Privacy Policy

The website PennyWorks.com (the “Site”) is brought to you by HybridFi Inc. ("PennyWorks","‘we", "us" or "our").

PLEASE READ OUR PRIVACY POLICY CAREFULLY.  BY ACCESSING AND USING THE SITE AND/OR OUR MOBILE APP (THE "APP"), YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SITE AND/OR OUR APP. 

This Privacy Policy provides information about our policies and procedures regarding how we collect, use, disclose and protect your personal information and your ability to control disclosure and opt-out (this "Privacy Policy").  It applies to the data we collect through any means, including, without limitation, information you provide to us, financial data, information about how you interact with us, including, without limitation, interactions through our Site and App.  By data, we mean any of your personally identifiable information or any other information regulated by law.  By personally identifiable information, we mean any information that can be used to distinguish or trace an individual's identity or any other information that is linked or linkable to an individual. 

If you are under the age of 18, you may not access or use our Site, App or Services (as defined below).  We do not solicit or knowingly collect data from individuals under the age of 18.  

This Privacy Policy is incorporated into, and a part of, our Terms of Use which govern your access to the Site and/or the App and/or your use of the Site, the App and/or of the Content (as defined in the Terms of Use) and the services made available on or through the Site and/or the App (collectively, the “Services”).  Unless otherwise defined herein, capitalized terms shall have the meanings assigned to such terms in the Terms of Use. 

ABOUT THIS PRIVACY POLICY AND OUR PRIVACY NOTICES 

The purpose of this Privacy Policy and our Privacy Notices is to let you know how we collect, use, disclose and protect your personal information and your ability to control disclosure and opt-out.

Note:  If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.  To learn more about your California privacy rights, see our California Privacy Notice.

INFORMATION WE COLLECT

A.  Information You Provide To Us.  When you visit our Site and/or App, we may collect your e-mail address if you provide it to us voluntarily in order to contact you about the Services.  While some requested information is optional, most is required for legal and security purposes.  In order to sign up as a registered user of our Services (“Registered User”) and access the User Restricted Areas (as defined in the Terms of Service), you have to create a user account and provide the following personal information to us during the registration process:  your name, your e-mail address, your phone number, physical address, date of birth, U.S. domiciliary status, social security number.  You may also provide to us voluntarily information about your investment profile, such as, income level, return expectations, net worth, investment experience, desired investment term, areas of investment interest, and additional information regarding your social media use, including preferred platforms and other information.  If you contact us by phone, email or other means, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us. Please note certain investments may be limited to accredited investors only and we may request information to verify your accreditation status.  We may also request supporting documentation such as proof of identity and proof of address to verify your identity in accordance with KYC/AML laws.  

Registered Users who use our Services to make an investment in securities featured on our Site and/or App will be asked to provide certain financial data, such as your bank account number and bank routing number.  This information is required to enable us or our payment processor, Plaid (see the Plaid Privacy Policy for more information on how that data may be used) and our banking partners, Mercury.com (Mercury.com Privacy Policy), to execute funds transfers and make subsequent investment disbursements to you.  We will also share information with North Capital, a registered broker-dealer who will perform KYC/AML and accredited investor status verification related to the offering, as well as certain transaction and processing of payments and will be subject to the North Capital Privacy Policy.  If you choose to use our referral service to invite a friend to the Service, we will ask you for that person’s email address or import your existing contacts, and automatically send an email invitation.  We store this information to send this email, to register your friend if your invitation is accepted and to track the success of our invitation service.

B.  Information Regarding Your Interaction With The Site And/Or Our App.  We collect additional information about how you interact with the Site and/or our App without identifying you as an individual (“Anonymous Information”), by using cookies.  For example, we receive certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring website addresses.  We may use Anonymous Information for any purpose at our discretion.  For clarity, Anonymous Information means information that is not associated with, or linked to, your personal information and does not permit the identification of individual persons.

