Poket Privacy Policy

Updated 1st March, 2023

GradientFI strives for transparency and trust when it comes to protecting your privacy and we aim to clearly explain how we collect and process your information. It is important to us that you should enjoy using our products, services and website(s) without compromising your privacy in any way. This policy outlines how we collect and use different types of personal and behavioral information, and the reasons for doing so. You have the right to access, change or delete your personal information at any time. You should read this policy in conjunction with our Terms of Use and ensure that you understand how we collect and use your information. Our policies will be updated from time-to-time. Please refer back regularly to keep yourself updated. This policy applies to “users” and “customers” that is anyone interacting with any product or service from any GradientFI business. This includes subscribers, website users, customers, event attendees, etc.

COLLECTION AND USE OF YOUR INFORMATION

The information you provide us, and that which we gather based on your activity, can help us to deliver more relevant content as well as to create a more seamless experience across the products and channels through which you may access that content. We collect and store some information about you in order to deliver products and services to you. We share some of that information with trusted third-party service providers to ensure the delivery of those products and services, or to give personalized recommendations on things we think will be of interest to you. We also collect information when you use our products and services. Further details are provided below.

INFORMATION YOU PROVIDE US

There are certain personal information required in order to provide the products and services that you have chosen, such as:

INFORMATION WE COLLECT THROUGH YOUR USE OF OUR PRODUCTS

When you use any of our services, we collect information that helps us to deliver the services you have chosen and to improve your experience. This is done through Cookies and other technologies. Examples of the type of information collected include:

You can also volunteer to disclose additional information which may not be essential to deliver a service to you. By providing these information, you will help us communicate with you in a way that is most relevant, useful and engaging. We may collect and ask for additional information when you order, purchase, register, subscribe or make use of our products or services in any way – via in person, marketing campaigns, phone or mail order, or our websites.

INFORMATION WE DO NOT TRACK

We do not track or collect any sensitive information about you. This includes race, religion, ethnicity, and political opinion.

HOW WE USE YOUR INFORMATION

We primarily use your information for the purpose of delivering the products and services that you have chosen and to personalize our interactions with you. We provided additional information below.

WE USE INFORMATION COLLECTED TO:

• Provide products and services.
• Fulfil requests and contracts across all our products and services, today and in the future, in conjunction with our third party service providers.
• Manage your access to our online content and apps, and to send you content via push notifications, newsletters and subscriptions if you have requested us to do so.
• Send you service notifications related to your product or service such as subscription renewal notifications, password resets and order confirmations.
• Manage customer service queries and complaints.
• Manage your privacy preferences and to ensure you only receive communications that you have requested, which may include using your details to suppress you from communications.
• Send you administrative emails about your account, reminders for upcoming events, service changes, or new policies. These updates, changes and notifications are essential for the services that you have selected.
• Detect and reduce fraud including fraudulent orders.
• Prevent users from posting illegal, offensive or objectionable comments on our site.

OTHER USES OF YOUR INFORMATION

We use your information in certain ways to provide our products and/or services to you, in accordance with our contracts with you. In certain cases, we may use your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests, to:

• Measure customer and user response and engagement with our products and services such as online content, email newsletters and subscription offers. This may include sharing your information with third parties to analyze and measure response and engagement.
• Ensure products (including websites and apps) are compatible with the browsers and operating systems used by most of our visitors.
• Improve customer and user experience and to support new product development. We may send customer satisfaction surveys and market research questionnaires (for which we may share your information with third party suppliers employed by us).
• Detect and reduce fraudulent activity and for other security related purposes such as to help us protect against harassment, IP infringement, crime or other security issues.
• For any purpose required by law or regulation and to verify information that we provide to third parties for compliance and audit purposes.

You have the right to object to any of the above uses of your information. Please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your information is still appropriate. We will explain our decision to you in a timely manner.

SOCIAL MEDIA

GradientFI publishes content on social media platforms e.g. Twitter, Facebook, LinkedIn through both “organic” and “paid” methods to reach current and potential users:

• “Organic” methods describe where content and/or offers are published onto a social platform so that they may appear in your social platform’s feed, without being promoted or forced to appear more prominently.
• “Paid” methods describe where content and/or offers are published onto a social platform so that they will appear more prominently, or be shown to users that do not currently follow GradientFI’s social pages e.g. a promoted tweet on your Twitter timeline.

