CycleEdge, LLC ("CycleEdge" or "we" or "us" or “our”) respects your privacy rights, and we are committed to maintaining your trust. This privacy policy and notice (this “Privacy Policy”) applies to information, including information about an identified or identifiable individual (“Personal Information”), we collect from our website (www.cycleedgecapital.com) (our “Website”), applications, widgets, products, services, and subscriptions (collectively “Services”) and any information collected by CycleEdge through any “opt-in” (whether paid or complimentary) to our advertisements, surveys, contests, sweepstakes, newsletters, or marketing (collectively our “Communication”), including third-party websites and/or applications, and information collected by CycleEdge offline. Please read the following to understand our practices regarding your Personal Information. This statement discloses our current privacy practices; CycleEdge reserves the right to modify this Privacy Policy at any time, without prior notice, by posting revisions to our Website. Such modifications shall be effective upon posting. The Effective Date at the top of this page will be updated when changes are made to this privacy policy. As with any other provisions of our Terms of Service (available at https://www.cycleedgecapital.com/privacy-policy), if you object to any such modifications, your only recourse is to discontinue use of our Website and/or Services. If you have questions, please contact us at sales@cycleedgecapital.com.
This Privacy Policy addresses the following:
CycleEdge and its designated service providers, collect, store, use, and/or process (collectively “Processes” or “Process”) information that you provide via the Services, including on our Website, or third-party websites and applications when you subscribe or “opt in” to our Communication, or an offer provided by a third party you authorize to provide us with your Personal Information, and when you interact with our Services, communications, and advertisements. We Process the following categories and specific types of Personal Information (information within some categories may overlap):
In addition to the aforementioned, we may process other information that you elect to provide to us in a manner consistent with the purposes for which the information was provided.
Certain Personal Information is required to provide the Services to you. If you do not provide the Personal Information we ask for, it may prevent us from providing the Services to you.
Certain Services may require that we request additional information in compliance with applicable laws, regulations, and good business practices governing the financial industry.
Do not provide information about other individuals or entities unless you are authorized to do so and have their consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting information about others, you represent and warrant to us that you are authorized to do so and that you have received authorization from the person or entity about whom you are providing information and that person or entity has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.
CycleEdge Processes your Personal Information in order to provide our Services and to provide for the proper operation of our Website and other carefully considered business purposes, which include:
CycleEdge retains data, including Personal Information, for so long as reasonably required or permitted to fulfill the purposes for which the data was collected. We will retain your Personal Information for as long as you maintain a subscription account with us or while we provide services to you. Thereafter, we will retain Personal Information as long as appropriate to comply with applicable legal or regulatory obligations or to defend against claims.
CycleEdge and parties with whom we work may place, view, and/or use “cookies”, web server logs, web beacons, pixels, or other electronic tools to Process statistical and other information about your use of the Services, our Website, and other websites and for advertising purposes. For more information about these practices, please review our Cookie Policy https://app.cycleedge.com/legal/cookie_policy.
If you subscribe to any of our Services, we may send you information about other products and services. If you subscribe to any of our Services, or if you register for a custom service or contract, we may contact you to confirm your purchase or subscription, or to provide you with information about its terms or features.
Consistent with this Privacy Policy, we may share, disclose, or deliver (collectively “Disclose”) your Personal Information to the following categories of third parties for the business purposes described in Section 1C above:
2. Service providers, contractors, and other third parties who support our services, including email service providers, advertising partners, chat services, cloud computing services, web hosting providers, customer relationship management providers, e-signature providers, mobile application platforms, and website and data analytics providers. Our disclosure of your information to these providers is governed by contracts that limit their processing of and safeguard your information.
3) other CycleEdge users or Website visitors when you post Personal Information on a blog or community forum (such as The Arena) that we may provide; and
4) the relevant institutional subscriber (typically your employer or their affiliate), and other third parties at their direction, if you receive the services as part of an institutional subscription.
We may also Disclose or allow access to information about our Website or Services users to other third parties on a purely unattributed and aggregated basis.
When you make a payment to CycleEdge, you submit your payment information directly to one of our payment processors, Braintree (a PayPal Company) or PayPal. CycleEdge does not process payments or collect full payment card details. Where you provide your payment information to our payment processors to enable you to purchase products or services, your information is subject to PayPal Inc.’s privacy policies. PayPal Inc. is an independent controller, as defined by the General Data Protection Regulation “GDPR,” of the information you submit to pay for the Services. CycleEdge is not responsible for PayPal’s use of your information. For information about PayPal Inc.’s privacy policies, including how to exercise your data privacy rights with PayPal Inc., please see the PayPal Inc. privacy statement applicable to your location which is available by selecting your location from the drop-down menu at https://www.paypal.com/us/webapps/mpp/ua/legalhub-full?locale.x=en_US and navigating to the privacy statement.