C.  Details Regarding Your Transactions With Us.  We collect details regarding any transactions, engagement, contact or activity you have with us or otherwise with respect to your account including, without limitation, your investments.

D.  Information Regarding How You Use Your Phone.  Any mobile network you use, your IP address, operating system and the settings on your phone.

E.  Information You Give Us Permission To Access On Your Phone.  Information that you give us explicit permission to see, like your address book, photos, geolocation and data from your camera.

F.  Information From Social Networks And/Or Online Accounts.  Information and data from any accounts that you share with us, including, without limitation, your access credentials for those accounts.

G.  Cookie Information.  Information from cookies.  Read about how we use cookies, log data and how we respond to do-not-track signals below under the heading:  COOKIES; LOG DATA; HOW WE RESPOND TO DO-NOT-TRACK SIGNALS; YOU CONSENT TO OUR USE OF COOKIES.  

BY USING THE SITE, APP AND/OR SERVICES, YOU ARE AGREEING TO THIS PRIVACY POLICY AND CONSENTING TO THE USE OF TRACKING TECHNOLOGIES AS SET FORTH IN THIS PRIVACY POLICY. 

H.  Third Party Collection Of Website And/Or Mobile App Data.  We do permit third parties to collect information about Site and/or App visitors activities over time and across other websites and/or apps.  

HOW INFORMATION COLLECTED IS USED AND SHARED

A.  How We May Use Your Information.  We may use the information we collect from and about you on the Site, App or any other source (collectively, “Information”) for any of the following purposes: (i.) to operate the Site and/or App and provide the Services; (ii.) to respond to your requests and inquiries; (iii.) to contact you and to communicate with you about your use of the Services and your Registered User account; (iv.) to notify you about important changes to our Services, such as updates or revisions to this Privacy Policy or our Terms of Use, security announcements or other similar messages; (v.) to review Site and/or App usage and operations and to analyze and improve the content and functionality of the Site and/or App and our Services; (vi.) to provide you with information and materials about our products and services; (vii.) to address problems with the Services; (viii.) to protect the security or integrity of our Services, our Registered Users and our business, (ix.) to communicate with you regarding any investments which you have made in products offered on the Site and/or App; (x.) to market the Services through our Site, App, email, or other means; (xi.) to research and develop new services; and (xii.) to tailor the Site and/or App to your needs.  We may also use Information as may be deemed necessary or desirable, in our discretion, to satisfy legal obligations or for other purposes, including, without limitation, (w.) to search your record at immigration and fraud prevention agencies; (x.) to prevent illegal activities such as tax evasion, money laundering, and fraud; (y.) to investigate any potential violation of our Terms of Use and/or enforce our Terms of Use; and (z.) to satisfy any obligation with respect to any legal requirement, regulation and/or governmental request. 

B.  How We May Share Your Information.  We will not sell or lease your Information to any third party.  Except as otherwise expressly provided in this Privacy Policy, we will only share your Information: (i.) as required by law or regulation or as we believe in good faith that disclosure of such personal information is reasonably necessary to: (a.) satisfy any applicable law or regulation; (b.) to respond to claims and/or to comply with a judicial or administrative proceeding, court order, or legal process served on us; (c.) to protect and defend our rights or property, and/or the rights or property of our Registered Users, or third parties, as permitted by law; (d.) to detect, prevent, or otherwise address fraud, security or technical issues; and/or (e.) to enforce our Terms of Use; (ii.) with North Capital as is necessary for them to conduct certain compliance services related to “Know Your Customer” regulations and anti-money laundering and sanctions laws (your personal information will be subject to the North Capital's Privacy Policy); and/or (iii.) with (a.) anyone who works for us (including contractors) when they need it to do their job; (b.) our service providers that provide certain services to maintain and operate the Services and certain features on the Services and to conduct certain compliance services related to “Know Your Customer” and compliance with anti-money laundering and sanctions laws (e.g., we may use third parties to host the Site and/or App or operate various features available on the Site and/or App); (c.) database administrators, cloud computing infrastructure providers or email and SMS service providers; (d.) providers of client interface services such as our in-app chat service, (e.) providers of cyber security services, (f.) providers that send and manage email, analyze data, and provide search results; (g.) providers of advertising services (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time); (h.) anyone whom you provide explicitly permit us to share it with.  As with any other business, it is possible that in the future we could merge with or be acquired by another company.  If such an acquisition occurs, the successor company would have access to the Information, but would continue to be bound by this Privacy Policy unless and until it is amended.

