Privacy Notice

Currence, Inc, a Delaware corporation (“Currence,” “us”, “we”, or “our”) operates the Currence Mobile Application and the Currence Advisor Web Application (hereinafter referred to as the “Service”). This Privacy Notice informs our end-users (“Users;” “you;” “your”) of our policies regarding the collection, use and disclosure of personal data when Personally Identifiable Information (as defined below) about users of our website, www.livecurrence.com (“Site”), interactive features and our Service, and governs our collection of your information and content and the forwarding of such information to applicable vendors, organizations, or business partners (collectively, “Partners”).

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy, including the transfer of your information to a Partner. Unless otherwise defined in this Privacy Notice, the terms used in this Privacy Notice have the same meanings as in our Terms and Conditions.

Due to the Internet’s rapidly evolving nature, we may need to update this Privacy Notice from time to time. If so, we will post our updated Privacy Notice on our Site and will notify you of the updated posting as stated herein. Your continued use of the Service and/or continued provision of Personally Identifiable Information to us will be subject to the terms of the then-current Privacy Notice.

Definitions

“Service”: Service means the www.livecurrence.com website and the Currence Mobile Application and the Currence Advisor Web Application.

“Personal Data”: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

“Usage Data”: Usage Data are data automatically collected that are either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

“Cookies”: Cookies are small files of information generated by web servers and sent to a web browser, which are stored on a user’s device (computer or mobile device) for a predetermined period or the length of a user’s website session. They help inform websites about the user and the user’s experience. .

“Data Subject” or “User”: Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service. This section describes the interactions and activities designed to support engagement between Currence Advisors and Users.

Types of Data Collected

Personally Identifiable Information

While you are using our Service, we may ask you to provide us with certain personally identifiable information that enables us to contact or identify you (“Personally Identifiable Information”). Personally Identifiable Information may include, but is not limited to:

  • First name and last name (Advisor and User)
  • Email address (Advisor and User)
  • Phone Number (Advisor and User)
  • Bank Account Number (User only)
  • Cookies and Usage Data (Advisor only)
  • Internet Protocol (“IP”) address

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Additionally, we may invite you to participate in surveys, questionnaires, or to contact us with questions, comments, or to provide us with feedback, which due to the nature of some of these activities, may include the collection of Personally Identifiable Information. By accessing or using the Service, we might collect additional data as set forth below in the “Aggregate Information” paragraph.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

We, as well as our affiliate program partners and other third parties, may also employ a software technology called “clear gifs,” or “web beacons” to help us better manage content on our Services, and improve the quality and experience of our Services. The same is applicable to any embedded script we may use in addition to flash and HTML5. Various browsers may offer tools for removing certain usage information trackers such as HTML5 local shared objects (LSOs).

We may also work with analytics service providers and other vendors to provide us with information regarding traffic on the Services.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. The NAI’s main webpage is located at www.networkadvertising.org.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites or applications. You may continue to receive advertisements, for example, based on the website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Aggregate Information.

We may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, and IP addresses. We may also analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and will not contain Personally Identifiable Information. We may use such aggregate information to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use.

Third Party Services.

We use a variety of services hosted by third parties to help provide our Service, including Amazon Web Services. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. We do not control third parties’ tracking technologies. If you have any questions about these third-party technologies, you should contact the responsible provider directly.

Use of Data

Currence uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To create a customer account

Retention of Data

Currence will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Currence will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Currence will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice Privacy Notice and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If Currence becomes a party to a merger, acquisition or asset sale, your Personal Data may be transferred in connection with that transaction. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Legal Requirements

Currence may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Currence
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and/or banking information will be encrypted using SSL technology.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

California Privacy Rights; California Consumer Privacy Act (CCPA)

  • California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes. We do not provide your Personally Identifiable Information to any third parties for direct marketing purposes as defined in California Civil Code Section § 1798.83. Please contact us at compliance@livecurrence.com for any questions regarding your Personal Information.
  1. Categories of Personal Information Collected

As set forth above, we collect the following categories of information: identifiers (such as your name, address, and email address), other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected personal information.This information is collected directly from you when you provide it to us (for example when you submit a form requesting more information, when you enter into a contract with us) or automatically as you navigate through the Site.We use this information for one or more legitimate business purposes, including to provide our Service, improve our Service, and offer information about our Service to you.

