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CULEDGER PRIVACY POLICY

Who we are: CULedger ("CULedger," "we," or "us") is a research-to-action initiative that is investigating the viability of a private, permissioned distributed ledger (DLT) that can be used by credit unions. It is an effort to do for the credit union industry what R3 is doing for the banks: assemble a consortia of credit unions and CUSOs to build a ledger network dedicated the needs of credit unions. (the "Services"). CULedger is committed to protecting your privacy and utilizing technology that gives you a powerful and safe online experience. The website www.CULedger.com, (hereinafter "the Site") is owned and operated by CULedger and CULedger is the controller of the personal data.

At CULedger we share your concerns about privacy. We created this Privacy Policy in order to demonstrate our firm commitment to our privacy practices. The following discloses our information gathering and dissemination practices for the CULedger Web Site.

The Terms and Conditions of Use ("Terms of Use") and this Privacy Policy constitute a binding agreement between you and CULedger. Please read carefully through all sections of the Terms of Use and the Privacy Policy. Where applicable, your access and/or use of the CULedger Web Site, or submission of contact information to request additional information from CULedger, constitutes your agreement to all such terms, conditions, and notices.

CULedger reserves the right to change this Privacy Policy at any time and without notice to you. We will notify you if we make material changes to the Privacy Policy or we will provide notice to you of our changes on our website landing page. Please review the posted Terms of Use and Privacy Policy on a regular basis as your access and use of the CULedger Web Site will be governed by the then-current Terms of Use and Privacy Policy.

Why We Collect and How We Use Personal Information

We collect and share information from the users of our Sites and Services to manage our contractual obligations to you, comply with legal obligations and/or because we have a legitimate business interest to do so. We collect and share information to: (a) provide information about our products and Services; (b) provide information about data security and privacy; (c) learn more about our customer's preferences; (d) enhance, personalize and support your experience on our Sites; (e) enhance and develop our products and Services based on your direct comments and/or on the pages or information you view on our Sites; and (f) analyze the traffic to our Sites.

Information Collection and Use

Information You Give Us

Information We Collect from You

Information we obtain from others.

Contact Information: You give us your Contact Information when you request information be provided to you via a download, email, text or other means. "Contact Information" includes your name, email, company, phone number, username and/or password.

We may use Contact Information and other Personal Data to:

  • to fulfill your requests for information; and
  • to contact you about information related to CULedger and its progress, products or services based on the preferences you have indicated.
  • To personalize your experience as your information helps us to better respond to your individual needs.
  • To improve customer service as your information helps us to more effectively respond to your customer service requests and support needs.
  • To administer a contest, promotion, survey or other site feature if you choose to participate.
  • To send periodic emails regarding information and updates pertaining to company news, updates, related product or service information, etc.

We collect Analytical Information through automated means when use and navigate the Site. "Analytical Information" includes log files, pages and products viewed, ads that you clicked on, emails from us that you opened, browser type, operating system, IP address and device information, your mobile operating system (OS), a mobile device identifier embedded by us, or other commonly used mobile device identifier if you access the Site on a mobile device.

We use Analytical Information to:

  • retain and evaluate information from your visits to the website and how you move around for analytics purposes to improve our website to make it more user friendly or improve the speed of the page loading or the website in general;
  • gather broad demographic information for aggregate use;
  • to review user preferences when navigating the site and to develop new services that may be able to better appeal to our customers based upon what information our customers view or how they navigate the website;
  • help diagnose problems with our server and to administer the services offered by the CULedger Web Site.

We may also collect your current location if your user settings allow such location and will use that information in the aggregate to provide demographic information for our users in general.

We do not currently collect information related to you from other sources.

You may, however, visit our site anonymously and do not have to submit personal information to use much of the Site. You are solely responsible for the information and other content you provide on or through the CULedger Web Site, including any personal information included in posts, captions or remarks on a board service, chat area, news group, forum, community, personal web page, calendar and/or other message or communication facility contained on the CULedger Web Site designed to enable you to communicate with the public at large or with a group (collectively, "Communication Services"). You understand that personal and other information (e.g., user names, e-mail addresses, phone numbers, personal life events) that you post on or using the Communication Services is generally accessible and may be collected and used by others and may result in unsolicited messages or other contact from others. Users of the Communication Services are encouraged to exercise caution when providing their own personal information while using any Communication Services.

