GALILEO FINANCIAL TECHNOLOGIES WEBSITE PRIVACY POLICY

Last modified November 1, 2020

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 INSTANT SANDBOX, THE PRO SANDBOX, AND INCLUDING ALL CONTENT AVAILABLE THROUGH THE WEBSITE, THE INSTANT SANDBOX, THE PRO SANDBOX, AND ANY INFORMATION COLLECTED IN PERSON BY GALILEO PERSONNEL (TOGETHER THE “SERVICE”).

IF YOU HAVE RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT, PLEASE SEE THE CCPA SUPPLEMENT. IF YOU HAVE RIGHTS AS A RESIDENT OF NEVADA, PLEASE SEE THE YOUR NEVADA PRIVACY RIGHTS SECTION BELOW.

The Service is operated by Galileo, 6510 South Millrock Drive, Suite 300, Salt Lake City, UT 84121 (“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; (b) that this Privacy Policy shall have the same force and effect as a signed agreement; and (c) that by agreeing to this Privacy Policy, You consent to receive notifications regarding security incidents to the email address We have on file for You.

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 Instant and Pro sandboxes, 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.

Aggregate Information

Aggregate information, which is data We collect about Your use of our or third-party websites or services, from which personal information has been removed. Aggregate data is used to help us understand business trends, needs, interests, and preferences so We can improve our Service.

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 and our affiliates 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 Instant Sandbox and Pro 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. We do not sell or rent Your personal or business information for compensation to anyone. We only share your personal or business information with unaffiliated third-parties as permitted or required by law or if required to provide the Service to You. We may share your personal or business information with our affiliate companies. Please note that a user may choose not to share certain information as described in the Analytics section below.

    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 share 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.

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 located in the U.S., 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 affiliates for purposes consistent with this Privacy Policy.

    D. Aggregated Information. We may share aggregated information relating to users of the Service with affiliated or unaffiliated third parties. This aggregated information does not contain personal information about any user.

    E. 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 [email protected].

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. Data Retention Policy, Managing Your Information

We will retain Your information for as long as You use the Service and for a reasonable time thereafter. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Service to function properly.

VI. 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.

VII. 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 [email protected].

Closing Your Account – You may close Your account by contacting us at [email protected]. If the email account associated with Your email address is not active, We may close Your account without notice.

VIII. 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 [email protected].

IX. 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.

X. How to Contact Us

Please feel free to contact us by email at [email protected], or by writing us at 6510 South Millrock Drive, Suite 300, Salt Lake City, UT 84121, if You have any questions about this Privacy Policy.

XI. 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 [email protected].  We will provide further information about how We verify the authenticity of the request and Your identity.