  1. Rights of California Residents

If you are a resident of California, you have other rights under the CCPA:

  • Right of Access: You can access your collected personal information by contacting us at compliance@livecurrence.com.
  • Right to correct, update, or delete: You can correct, update or request deletion of your personal information by contacting us at compliance@livecurrence.com. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law. Further, with regard to your account and/or profile page, you can request access to correct or delete any personal information that you have provided to us. We cannot delete your personal information, however, except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
  • Right to Request Disclosure of Information Collected: Please contact us at compliance@livecurrence.com to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
  • Right to Disclosure of Information Sold and Right to Opt-Out: You have the right to know what information of yours we have sold, and you have the right to opt-out of any sale of your information. We do not sell any of your information.If you have any questions about these rights, please contact us at compliance@livecurrence.com.
  • Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CCPA.
  • When you contact us regarding any of your rights under the CCPA, we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CCPA, please contact us at compliance@livecurrence.com.
  1. Colorado Privacy Act (“CPA”), Nevada Privacy of Information Collected on the Internet from Consumers Act (“NPICICA”), and Virginia Consumer Data Protection Act (“VCDPA”) Disclosures
  1. Categories of Personal Information Collected

As set forth above, we collect the following categories of information: identifiers (such as your name and email address), personal information (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected personal information.This information is collected directly from you when you provide it to us (for example when you submit information for us to create an account for you) or automatically as you navigate through the Site.We use this information for one or more legitimate business purposes, including to improve our Service and offer information about our Service to you.

  1. Rights of Colorado, Nevada, and Virginia Residents

If you are a resident of Colorado, Nevada, or Virginia, you have other rights under your respective states’ consumer privacy statutes:

  • Right of Access: You can access your collected personal information by contacting us at compliance@livecurrence.com.
  • Right to correct, update, or delete: You can correct, update or request deletion of your personal information by contacting us at compliance@livecurrence.com. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law.
  • Right to Request Disclosure of Information Collected: Please contact us at compliance@livecurrence.com to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
  • Right to Disclosure of Information Sold and Right to Opt-Out: You have the right to know what information of yours we have sold, and you have the right to opt-out of any sale of your information. We do not sell any of your information. If you have any questions about these rights, please contact us at compliance@livecurrence.com.
  • Right to Disclosure of Targeted Advertising and Right to Opt-Out (Colorado & Virginia): If you are a resident of Colorado or Virginia, you have the right to know what information of yours we have processed for targeted advertising. If you have any questions about these rights or wish to opt-out of any processing of your personal information as it relates to targeted advertising, please contact us at compliance@livecurrence.com.
  • Right to Disclosure of Profiling (Colorado & Virginia): If you are a resident of Colorado or Virginia, you have the right to know what information of yours we have processed for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. If you have any questions about these rights or wish to opt-out of any processing of your personal information as it relates to profiling, please contact us at compliance@livecurrence.com.
  • Colorado Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CPA.
  • Nevada Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the NPICICA.
  • Virginia Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the VCDPA.

When you contact us regarding any of your rights under the CPA, NPICICA, or VCDPA we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CPA, NPICICA, or VCDPA please contact us at compliance@livecurrence.com.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Notice of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

  • The Children’s Online Privacy Protection Act (“COPPA”) requires that all online service providers, including Currence, obtain parental consent before knowingly collecting personally identifiable information from children under the age of 13. Our Service is directed towards adults who are of the legal age to access them in their respective jurisdictions and by accessing and using our Service, you represent and warrant that you are of the legal age to form a binding contract with us in your respective jurisdiction and that you meet the foregoing eligibility requirements. Currence does not knowingly collect or solicit any personally identifiable information from children under the age of 13. Children under the age of 13 are prohibited from using the Service. If we learn that we have collected personal information from a person under the age of 13 that does not comply with COPPA, we will delete that information in a reasonably prudent amount of time. If you believe that a child under the age of 13 has provided personally identifiable information to us, please contact us at compliance@livecurrence.com.

Breach Notification

This section addresses possible Breaches involving Currence customer PI data.

Personal Information (PI) security breaches (“Breaches”) can occur and be caused through numerous ways. As the amount of data and information grows and technology develops, there are increasingly new ways by which PI can be breached. Currence is required to have in place a robust and systematic process for responding to any reported PI data security breach, to ensure it can act responsibly, protect PI data which it holds and comply with its legal requirements.

Currence’s policies and procedures, including its information security plan, ensure that the following occur:

  • incidents are reported swiftly and can be properly investigated;
  • incidents are dealt with in a timely manner and normal operations restored;
  • incidents are recorded and documented;
  • the impact of the incident is understood, and action is taken to prevent further
  • damage;
  • relevant notifications are made to authorities, data subjects and potentially others (in particular, customers) are informed as required in more serious cases;
  • incidents are reviewed, and lessons learned.

Changes to This Privacy Notice

We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Notice.

You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Notice, please contact us:

  • By email: compliance@livecurrence.com