In addition to the aforementioned, we may Disclose information to third parties when you have provided your prior consent, for example, if you request that we make an introduction on your behalf to someone with whom we have a relationship. Once the third party receives the information, your information will be handled by that third party, and the third party’s privacy policies (if any) shall govern their use. As between you and that third party, we cannot be held, and are not, responsible for how that third party will handle your information.
We may Disclose your Personal Information to unaffiliated parties, or parties with whom we do not have a relationship, provided we believe in good faith that such disclosure is necessary or appropriate to: (A) comply with any applicable law, rule, or regulation, or in response to a subpoena, court order or other legal process; or (B) to protect the interests, rights, safety, or property of CycleEdge or others.
If CycleEdge or its affiliate is involved in a merger, acquisition, sale, or similar transaction involving all or part of its business, customer information may be one of the assets disclosed, transferred, sold, or received in connection with such an event. If CycleEdge is involved in a change of ownership event that, in our sole discretion, we believe may materially impact you in relation to your Personal Information, we will notify you via email and/or a prominent notice on our Website, as well as any choices you may have regarding your Personal Information.
5. LOCATION OF PROCESSING
CycleEdge is based in the United States and is subject to U.S. law, including data protection law. If you access the Website or Services, your Personal Information will be Processed in the U.S. and may be subject to different levels of data protection than that provided in your state or country of residence. Your use of the Services constitutes your affirmative consent to the Processing of your Personal Information in the U.S and other jurisdictions.
6. SECURITY MEASURES TO PROTECT YOUR INFORMATION
CycleEdge is committed to protecting your Personal Information. We Process Personal Information you provide us on our secure servers and use technical, physical, and organizational measures reasonably designed to ensure a level of security, confidentiality, and integrity appropriate to the risk associated with the Personal Information we Process.
Your subscription is password-protected. Only you and limited designated CycleEdge personnel have access to the password-protected areas. Your password is unique to your subscription account and is designed to protect your subscription account from unauthorized access and use. We will not be responsible for any lost, stolen, or otherwise disclosed passwords. You should choose a complex and unique password for your subscription and must not share your password with anyone. You should change your password periodically. CycleEdge will never ask you for your password in an unsolicited phone call or email, and you should not respond to any such request, as it will not come from us. If you are using a computer to which others have access, always remember to log out and close your browser window when leaving our site. When you use a public computer or network, it is good practice to change your password on a trusted network shortly thereafter. We believe our security measures are appropriately tailored to the information we Process.
7. CHILD POLICY
CycleEdge’s Website and Services are not directed at children under the age of 18. We will not knowingly Process or use Personal Information from anyone under 18.
8. WHAT ELSE YOU NEED TO KNOW ABOUT OUR PRIVACY POLICY
A. PUBLIC PORTIONS OF OUR WEBSITE
CycleEdge’s Website may offer publicly accessible blogs or community forums, such as The Arena. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, contact us at sales@cycleedgecapital.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Visit the Arena’s Community Guidelines and product-specific disclaimer [PRODUCT DESCRIPTIONS LINK] for more information specifically relating to that Service.
B. DISCLAIMER
While CycleEdge does our best to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are responsible for maintaining the secrecy of your password and other subscription account information.
Information we learn about you that is readily available to the general public may not be subject to this Privacy Policy.
Where our Services contain links or references to third parties’ websites or content, it does not constitute an endorsement of such third parties or their privacy practices. Once you leave our Website or click on a link, we are not responsible for the privacy practices of third parties, and you should review the applicable third party’s privacy policy.
C. UPDATING/ACCESSING/AMENDING/CORRECTING YOUR PERSONAL INFORMATION
You are required to keep the information CycleEdge requests from you current. This is critical to our ability to provide you with the Services to which you subscribe. If your Personal Information changes, you may correct, update, or delete it by making the change on our Account Settings page, you may also deactivate your subscription account on our Account Settings page, or by emailing our Customer Support at sales@cycleedgecapital.com or by contacting us via postal mail at the contact information listed below. We will respond to your request within thirty (30) days. We will retain your Personal Information for as long as your account is active, as needed to provide you the Services to which you subscribe and as necessary and practical to comply with our legal and regulatory obligations as well as good business practices. If you are having trouble manually updating any of your Personal Information, or do not have access to the portal, please contact us at sales@cycleedgecapital.com or your designated sales representative if you are a subscriber for Institutional Use (defined in CycleEdge Terms of Service).
