What information we collect about you
We, GRLM, LLC dba Financial Investment News “FIN”, collect information about you when you provide it to us, when you use our services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into the services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the services. For example, you provide your contact information and, in some cases, billing information when you register for the services. You also have the option of adding other details to your profile information to be displayed in our services. We keep track of your preferences when you select settings within the services.
Content you provide through our websites: The services also include our websites owned or operated by us. We collect other content that you submit to these websites. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels: The services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a service. Whether you designate yourself as a technical contact, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you register for certain paid services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
Information we collect automatically when you use the Services
We collect information about you when you use our services, including browsing our websites and taking certain actions within the services.
Your use of the services: We keep track of certain information about you when you visit and interact with any of our services. This information includes the features you use; the articles and other features of our sites you click on; and frequently used search terms.
Device and Connection Information: We collect information about the devices you use to access the services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages and pages viewed. How much of this information we collect depends on the type and settings of the device you use to access the services. We use this information because we have a legitimate business interest in understanding how our website is accessed, how it is used and any problems users have with it.
Information we receive from other sources
We receive information about you from other service users.
Other users of the services: Other users of our services within your company may provide information about you when they submit content through the services. For example, a team member may upload content about you, including your name, title, e-mail address and phone number when designating you as a verified user of our services. We use this information because we have a legitimate business interest in performing the contract that we have entered into with you, your employer or a third party and in providing, managing and administering our service.
How we use information we collect
How we use the information we collect depends in part on which services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the services and personalize your experience: We use information about you to provide the services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the services. Our services also include tailored features that personalize your experience. We may use your email domain to infer your affiliation with a particular organization or industry to personalize the content and experience you receive on our websites. Where you use FIN services, we may combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one service while searching from another or to present relevant product information as you travel across our websites.
For research and development: We use collective learnings about how people use our services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the services. In some cases, we apply these learnings across FIN services to improve and develop similar features or to better integrate the services you use. We also test and analyze certain new features with some users before rolling the feature out to all users.
To communicate with you about the services: We use your contact information to send transactional communications via email and within the services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
To market, promote, and drive engagement with the services: We use your contact information and information about how you use the services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the services. We need this information to provide you with support requested. We use and disclose this information to provide the Service and provide relevant support services. We use this information because we have a legitimate business interest in ensuring that you receive an effective Service from us. We will keep this information for a reasonable length of time that lets us understand any technical issues that users have with our Service.
Billing: If you have been designated by your organization as being a contact for billing or payment purposes, we will use your Personal Information to process your organization’s order, issue invoices to your organization and take payment from, or make payment to, you (including refunds if applicable). We use this information because it is necessary for our contract with your organization that we collect information from its representatives to process payments for new and renewal subscriptions or give or receive refunds.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the services, with your permission.
Legal basis for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the services you use and how you use them. This means we collect and use your information only where:
We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services.
How we share information we collect
We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.
For collaboration: You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the services display some or all of your profile information to other Service users when you share or interact with specific content.
Managed accounts and administrators: If you register or access the services using an email address with a domain that is owned by your employer or organization, or associate that email address with your existing account and such organization wishes to establish FIN services account, certain information about you including your name, contact info and account use may become accessible to that organization’s administrator to provide you additional products and services.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our services.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
Links to Third-Party Sites: The services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect FIN, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
How we store and secure information we collect
Information storage and security: We use data hosting service providers in the United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.
How long we keep information: How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information during your subscription as well as if your account is inactive. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our services, not to specifically analyze personal characteristics about you.
Managed accounts: If the services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the services and using settings available within the services or your account. Where the services are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep.
Access and update your information: Our services give you the ability to access and update certain information about you from within the service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).
Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our services. You can opt out of some notification messages by updating you preferences in the e-mail.
How we transfer information we collect internationally
International transfers of information we collect
We collect information globally and primarily store that information in the United States. We may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the services. Whenever we transfer your information, we take steps to protect it.
Other important privacy information
Notice to End Users
Our products are intended for both personal use and use by organizations. Where the services are made available to you through an organization (e.g. your employer), that organization is the administrator of the services and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Even if the services are not currently administered to you by an organization, if you are a member of a team administered by an organization, or if you use an email address provided by an organization (such as your work email address) to access the services, then the administrator of that team or the owner of the domain associated with your organizational email address (e.g. your employer) may assert administrative control over your account and use of the services at a later date. You will be notified if this happens.
In some cases, administrators can also:
require you to reset your account password;
restrict, suspend or terminate your access to the services or your account;
control your ability to edit, restrict, modify or delete account information;
change your account information, including profile information or the email address associated with your account;
access information in and about your account;
access or retain information stored as part of your account; and
If you do not want an administrator to be able to assert control over your account or use of the services, you should deactivate your membership. Once an administrator asserts control over your account or use of the services, you may no longer be able to withdraw membership or change the email address associated with your account without administrator approval.
Please contact your organization or refer to your administrator’s organizational policies for more information.
Our policy towards children
The services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
Your information is controlled by FIN. If you have questions or concerns about how your information is handled, please direct your inquiry to FIN as set forth below:
GRLM, LLC dba Financial Investment News
15 West 26th Street, 4th Floor
New York, NY 10010
E-Mail: [email protected]