ACCESSING, CHANGING OR REMOVING PERSONAL INFORMATION

If you are a Registered User, we urge you to review your personal information regularly to ensure that it is correct, complete and up to date.  We provide an easy way via your online account profile for you to access, correct, update or remove personal information that has previously been provided to us.  You can review your personal information and make any necessary changes at any time, by logging in to your Registered User account.  If you are unable to edit your personal information by logging into your Registered User account, please contact us for assistance at support@pennyworks.com.

OPTING OUT

We may also use your contact information to send you marketing and promotional messages.  If you do not want to receive such messages, you may opt out by following the instructions in the message.  Please understand that if you choose not to receive promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.  If you need assistance opting out, please contact us at support@pennyworks.com.

SECURITY OF YOUR PERSONAL INFORMATION

The security of your data is important to us.  When you enter sensitive information, such as financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).  We have implemented reasonable technical and organizational measures designed to deter unauthorized access to and use, destruction, modification, disclosure and accidental loss, of personally identifiable information we collect.  Regardless of the precautions taken by us or by you, no data transmitted over the Internet or any other public network can be guaranteed to be 100% secure.  We cannot ensure or warrant the security of any information you transmit to us and you provide all personally identifiable information via the Site and/or App at your own risk.  You are responsible for maintaining the security of your Registered User profile information, including, without limitation, your password and for any and all activities that occur under your account.  Do not share this information with anyone.  We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Site and/or App.  If you are sharing a computer with anyone, you should always log out before leaving a site or service in order to protect access to your personally identifiable information from other users.

NOTICE TO USERS IN THE EVENT OF A SECURITY BREACH

If a Registered User’s personal information is compromised as the result of a breach of security, we will use commercially reasonable efforts to attempt to notify affected users directly, or via the Site and/or App, of the breach if we determine that the information is sensitive, in accordance with this Privacy Policy and the Terms of Use, or as otherwise required by applicable law.

COOKIES; LOG DATA; HOW WE RESPOND TO DO-NOT-TRACK SIGNALS; YOU CONSENT TO OUR USE OF COOKIES 

Like most websites and apps, we use cookies.  

A.  Tracking Technologies.  Unique identifiers such as cookies (which are small text files stored locally on your computer that help store user preferences and may be html files, Flash files, or other technology), web beacons or clear gifs (which are small pieces of code placed on websites used to collect advertising metrics, such as counting page views, promotion views, or advertising responses, tags and scripts or similar technologies (collectively referred to as “Tracking Technologies”) are used by PennyWorks and our marketing, analytics, or other service providers to understand Site and/or App usage, help customize our content, offerings or advertisements on the Site and/or App, personalize your experience on the Site and/or App (e.g., to recognize you by name when you return to the Site and/or App, save your password in password-protected areas, or save your online settings), analyze trends, allow users to move between associated websites without logging into each site, and other purposes related to our management and administration of the Site and/or the App.  In many Internet browsers, you can choose to delete, disable, turn off or reject most Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature.  Additional information on deleting, disabling, rejecting or turning off Tracking Technologies may be available through your browser’s support feature.  Please consult the “Help” section of your browser for more information.  Please know that certain areas and features of our Site and/or App can only be accessed in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.  

