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 to 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, (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
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:

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

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 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.
CULedger, LLC.
1009 Grant Street
Denver, CO 80203

Revised 11/19/18