changes to Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before You provide any information. This Privacy Policy was made effective on the date indicated above.

IX. How to Contact Us

Please feel free to contact us by email at privacy@galileo-ft.com,or by writing us at 9800 South Monroe Street, 7th Floor, Sandy, Utah 84070, if You have any questions about this Privacy Policy.

X. Your Colombia Privacy Rights

Under Law 1581 of 2012 and its Regulatory Decrees, You have the right to know, update, and rectify Your personal data; request proof of the authorization granted; revoke Your authorization and/or request that Your data be deleted when there is no legal or contractual obligation that prevents it, and access free of charge the data that is subject to processing. You may also file a complaint before the corresponding authority when applicable.

To exercise Your rights, you may contact the area in charge at the following e-mail address:privacy_colombia@galileo-ft.com, and telephone: 801-736-1083.

In the event that we are acting as data Processors in the provision of third-party data processing services pursuant to our service agreement with the data controller. In such event, please refer to your agreement with the applicable data controller regarding additional terms and information on how personal data will be processed.

XI. State Privacy Rights

Your Rights

Depending on your jurisdiction of residence, you (or an authorized agent acting on your behalf) may be able to make certain requests or have rights related to your personal information in accordance with applicable laws, as follows:

• know what personal information We have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you;
• request the deletion of certain personal information collected by Us;
• correct Inaccurate personal information;
• know/access or receive a disclosure of your personal information;
• know what personal information is sold or shared and to whom;
• opt-out of the sale or sharing of your personal information;
• in certain cases, limit the use and disclosure of sensitive personal information; and
• no retaliation for opting out or exercising any other rights, including an employee’s right not to be retaliated against for the exercise of their rights;
• appeal our denial of any request above. We will respond to your appeal within the timeframe required by law, and provide a written explanation in support of our response and provide additional information as required by law.

Your Nevada Privacy Rights

Senate Bill No. 220 (May 29, 2019) amends Chapter 603A of the Nevada Revised Statutes to permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by emailing us at privacy@galileo-ft.com.We will provide further information about how We verify the authenticity of the request and Your identity.

Exercising Your Rights

To exercise one of these rights, please provide a verifiable consumer request by calling us toll-free at 1-833-826-7792, or emailing us at privacy@galileo-ft.com. You will not need to create an account to exercise Your rights, but if You do not have an account We may require additional information to verify the authenticity of Your request.

Before We can fulfill the consumer requests noted above, We must verify Your identity. If You have a password-protected account with us, We can verify Your identity through our existing authentication procedures for Your account. However, We will require You to re-authenticate Yourself before We can disclose or delete any of Your information.

If You do not have a password-protected account with us, You may provide us with Your name, telephone number, email address, company name, Galileo account type, home address, and corporate address, together with a signed declaration under penalty of perjury that You are the consumer whose personal information is the subject of the request. We will match this information to the personal information We maintain.

You can also authorize another person, called an agent, to exercise Your rights on Your behalf. You must provide the authorized agent written and signed permission to act on Your behalf. We may deny requests from an authorized agent who does not submit proof that he or she has been authorized to act on Your behalf. Furthermore, We may require You to verify Your identity directly with us. We may also require You to directly confirm with us that You have provided the authorized agent permission to submit a request on Your behalf. An authorized agent can make a request on Your behalf by either calling us at 1-833-826-7792, or by emailing us at privacy@galileo-ft.com.

Additionally, to exercise your rights to opt-out of the sale or sharing of your personal information, you may select the “Do Not Sell or Share my Personal Information” toggle available on our Privacy Choices pages You may also set your browser to “Do Not Track” or “Send a Do Not Track Request.” Galileo processes browser opt out/do not track signals in a frictionless manner. If your browser is set to “Do Not Track” or “Send a Do Not Track Request” We will interpret this as a valid request to not sell or share the personal information for that browser or device.

