Privacy Policy

Last Updated June 2016

We at Polly Portfolio, Inc. (the “Company,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared.  This Privacy Policy relates to the information collection and use practices of the Company in connection with our Website and Platform.  By visiting our Website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use for Visitors.  By visiting our Website and/or accessing and using our Platform, Registered Users and Account Clients are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use for Registered Users and Account Clients.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in your applicable Terms of Use.

The Information We Collect and/or Receive

In the course of operating the Website and the Platform, the Company will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Personal Information

When you sign up to become a Registered User or an Account Client, you will be required to provide us with personal information about yourself, such as your name, phone number, and e-mail address.  To use Polly Portfolio, Account Clients will also need to provide certain personal financial information in response to queries and required information requests made by the Company. And, if you contact us via the Contact Us page, you will need to provide your name, e-mail address, phone number, and postal address.  All information that we receive under this section is collectively called “Personal Information.” We do not collect any Personal Information from Visitors, Registered Users, or Account Clients when they use the Website or the Platform, unless they provide such information voluntarily.

2. Other Information.

In addition to the Personal Information, we may collect or receive additional information (collectively, the “Other Information”).  Such Other Information may include:

a.From Your Activity.  In an ongoing effort to improve the Website and the Platform, we automatically collect certain information when Visitors, Registered Users, and Account Clients access and use the Website and/or the Platform.  Such information includes, without limitation, IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website and/or the Platform you visit, log files, and similar information and data.

b.From Cookies.  We collect information using “cookie” technology.  Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website and/or Platform.  If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer.  Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.  However, if you decide not to accept cookies from us, the Website and the Platform may not function properly.

c.From You.   You may voluntarily provide us additional information about yourself that does not identify you personally, such as your gender, country, product and service preferences, and other information.

How We Use and Share the Information

You authorize us to use the Personal Information and the Other Information (collectively, the “Information”) to provide and improve our Website, Platform, products, and services; to process transactions you request; to inform you about our products and services and those of our promotional partners; and to bring you customized content (such as newsletters) based on your activity on the Website and/or the Platform.

You also authorize us to use and/or share Information as described below.

Accessing and Modifying Information and Communication Preferences

Registered Users and Account Clients may access, remove, review, and/or make changes to their Personal Information by following the instructions found on the Website and/or the Platform.  In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Company marketing e-mail.  We will use commercially reasonable efforts to process such requests in a timely manner.  You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.  Account Clients cannot opt out of receiving transactional e-mails related to their account with the Company.

How We Protect the Information

We take reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website and/or the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents

The Website, the Platform and the applicable servers are operated in the United States and elsewhere.   Please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to use the Website and/or the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

External Websites

The Website and/or the Platform may contain links to third-party websites.  The Company has no control over the privacy practices or the content of these websites.  As such, we are not responsible for the content or the privacy policies of those third-party websites.  You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Children 

We do not knowingly collect Personal Information from children under the age of 18 through the Website and/or the Platform.  If you are under 18, please do not give us any Personal Information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Website and/or the Platform without their permission.  If you have reason to believe that a child under the age of 18 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time.  Any such changes will be posted on the Website and/or the Platform.  By accessing the Website and/or the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information.  Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please contact us via e-mail at privacy@pollyport.com with “PRIVACY POLICY” in the subject line.