Brwly Banks Privacy Policy

Our Commitment to You

Traversal Studios LLC and its affiliated companies, conducting this business as ‘Brwly Banks’ (together: “Brwly Banks”, “us” or “we”) are dedicated to providing users with the highest level of transparency and control over the use of their information. In order for us to provide you with our Services (as defined below) or engage with you as a contributor, we are required to collect and process certain personal information about you and your activity.

By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information.

When you are using our Brwly Banks Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Privacy Policy.

We urge you to read this Privacy Policy carefully and make sure that you fully understand and agree to it.

If you do not agree to this Privacy Policy, please discontinue and avoid using our Services (as much as we like you to stick around).

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Grounds for Data Collection

You are not legally required to provide us with your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means), but without it we might not be able to provide you with the full range of, or the best experience while using our website(s), mobile application(s) or any other affiliated service (together, the “Services”).

Processing of Personal Data is necessary for the performance of our contractual obligations towards you, for provision and operation of our Services, to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.

Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:

1. Performance of a contract – We will use this basis for processing necessary to make the Services, including support services, available to you, and to send you service communications.
2. Consent – In limited cases (where you choose to sign up to receive direct marketing emails, or where you accept cookies on our Services) we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details provided below.
3. Legitimate interests – We will process your Personal Data based on our legitimate interests in maintaining and improving our Services, such as for the purpose of understanding how our Services are used and improving them, our customer service and support operations, and protecting and securing our users, ourselves and our Services.
4. Compliance with a legal obligation – In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.

What type of data we collect?

1. Personal Data
   In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Policy.
   
   We collect the following Personal Data about you:
   • Registration information: when you sign up to use our Services, we will collect your name, your mailing address, your email address, your home and work telephone number, and similar contact details.
     
     We will also process your payment details via our payment processing providers.
     
   • Information received from you: you may choose to provide us Personal Data voluntarily, such as when you contact us (via a contact form on our Services, e-mail or any other channel, including any support services), or when you provide us with your e-mail address or when you sign-up to receive our newsletter.
     
   • When using our Services & Information from third parties: our Services may allow registration using social media accounts such as Facebook or Google.
     
     If you choose to connect your Brwly Banks account with your social media account, we will receive information from your social media account such as your profile name, profile picture and additional information depending on such social media platforms and your privacy settings on it.
     
     We may also receive from our business partners certain information, such as your contact details (name, phone, email) as well as details pertaining to your company, your job description, etc’.
     

1. Non-Personal Data
   We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it.
   
   We may collect the following non-Personal Data:
   • Technical information: when someone visits, interacts with or uses our Services, including by e-mail or text messages sent to them by us or our Services, we may collect or generate technical data about them.
     
     This includes data such as visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, referral URL, time zone, network connection type (e.g., Wi-Fi, cellular), and cookie information.
     
     We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies.
     
     We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services.
     

If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

Tracking Technologies

When you visit or access our Services we use (and authorize 3rd parties to use) cookies, events and other technologies (collectively, “Tracking Technologies”).

Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience.

We store Tracking Technologies when you visit or access our Services. These are called “First Party Tracking Technologies”.

In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) – these are called “Third Party Tracking Technologies”.

Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

We use a tool called “Google Analytics” to collect information about use of our Services.

Google Analytics collects information such as how often Users visit our site, what pages they visit when they do so, and what other sites they used prior to coming to this site.

We use the information we get from Google Analytics only to improve our Services.

We also use a “Third Party Tracking Technology” called CookieYes, which collects only the IP address assigned to you on the date you visit our site, and plants a cookie on your web browser to identify you as a unique user the next time you visit.

The cookies cannot be used by anyone but CookieYes and we do not combine the information collected through the use of Google Analytics with personally identifiable information.

For more information visit Google Analytics Privacy Policy as well as the CookieYes Privacy Policy.

You can prevent Google Analytics & CookieYes from recognizing you on return visits to this site by disabling cookies on your browser as described below.

How Do We Use the Data We Collect?

• Provision of service: we will use your Personal Data for the provision and improvement of our Services, including for support and to respond to your queries.
  
• Service announcements: we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
  
• Marketing purposes: we may use your Personal Data (such as your email address or phone number) for marketing purposes. For example, by subscribing to our newsletter you will receive tips and announcements straight to your email account.
  
  We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, by building an automated profile based on your Personal Data, for marketing purposes.
  • Opt-out of receiving marketing materials: You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us.
    

Please note, even if you unsubscribe from our promotional or marketing emails, we may send you service-related updates and notifications, or reply to your queries and feedback you provide us.

Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes.

• Analytics, surveys and research: from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Service and think of new and exciting features for our users.
  
• Protecting our interests: we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Traversal Studios LLC., its users and/or partners.
  
• Enforcing of policies: we may use your Personal Data in order to enforce our policies, including but not limited to our client agreement.
  
• Compliance with legal and regulatory requirements: we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
  

With Whom Do We Share Your Personal Data?

• Internal concerned parties: we share your information with companies in our group, as well as our employees, in order to provide you with our services.
  
• Business partners: we share your information with business partners, such as storage and analytics providers who help us provide you with our Services.
  
  These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.
  
• Compliance with laws and law enforcement entities: we cooperate with government and law enforcement officials and private parties to enforce and comply with the law.
  
  We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
  
  We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
  
• Merger and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your Personal Data in accordance with the terms of this Privacy Policy.
  
  • Opt-out of receiving marketing materials: You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us.
    

How we protect your information

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data.

Your data is stored on secure servers and isn’t publicly available.

We limit access to your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security.

You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.

You should also be aware that there is always some risk involved in transmitting information over the internet.

While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.

Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

Submitting a request

Under applicable law, when you submit a request regarding any of the aforementioned rights, please note that your request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
  

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Our Children Policy

We understand the importance of protecting children’s privacy, especially in an online environment.

The Site and Services are not designed for or directed at minors under the age of 16 years old (“Minors”).

We do not knowingly collect any Personal Data from Minors.

If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.

Additional Information for California Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ.§1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA”).

Collecting, Sharing, and Selling Personal Information

In the preceding twelve (12) months, we have disclosed personal information (as mentioned above).

We do not “sell” personal information about our users as most people would typically understand this term.

However, we do allow certain third-party partners to collect pseudonymized information about consumers through our Services for purposes of serving ads and related marketing materials that are relevant (including related activities such as campaign measurement and analytics, fraud detection and reporting).

In this context, we “sell” resettable advertising identifiers and IP addresses with our advertising partners.

These allow developers and marketers to track activity for advertising purposes and are used to enhance the personalization of ads.

You may opt out from the “sale” of your personal information by deleting or rejecting our cookies or unsubscribing.

You may also contact us, by using the contact details provided below.

How to Contact Us?

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us.

Brwly Banks a Traversal Studios LLC. Platform –
2167 Shaw Ave.
Clovis, CA 93611

Policy Updates

Updates to This Policy

This Privacy Policy is subject to changes from time to time, in our sole discretion.

The most current version will always be posted on our website.

You are advised to check for updates regularly.
In the event of material changes, we will provide you with a notice.

By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.

Updated December 2023