Privacy policy - last revised 6/29/2017

Gradifi, Inc.

699 Boylston Street

Boston, MA 02216

Phone: 857-310-4340

Welcome

Gradifi, Inc. (“we,” “our,” “us,” and “Gradifi”) respects the privacy of our customers and visitors to this website (www.gradifi.com) and its affiliated pages (collectively, the “Site”). This Privacy Policy (the “Privacy Policy”) applies to the Site and to other online or telephonic means of communication through which we may obtain information from you, including email, text, and mobile and desktop applications you download from the Site, which provide dedicated non-browser-based interaction between you and Gradifi.

The Site may contain links to third party websites, social media sites, services or applications that we do not control (collectively “Third-Party Sites”). We make no representations or warranties regarding Third-Party Sites. Third-Party Sites may have privacy policies different from ours and they may provide you with less privacy and/or security than our Site. We are not responsible for any losses or damages you incur in connection with the information, security, privacy practices, availability, content or accuracy of materials of such Third-Party Sites. We encourage you to review the privacy and security policies of all Third-Party Sites before you share any personally-identifiable information with them. The choice to access or use a Third-Party Site is in your sole discretion.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Site, you agree to this privacy policy. This policy may change from time to time (see below under “Changes to Our Privacy Policy”). Your continued use of the Site after we make changes to the Privacy Policy is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Information We Collect Through the Site and How We Collect It

Generally

When you visit our Site we receive and collect certain information about you. The information that we receive and collect depends in part on what you do when you visit the Site.

Information You Provide to Us

You can browse our Site and take as much time as you want to review our services without having to submit information about yourself.

You may be able to improve your experience on our Site if you tell us who you are - for example, by signing up for email, applying for products, making inquiries, or requesting further information about a product or service. When you seek such additional communications with us, you generally will need to provide us with specific information about yourself, such as your name, date of birth, phone number, address, email address, and account number. We consider this to be “personally identifiable information” (PII) because it either identifies or could be used to identify you. From time to time, we may supplement the PII you provide through our Site with information from other sources, such as information validating your address or with information obtained from a consumer reporting agency when you enroll in our service. Thus, information we obtain through our Site may be intermingled with and used in conjunction with information obtained through sources other than our Site, including both offline and online sources.

Information We Collect Automatically When You Visit the Site

We also collect information from your computer or other online access device automatically when you visit the Site. Such information may include the type of products and services you are interested in, the type of browser you are using (e.g., Internet Explorer or Google Chrome), the type of operating system you are using (e.g., Windows or Mac OS), and the domain name of your Internet service provider (e.g., Verizon or Comcast).

We may use certain tracking tools to collect information from your computer or other online device when you visit the Site, including:

  • Cookies: A "cookie" is a small text file that is placed on your computer to distinguish you from other visitors to our Site. 
  • Web Beacons: A “web beacon” (also referred to as a “pixel tag”) is a small block of code that is placed on a Site page or within an email.

As explained further in the “Choices” section below, your browser may enable you to block or, in the case of cookies, to delete some of the means by which we automatically collect information when you visit the Site. However, doing so may impact the usability of the Site for your purposes. To learn more about cookies, please visit http://www.allaboutcookies.org.

By using the Site, you are deemed to unambiguously agree to its use of any cookies that you do not disable.

Social Media

Our Site includes social media features, such as the “Follow Gradifi” link for Twitter. If you interact with any of these features -- such as by clicking on the “Follow Gradifi” link -- the feature may collect your IP address and the page you are visiting on the Site, and may set a cookie to enable the feature to function properly. These social media features may be hosted by us or a third party. To the extent they are hosted by a third party, your interactions with the features are governed by the privacy policies of the companies providing them, and you should review those privacy policies to learn about how the information is used and shared.

Other Third-Party Tracking

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  This analytical tool uses cookies and similar technologies to help analyze how users use the Site.  The information generated about usage, including visitor IP address, is transmitted to Google.  This information is then used to evaluate visitors’ usage, compile statistical reports on website activity, and provide other services relating to website activity and Internet usage.  For further information about the collection and use of data through Google Analytics, please refer to:  http://www.google.com/policies/privacy/partners/.  Google offers the ability to opt out from tracking through Google Analytics cookies; for more information, visit: http://tools.google.com/dlpage/gaoptout.

Our site also utilizes Pardot, LLC, a Salesforce company, as a marketing automation agent for our site. Pardot uses cookies or similar technologies to help analyze how users use the site. Please review Pardot's Privacy Policy for information about Pardot's data use policy and security measures. Please also review "How Does Pardot Track Activities?" for information about how Pardot uses cookies and how you may refuse the use of cookies. 

 How We Use the Information We Collect

We may use the information, including PII, that we collect from you in order to:

  • Provide you with notices about your account;
  • Provide you with services you request from us, including publications or other forms of information;
  • Ensure technological compatibility of the Site with your computer;
  • Verify your identity and/or remember your personal settings (including your preferences);
  • Protect against fraud or identity theft;
  • Conduct aggregate analyses of Site usage patterns;
  • Monitor Site usage and to improve the customer experience of our Site; and
  • Personalize and improve the marketing that we make available on the Site.