9. CONTACTING CycleEdge REGARDING YOUR PRIVACY
You may opt out of any communications by completing the “opt-out”, “unsubscribe,” or “email preference” function made available to you through the Services or our Communications. You may also opt out by notifying us via email at sales@cycleedgecapital.com. We reserve the right to send you notices necessary for us to deliver services commensurate with your subscription, or to collect payment related to any unpaid Services. Generally, you may not opt out of these communications, which are not promotional in nature.
If you have any questions regarding this Privacy Policy, please contact us at support@cycleedge.com.
Depending on your place of residence, you may have the right to (A) contact an applicable supervisory authority regarding any complaints you have about our processing of your Personal Information; (B) have your Personal Information deleted from our records, subject to applicable record-keeping requirements; and/or (C) make other inquiries relating to this Privacy Policy or our use of your Personal Information.
Please submit inquiries or requests regarding our Privacy Policy or practices or your Personal Information to sales@cycleedgecapital.com
10. ADDITIONAL INFORMATION FOR DATA SUBJECTS IN THE EUROPEAN ECONOMIC AREA (“EEA”), SWITZERLAND, AND THE UNITED KINGDOM (“UK”)
A. YOUR DATA PRIVACY RIGHTS
Under European data protection laws, data subjects in the EEA, UK, and Switzerland have the right to access or correct or receive a copy of any personal data that CycleEdge Processes about you. You also have the right to withdraw your consent for any data Processing that is based on your consent. In certain circumstances, you also have the right to request that we delete your personal data or object to or restrict our Processing of your personal data. To exercise any of these data privacy rights, please contact us at sales@cycleedgecapital.com or via certified letter at the postal address listed in Section 9 above. You may also correct, delete or update the Personal Information associated with your CycleEdge subscription account by visiting the Account Settings page.
Please note that we may not delete your Personal Information if: 1) it is still necessary in relation to the purpose for which it was collected, for example, to complete a transaction or to provide a service you requested; 2) it must be retained to comply with law, rule, regulation or industry standard (including email retention policies applicable to the certain financial service entities such as CycleEdge); or 3) it is necessary for the establishment, exercise or defense of legal claims. Where we are unable to delete Personal Information, we may anonymize it so that it can no longer be linked to you. We will retain an anonymized record of all requests for deletion in order to comply with our legal obligations.
CycleEdge Processes the Personal Information described above in connection with the following legal bases:
i. As necessary to perform or prepare a contract with you. For example, to provide you with subscription services and a subscription account, process payments, fulfill our commitments under and enforce our Terms of Service, and communicate with you to provide customer service.
ii. As necessary to pursue our legitimate interests or those of a third party, for example, our legitimate interests in providing and improving our services, protecting our Website, IT systems, and intellectual property, communicating with subscribers and others about our business and our Services, and other business purposes described in Section 1C above.
iii. In order to comply with our legal and regulatory obligations; or
iv. Where you have given your consent to processing, which may be withdrawn.
CycleEdge and its service providers Process information in the U.S. and other jurisdictions. If we transfer Personal Information from Europe or the UK to third parties outside of those jurisdictions, we will take measures, including through contracts, to ensure that the information continues to be protected wherever it is processed and in a manner consistent with the standards of protection required under applicable law.
If you have any questions or concerns about our Processing of your Personal Information, please contact us at support@cycleedge.com or via certified letter at the postal address listed in Section 9 above. If we cannot resolve your questions or concerns, you have the right to make a complaint with the Data Protection Authority where you reside. For data subjects in the European Economic Area, that information may be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For data subjects in the United Kingdom, the contact information for the ICO is available here: https://ico.org.uk/global/contact-us/#:~:text=You%20can%20call%20us%20on,contact%20us%20via%20live%20chat.
The California Consumer Protection Act (CCPA) grants California consumers specified rights relating to the Personal Information that businesses Process and requires that businesses provide certain information about Processing practices.
If you reside in California, you have the right to request: (i) that we inform you of the Personal Information we have collected, used, sold, and disclosed about you in the preceding twelve (12) months; (ii) that we delete the Personal Information we have collected from you unless certain exceptions apply; (iii) that we correct incorrect Personal Information we maintain about you; and (iv) that we refrain from selling or sharing your Personal Information. You also have the right to not receive discriminatory treatment for exercising the privacy rights conferred by the CCPA.