B.   Log Files.  Log data collected on web servers supplies us with aggregate information about the number of visits to different pages on our Site and/or App.  We use such aggregate information to improve access to our content based on our visitors’ browsers and operating system types to make our content available to as many users as possible.  We do not link the “log data” collected to personally identifiable information submitted by users when participating in our activities.  This Privacy Policy covers the use of cookies by PennyWorks and does not cover the use of cookies by any advertisers.  Some of our third-party providers (e.g., third-party advertisers) may use cookies on our Site and/or App.  We have no access to or control over these cookies.

C.  How We Respond To Do-Not-Track Signals.  We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our Site and/or App.

D.  You Consent To Our Cookie Policy.  BY USING THE SITE, APP AND/OR SERVICES, YOU ARE AGREEING TO THIS PRIVACY POLICY AND CONSENTING TO THE USE OF TRACKING TECHNOLOGIES AS SET FORTH IN THIS PRIVACY POLICY.  

LINKS TO OTHER SITES

Our Site and App contain links to other websites.  The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party.  We do not exercise control over third party websites.  These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you.  Other sites follow different rules regarding the use or disclosure of the personal information you submit to them.  We encourage you to read the privacy policies or statements of the other websites you visit.  Please be aware that the terms of our Privacy Policy does not apply to these third party websites.

CHILDREN’S PRIVACY

This Site and App are not intended for, or designed to attract, children under the age of 13 and as such, we do not intentionally gather information from individuals who are under the age of 13.  Upon notification that a child under 13 has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records.

CA RESIDENTS PRIVACY RIGHTS SUMMARY

Under California law, we must provide California residents with a summary of their privacy rights.  California law requires us to inform you, at your request, (a) the categories of personal information we collect and the third parties we share that information with; (b) the names and addresses of such third parties; and (c) examples of the products marketed by such companies.  Additionally, California law requires us to allow you to control who you do not want us to share that information with.  To obtain this information, please send us your request by email at support@pennyworks.com.  When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share.  Your request should be labeled “California Customer Choice Notice”.  Please allow 30 days for a response.  There is no charge for controlling how your personal information is shared.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see the California Privacy Notice.

INTERNATIONAL VISITORS

PennyWorks and its servers are located in the United States, our services are directed towards the United States market, and our Privacy Policy has been prepared to comply with applicable United States law.  We do not serve non-U.S. persons.  If you are an international visitor, please do not use our Site, sign up for an account or provide personally identifiable information to us.  If you do provide your personal information on, or through, the Site and/or App, you are: (i) consenting to the transfer of your personal information from regions outside the United States to the United States which may not have the same data collection and protection laws as the country in which you reside; and (ii) consenting to the use of your personal information in accordance with this Privacy Policy. 

CHANGES TO THIS PRIVACY POLICY

As PennyWorks grows and changes, this Privacy Policy and our Privacy Notice may change with it.  If we do change our Privacy Policy and/or our Privacy Notice, we will notify you by (a.) sending an email to you to let you know of that a change has occurred and including our updated Privacy Policy and/or our updated Privacy Notice, as applicable, or (b.) posting a prominent notice on our website and/or mobile app and having you acknowledge and accept the updated Privacy Policy and/or Privacy Notice, as applicable.  We will also update the date and version number displayed.  

Any such changes or updates will be effective immediately upon posting on the Site and/or App.  Each time you use the Site and/or App, the current version of this Privacy Policy will apply.  You understand and agree that your continued use of the Site and/or App after we have made any such changes constitutes your acceptance of the most current Privacy Policy, as amended.  You can always refuse to accept the changes to our Privacy Policy by terminating your use of the Services.

CONTACT US

If you have comments, suggestions, questions, concerns or complaints about our Privacy Policy, please contact us by email at support@pennyworks.com, by phone at 848-420-8350, or by mail at:

HybridFi Inc.
221 River St.
9th Floor, Suite #9165
Hoboken, NJ 07030