Electronic Marketing

We will give you the opportunity to "opt out" of receiving any unsolicited information from us or to limit the unsolicited information you receive from us to information regarding the Services or information you specifically request or information we determine you may find useful as a result of your use of the Site.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.

While the CULedger Web Site includes commercially reasonable security measures in place to protect against the loss, misuse and alternation of the information under our control, you acknowledge that no security measures are always effective and CULedger does not guarantee the performance or adequacy of such security measures.

Third Party Processors

To ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate procedures with the third party contractors to CULedger we share your Personal Data with to ensure that your Personal Data is treated by those third parties in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use third-parties to host our website and CRM system to keep you informed about CULedger's products and services and for updates on CULedger's progress.

How long do we keep your information?

We will store your information you choose to provide for as long as you are a member and for up to five (5) years thereafter.

Do we use cookies or clear gifs?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. We use cookies to help us remember and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. Information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that deleting cookies or disabling future cookies may negatively affect the continuity and user experience when you use the CULedger Web Site.

Clear gifs (also known as web beacons) are tiny graphics with a unique identifier, similar in function to cookies, that are used to track the online movements of mobile internet users. Clear gifs help us better manage content on the CULedger Web Site by informing us what content is effective and of interest to our users.

Cookies and clear gifs are not tied to your personally identifiable information.

The use of third-party cookies is not covered by our Privacy Policy. We do not have access or control over these cookies. If you continue to use our website, we will assume you agree to the use of these cookies. You may visit the following links from our third-party providers to opt-out of their tracking and learn about their privacy practices:

  • Google Analytics:
    • To view Google's privacy policy, please visit: http://www.google.com/policies/privacy/.
    • To opt-out, please download and install the Google Analytics opt-out browser add-on by visiting: https://tools.google.com/dlpage/gaoptout.

Do we disclose any information to outside parties?

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Do Not Track

Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the "Do Not Track" signal, the Site does not currently interpret, respond to or alter its practices when it receives "Do Not Track" signals.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties, including any third party for its direct marketing services, without your consent. Thus, under California Civil Code Sections 1798.80-1798.84, CULedger has no obligation to a California resident to provide further information regarding CULedger's use of the California resident's personal information.

Any inquiries regarding the Terms of Use or this specific Privacy Policy can be directed to the contact identified below.

Notice to Utah Residents

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties, including any third party for its direct marketing services, without your consent.

Notice to Residents of the European Economic Area and the UK

Under the GDPR, residents of the European Economic Area and the UK have the following rights related to CULedger's use of your Personal Data.

Number Description of your right
Right 1 A right to access personal data held by us about you, as well as information about how we are using your data.
Right 2 A right to require us to rectify any inaccurate personal data held by us about you.
Right 3 A right to require us to erase personal data held by us about you, and where the personal data has been made public, for other controllers processing the personal data to also erase links to, or copy or replication of, such personal data. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4 A right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 5 A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 6 A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you).
Right 7 A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you).

To exercise any of your rights above, please contact Owner at info@culedger.com or CULedger LLC, 1009 Grant Street, Denver, CO 80203. If you choose to exercise any of your rights listed above, it may affect your ability to use the Site, as the operation and functionalities provided on the Site may require the use of your Personal Data.

Childrens Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), 15 U.S.C. §§ 6501-06 and 16 C.F.R. §§ 312.1-312.12, we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older. By using the CULedger Web Site, you represent that you are thirteen (13) years of age or older.

Online Privacy Policy Only

This online privacy policy applies only to information collected through our website and not to information collected offline.

Data Transfers Across Jurisdictional Boundaries.

Since our Services are based in the United States, your data will be transferred from your country of residence into the United States.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below.
www.culedger.com
CULedger, LLC.
1009 Grant Street
Denver, CO 80203
Email: info@culedger.com

Revised 11/19/18