We may not discriminate against You because You exercised any of Your rights under the CCPA, including, but not limited to, by:

• (A) Denying goods or services to You.
• (B) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• (C) Providing a different level or quality of goods or services to You.
• (D) Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Categories of Information We Collect, Sell or Share, Disclose For A Business Purpose

Category of Personal Information	Collected	Sold or Shared for Cross-Content Advertising	Disclosed for a Business Purpose
Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.	Yes	Yes	Yes
Categories of personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute, Cal. Civ. Code 1798.80(e)), such as name, address, telephone number, and credit card number, debit card number, or any other financial information	Yes	Yes	Yes
Characteristics of protected classifications under California or federal law such as birth date	Yes	Yes	Yes
Commercial information, including records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies such as activity in the sandbox	Yes	Yes	Yes
Internet or other electronic network activity information, including browsing history, search history, information regarding Your interaction with an Internet website, application, or advertisement	Yes	Yes	Yes
Geolocation Data	Yes	Yes	Yes
Professional or employment-related information	Yes	Yes	Yes
Inferences drawn from Your personal information to create a profile reflecting Your preferences, characteristics, predispositions, behavior, etc.	No	No	No
Audio, electronic, visual, thermal, olfactory, or similar information	No	No	No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. 1232(g), 34 C.F.R. Part 99) (for job applicants only)	No	No	No

We do not collect, sell, share, or disclose sensitive personal information.

Sources of Personal Information

We may obtain the personal information listed above from the following categories of sources:

• Directly from You or your authorized agents. For example, from forms you complete or from communications you have with Galileo.
• Indirectly from You. For example, from your actions on our website (www.galileo-ft.com).
• Third-Parties. For example, from marketing and advertising service providers (such as joint marketing partners and event co-sponsors), data providers (such as information services and data licensors that provide demographic information, mailing addresses, and other information), and public sources (such as government agencies, public records, social media platforms, and other publicly available sources).

The Business Purposes For Which We Collect,Disclose, and/or Share Your Personal Information

We may collect, disclose, and/or share personal information for the following business purposes:

• performing the Services for business consumers, such as processing or fulfilling orders and transactions, creating, maintaining, and servicing accounts, verifying business customer information, undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Galileo, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Galileo, providing advertising or marketing services, and providing analytics services;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• debugging to identify and repair errors that impair existing intended functionality;
• research and development purposes, including to analyze and improve the Services and our business, and for business promotion purposes.
• marketing and advertising purposes, including direct marketing and interest-based advertising:
  • direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
  • interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction with the Services, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. To opt out of this advertising, select the “Do Not Sell or Share my Personal Information” toggle available on our Privacy Choices pages or review the Global Privacy Control section on this page to learn more about options.
• collecting and processing applications for employment; and
• as required to comply with applicable laws and regulations, including responding to law enforcement requests

Global Privacy Control

Galileo recognizes the Global Privacy Control (GPC), which is a setting that allows you to communicate your privacy preferences to websites and online services that you visit. When we detect a GPC signal from a browser, we interpret this as a valid request to not sell or share the personal information for that browser or device in compliance with applicable laws. Please visit the Global Privacy Control website to learn more about the setting and how to enable it on your browser.

The Categories of Third Parties With Whom We Share Your Personal Information

Below is a list of third parties to whom we may disclose your personal information:

• Affiliates
• Services Providers and vendors who provide services such as data analytics, marketing and advertising, customer relationship management, employment recruiting, and card fulfillment
• Issuing Banks

Data Retention

We use the following factors to determine the retention period of personal information:

• to maintain an ongoing relationship with you as a customer or business contact;
• to perform under applicable terms and services to which You agreed;
• as necessary in connection with the lawful purposes set out in this CCPA Supplement;
• to comply with applicable laws; and
• to establish, exercise or defend our legal rights.

Shine the Light Notice

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes, and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at privacy@galileo-ft.com, or by writing us at 9800 South Monroe Street, 7th Floor, Sandy, Utah 84070.