To exercise any of these privacy rights, or for more information about our privacy practices, please contact us at support@cycleedge.com or via certified letter at the postal address listed in Section 9 above. We will verify your identity using the email address you provided to us. If we do not maintain an email address for you, we will verify your identity using other Personal Information and may request additional information from you if necessary. You may have an authorized agent submit a request on your behalf. However, we will still need to verify your identity via the email address you provided to us. Please be advised that we cannot process your request if we cannot verify your identity.
We may not delete your Personal Information if it is necessary to: 1) complete the transaction for which the Personal Information was collected, provide a service you requested, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; 2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 3) Debug to identify and repair errors that impair existing intended functionality; 4) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 5) comply with an existing legal obligation; or 6) otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information. Where we are unable to delete Personal Information, we may anonymize it so that it can no longer be linked to you. Additionally, we will retain an anonymized record of all requests for deletion to comply with our legal obligations.
Over the last twelve (12) months, we have collected the following categories of Personal Information: Identifiers, Customer information, including information subject to Cal. Civ. Code Sec. 1798.80, Commercial Information, Internet or other electronic network activity information, Geolocation data, and Inferences. (For descriptions of each category, please see Section 1A above.) We Processed this Personal Information for the business purposes listed in Section 1C above.
Over the last twelve (12) months, we collected the following categories of Personal Information from the following sources and Disclosed it to the following categories of third parties to fulfill the business or commercial purposes listed in Section 1C above: (For descriptions of categories of Personal Information and third parties, please see Sections 1A and 4 above.)
Categories of Information
Categories of Sources
Categories of third parties disclosed to for the business or commercial purposes listed in Section 1C.
Identifiers
Consumers, Service Providers, advertising partners, publicly available sources, and institutional clients (if you receive the services as part of an institutional subscription).
Contractors and Service Providers (including operating systems and platforms, internet service providers), advertising partners, and data analytics providers.
Customer Information (including information subject to Cal. Civ. Code Sec. 1798.80(e))
Consumers, advertising partners, institutional clients (if you receive the services as part of an institutional subscription), and publicly available sources.
Contractors and Service Providers (including operating systems and platforms).
Commercial Information
Consumers, Service Providers.
Contractors and Service Providers (including operating systems and platforms), institutional clients, advertising partners, and data analytics providers.
Geolocation Information (non-exact location information derived from an IP address).
Consumers.
Contractors, Service Providers, data analytics providers, and advertising partners.
Professional or employment-related information
Consumers, institutional clients (if you receive the services as part of an institutional subscription), publicly available sources, and advertising partners.
Service Providers (including operating systems and platforms).
Inferences
Consumers.
Contractors.
Internet or other electronic network activity
Consumers, Service Providers, and advertising partners.
Advertising partners, data analytics providers, Contractors, Service Providers (internet service providers), and institutional clients.
Audio and audio-visual recordings.
Consumers (if you agree to appear in a CycleEdge broadcast, social media event, or similar event).
Service Providers. Displayed on CycleEdge’s website or social media consistent with the terms under which the recording was collected.
We may share commercial information and internet or other electronic network information with the institutional subscriber associated with your subscription (typically your employer or their affiliate), and selected third parties at their direction, but only where you receive the services as part of an institutional subscription through your employer or their affiliate and only when requested by the institutional subscriber. Where you post information on a blog or community forum (such as the “Arena”) that we provide, we will share that information with CycleEdge users and website visitors, but only to the extent that you make this information available in the forum. And, where you request that we introduce you to our affiliates or other third parties, we will share Identifiers, professional or employment-related information, and any other information that you request that we disclose to our affiliate or a third party.
CycleEdge values your privacy and we do not sell your Personal Information in exchange for money. CycleEdge has allowed advertising and analytics providers to collect information using cookies, pixels, and similar tracking technologies on our Website to display interest-based advertising and to provide analytics services in the last twelve (12) months. You may opt out of having your information shared for analytics and targeted advertising as described in Section 5 of our Cookie Policy https://app.cycleedge.com/legal/cookie_policy.
CycleEdge will not discriminate against you if you exercise any of your privacy rights. However, please be advised that we cannot provide you with the Services if you do not permit us to collect or process certain types of Personal Information.
CycleEdge processes account usernames and passwords solely to provide and maintain the security of customer accounts. CycleEdge does not process any other Sensitive Personal Information. CycleEdge does not sell, share, or disclose Sensitive Personal Information and does not use Sensitive Personal Information for purposes other than those specified in Section 7027, subsection (l) of the California Consumer Privacy Act Regulations.
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