We may place one or more social media platform “tags” on our website in order to better understand how GradientFI may be of best value to you by providing you with the most relevant content available according to what you have chosen to read on our own websites. These tags only record information around events to help us understand if you are registered or subscribed with us, so that we may use your reading preferences to provide more relevant content and/or offers to you, on social media platforms, e.g. removing subscription offers from your feed if you are a current subscriber.

We do not have direct access to your personal data on your social media platforms.

HOW WE USE YOUR INFORMATION TO PERSONALIZE THE CONTENT

To enable us to personalize the content you see (including on social media), we may use your interaction and browsing behavior or preferences (such as how and what you read on our websites and our apps). This is to enable content and message personalization to be delivered to you or a group of users with similar interests to you. This can be done both on our site and on those of third parties.

We may analyze your individual information to create a profile of your interests and preferences as a part of an audience. These insights are used to help us make marketing decisions so that we can ensure our messages are relevant to you. There are times we may use additional information available from external sources to help us do this effectively.

HOW WE WORK WITH THIRD PARTIES

As mentioned, in some instances, we disclose personal information to third parties when it is necessary to deliver a service and/or product, or to help us improve your experience with us, or when we are required to do so by contract or law. “Third parties” include agents, subcontractors, sponsors and other associated organizations. We have in place contracts to ensure the information remains secure and in limited use, and if we do not have a legitimate business reason to pass on your information, we will ask you to give consent first. Some examples of when we share your information are below:

• When you make a payment on any of our platforms, example: on-ramp payment, your payment will be processed by a specialist payment processor to ensure a secure transaction. All payment processors used by GradientFI are compliant with required security standards.
• When we send you an email or a push notification, these are delivered by platforms we use for publishing, forums and marketing. As part of this service, certain information such as message opens, clicks and formatting are recorded to help deliver the best email experience.
• When we test and launch new products, services or offers, we may work with trusted third parties to support us.
• We also employ third parties to carry out statistical analyses and conduct surveys on our behalf.
• To provide information for auditing purposes by official regulators.
• To enhance your profile with non-personal information.

RETAINING AND STORING YOUR INFORMATION

Retention policy

We securely store your information, and hold it for as long as we need to in order to provide our services and products to you in accordance with (i) applicable law, or (ii) as long as is set out in any relevant contract you have with us.

Keeping your information safe

We take information security seriously and have policies and procedures in place to ensure the information we hold on you remains safe. We limit who has access to your information and ensure that those who do are bound by contracts to keep your information availability restricted and safe.

Individuals under 16

GradientFI does not intentionally, or knowingly, process personal information from individuals under the age of 16. When necessary, users under the age of 16 will be told not to submit any personal details. We will make every effort to delete any details of such users where a parent or guardian has informed us that these details have been collected.

EXTERNAL LINKS

This Privacy Policy only applies to GradientFI’s use of data. Our websites, services or products may contain links to, use, or be on external sites. GradientFI is not responsible for the Privacy Policies or the content of such sites and we recommend that you read the Privacy Policies on any external sites you use. Similarly, if you are directed to our website from a third party, we are not responsible for the Privacy Policy or practices of the third party. We strongly recommend you read their policy.

COOKIES

Cookies are small files that are created in your web browser when you visit any of our websites.

Cookies are used to personalize online content. GradientFI does not use Cookies for advertising.

WHAT ARE MY RIGHTS UNDER GDPR (GENERAL DATA PROTECTION REGULATION)?

You have a right to ask us for information we hold about you, please write to us at the address below including the subject line, “Subject: Information Access Request”, so that we can respond as promptly as possible.

YOUR RIGHTS

You also have the right to ask for us to update, delete or stop processing information we hold about you. However, please note that there are circumstances in which complete erasure of your information or ceasing to process your information will not be possible for operational, legal and business reasons. This may include if you remain a customer for whom we need to provide services, or if you wish us to no longer contact you for marketing purposes. In this case we may need to retain some of your details securely in order to facilitate this request by, for example, keeping you on a “do not contact” or suppression list. This will be the only purpose for which your data will be used if this is the case.

CHANGES TO THIS POLICY

We may make occasional changes to the Privacy Policy. This may be in relation to changes in the law, best practice or changes in our services. These changes will be reflected in this statement, so you should check here regularly.

WHO WE ARE AND HOW TO CONTACT US

San Francisco, CA, United States