Unless you direct us otherwise, we also may use your information, including PII, to provide you with information about the products and services of Gradifi and of third parties that are “affiliates” of Gradifi -- meaning they are part of the same company group as Gradifi.  If you do not want us to provide you with affiliate-related information, you can “opt out” of this use, as described in the “Choices” section below.

How We Share the Information We Collect

We may share the information that we collect, including PII, in the following manner:

  • With our agents and service providers, so that they may assist us in providing our products and services to you. For example, we may share your mailing address with a party that performs mailing services for us. When we use these third parties, we give them only the personal information reasonably needed to perform the service and we limit their ability to use such information to only those services we have hired them to perform on our behalf.
  • To entities that may seek to acquire all or part of Gradifi's business (whether by merger, sale, or otherwise) and to any such entity if it were to make such an acquisition. The purchaser might choose to change the terms of use with respect to your information and would be responsible for communicating those changes to you.
  • In response to judicial or other governmental subpoenas, warrants and court orders served on us in accordance with their terms, or as otherwise required by applicable law;
  • To comply with legal, regulatory or administrative requirements of governmental authorities;
  • To protect our rights or property or our legitimate business interests;
  • To enforce the provisions of our terms or policies;
  • To resolve disputes, protect against fraud, and/or to prevent harm to you or others;
  • To protect or defend us, our subsidiaries, affiliates, or parent company and any of their officers, directors, employees, agents, contractors and partners, in connection with any legal action, claim or dispute;
  • As disclosed in other applicable policies, terms of use, or other agreements; or
  • As permitted or required by law or as authorized by you.

Unless you direct us otherwise, we also may share your PII with our affiliates so they may themselves provide you with information on their products and services.  If you prefer that we not share your PII for this purpose, you may opt out of this sharing as described in the “Choices” section below.

We do not share your PII with nonaffiliated third parties for their use in marketing their own products and services to you.

Choices About How We Use and Disclose Your Information

As noted above, you have certain choices regarding the collection, use and disclosure of your information. These include the automatic collection of information through cookies, and uses and disclosures of PII to send you promotional material:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. As noted above, if you disable or refuse cookies, some parts of this Site may then be inaccessible to you or not function properly. Our Site currently responds to a browser’s “Do Not Track” request regarding tracking of Site visitors across the Site and other websites over time.
  • Promotional Information from Gradifi or Our Affiliates. If you do not wish to have your personal information used by us or shared by us with our affiliates to send you promotional information concerning our or their products or services, you can opt out of such use by sending an email stating your request to privacy@gradifi.com or, if you are a Gradifi member, by changing your notification preferences in your account settings through the Gradifi member portal. If you don’t choose to opt out now, you may always opt out later through such an email request or in the manner described in such emails or text messages that you do receive.

Corrections to Your Information

To correct errors in or provide updates to PII that you have provided to us, please email us at privacy@gradifi.com or, if you are a Gradifi member, please update your account information through the Gradifi member portal.

Discussions on Community Tools

We may, from time to time, make chat rooms, forums, message boards, news groups and other community tools (collectively, the “Community Tools”) available to you on the Site. The Community Tools are publicly available areas of the Site. This means that any information you post to the Community Tools, including PII, is visible to other users of the Community Tools. As a result, you should exercise caution when deciding to disclose your information in these areas, since anyone --not just us -- may view and use publicly-posted information.

Electronic Communications

When you send an email or a text message to us, you consent to receive reply communications from us or our providers through the same electronic media (email or texting). We may retain the content of the email or text message, your email address or mobile phone number, and our response in order to better service your needs or for legal and regulatory reasons.

Electronic forms of communication such as, email, text messaging, or similar forms of communication are inherently unsecure. Please refrain from submitting sensitive personal information (such as account number or Social Security number) via email or similar methods of communication.

Security

All PII that you provide to us is housed within our secure environment.  We will take reasonable steps to protect your PII as you transmit it from your computer to our Sites and to protect it from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should be aware, however, that no Internet transmission is ever fully secure or error-free. In particular, e-mail transmissions may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them from disclosure or misuse.

It is our policy not to request PII from anyone in an email.  Therefore, if you receive an email that appears to be from Gradifi that solicits any PII from you, please do not respond in any way to the suspect email but immediately forward it to us at privacy@gradifi.com, and then delete the email from your mailbox.

Personal Information of Children - A Special Note to Parents

Our Site is not geared towards children. Our Site will not knowingly collect information from anyone under 13 years old. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at privacy@gradifi.com.

Notice to Persons Accessing this Website outside the United States

If you reside outside the United States, any information you provide to us on our Site will be transferred out of your country and into the United States. If you do not want your PII to leave your country, please do not provide the information to us. By providing PII to us, you explicitly consent to the transfer of that information to the United States.

Questions or Comments

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us at privacy@gradifi.com.

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we make material changes to how we collect, use or disclose PII, it is our policy to post a notice that the Privacy Policy has been updated on the Site home page.  It is your responsibility to check the Site and review the Privacy Policy from time to time to learn whether any changes have been made. The most recent revision date for this Privacy Policy appears above. Your continued use of the Site on or after the most recent revision date means you accept its revised terms.