This Privacy Policy describes the types of Personal Information that Becoming Bankcable may collect from all Users or that you may provide us when accessing and using our website located at becoming-bankable.com (“Site”), as well as users who access and use our Becoming-Bankable products and services (“Services”)(collectively, the Site and the Services are referred to as the “Platform”).

This Privacy Policy also describes our policies and procedures on the collection, use, maintenance, protection, and disclosure of your Personal Information when you access and use our Platform and tells you about your privacy rights and the choices you may have with respect to your Personal Information.

Please read this Privacy Policy carefully before accessing and using the Platform to understand our policies and procedures regarding your Personal Information and how we will treat it.

Capitalized terms not otherwise defined herein have the meaning outlined in our Website Terms of Use (www.becoming-bankable.com/terms-of-use) and our Becoming-Bankable End User Agreement (www.becoming-bankable.com/tandc).

Acceptance

By accessing and using our Platform, you agree to the collection and use of your Personal Information according to this Privacy Policy. If you do not agree with our policies, please do not download, access, or use the Platform.

Updates

We reserve the right to modify this Privacy Policy anytime by posting an updated Privacy Policy on the Platform. If we make changes, we will notify you by revising the date at the top of the policy. If we make any material changes, we may provide you with a notice on the Platform. You are responsible for regularly reviewing this Privacy Policy, and your continued use of the Platform after we make changes is deemed to be acceptance of the updated Privacy Policy. If any modification is unacceptable to you, you shall cease using the Platform. If you have any questions about this Privacy Policy or if you wish to exercise any of your rights under this Privacy Policy, you may contact us at info@becoming-bankable.com.

Personal Information Defined

“Personal information” means any information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, email address, records of products purchased, internet browsing history, geolocation data, and inferences from other personal information that could create a profile about your preferences and characteristics.

1. Personal Information We Collect About You

We may collect Personal Information from the following categories of sources: (a) directly from you; (b) indirectly/automatically from you; and (c) from third parties.

Personal Information We Collect Directly From You

While you are using our Platform, we may ask you to provide us with certain Personal Information about you that is necessary to provide you with our Platform or to provide services for you. You may also provide us with information about you while providing Feedback or requesting customer support, including the following:

• Contact Information. First and last name and address.
• Business Information. Business name, website, phone number, and address.
• Payment Information. If you purchase access to our Platform or any Third-Party Services through the Platform, we or the applicable Third-Party Services provider may receive access to your payment information, such as the credit card or bank account number you use to purchase such services.
• Financial Information. You may be asked and/or choose to provide financial information related to your business, such as revenue, debts, and other financial information necessary to assess your financial condition and to present applicable business products and services to.
• Mobile Device Information. If you access the Platform from a mobile device, we may access and receive information that you provide access to, such as your photos and location services.
• Communication Information. Any content of any communications you send and/or receive through the Platform or through other communication, such as email, to or from us.
• Customer Testimonials. Any customer testimonials and comments on the Platform, which you provide us through consent.
• Feedback and Support. Information you provide through our customer service helpdesk, including subjects, descriptions, request type, and attachments.

We will not ask or require you to provide sensitive information that is not required to provide the Platform. We will not ask for, and you should not provide us with, information regarding protected classifications, including: race, color, religion, age, gender identity, sexual orientation, marital status, medical condition, and disability information (as described under the appropriate state or federal law).

Information We Automatically Collect From You

While you are accessing and using our Platform, we may automatically collect certain information from you. This information may include:

• Your device’s internet protocol address (e.g. IP address), browser type, and version;
• Access date and time, pages of our Platform that you visit and the time spent on those pages, and other actions while using the Platform;
• The time you spend accessing the Platform;
• Geolocation data, such as the location determined from your IP address;
• When you access the Platform by or through a mobile device, we may collect certain information automatically, including the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data;
• Information about the device you use to access our Platform, including the hardware model, the type of mobile you use, operating system and version, unique device identifiers, and cookie data;
• Other diagnostic data.

The information we automatically collect from you is only statistical data and does not include Personal Information, but it may be combined and associated with Personal Information we collect in other ways. We use these technologies for several purposes, including enabling the use of the Platform, facilitating the functioning of the Platform, better understanding how you navigate through the Platform, and detecting and preventing fraud.

The technologies we may use for this automatic data collection may include:

Cookies (or browser cookies).  Cookies are small files placed on your computer’s hard drive when you access certain websites that record your preferences. We use cookies to track the use of and improve the Platform.

Web Browser Storage.  Some websites use your browser’s “sessionStorage” and “localStorage” to store data; “sessionStorage” is stored temporarily, but the “localStorage” is persistent. You may erase them by deleting your browser’s history.

Web Beacons.  Certain sections of our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs) that permit us to determine whether you performed a specific action, for example, if you visited our Platform or opened an email.

Third-Party Use of Cookies

Some content or services on the Platform are served by third parties, such as Third-Party Content. These third parties may use cookies, web beacons, or other tracking technologies to collect information about you when you access or use our Platform. The information they collect may be associated with your Personal Information, and/or they may collect information related to your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-party tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. You can opt out of accepting cookies (or browser cookies) by activating the appropriate settings on your browser or setting your browser to alert you when cookies are being sent. For more information about how to opt out of receiving targeted advertising from many providers, see the Network Advertising Initiative’s opt-out page and Google Ads setting page.

Website Analytics.  We use website analytics that track and report website traffic on our Site and the Platform (“Website Analytics”). Website Analytics collects information about how our Site performs and how our users navigate through and use the Site so we can improve our Site performance. We use Website Analytics as a third-party tracking service, but we don’t use it to track you individually or collect your Personal Information.

Website Analytics may gather certain non-personally identifying information over time, such as your IP address, browser type, internet service provider, referring and exit pages, timestamp, and similar data about your Site use. We do not link this information to any of your Personal Information, such as your account name or email address.

You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit Google Privacy & Terms.

Personal Information We Collect from Third Parties

We may collect Personal Information about you from other sources, including but not limited to: (i) Becoming-Bankable Partners through which you purchase or otherwise access Becoming-Bankable; (ii) Third-Party Services providers who provide or present you with products and/or services through Becoming-Bankable; and (iii) service providers, advertising networks, and other third parties that, to the extent permitted by applicable law, provide us with additional information about you.

The information we collect from third parties may include your name, account name, email address, phone number, business name, address, and other information you provide them in connection with your purchase, access, and use of the Platform and any related Third-Party Services provided on or through the Platform.

2. How We Use Your Personal Information

We use the Personal Information you provide, or we collect:

• To present our Platform to you;
• To provide and maintain the functionality of the Platform, including monitoring the usage of our Platform;
• To notify you about changes to our Platform;
• To allow you to participate in interactive features of our Platform when you choose to do so;
• To provide customer support;
• To provide you with news, special offers, and general information about other goods, services, and products that we offer that are similar to those you have already purchased or enquired about unless you have opted not to receive such information;
• For our internal business purposes, such as data analysis, audits, and so forth;
• To gather analysis or valuable information so that we can improve our Platform;
• To fulfill our obligations and enforce our rights arising from any contracts you entered with us;
• To monitor the usage of our Platform;
• To detect security incidents and protect against deceptive, illegal, or unauthorized activities;
• To comply with applicable law;
• To evaluate and/or conduct a divestiture, restructuring, dissolution, merger, or other transfer or sale of some or all of our assets;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

3. How We Share and Disclose Your Personal Information

Where permissible under applicable law, we may share your information in the following situations:

• With Service Providers. We may share your Personal Information with service providers, contractors, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• With Becoming-Bankable Partners. We share your Personal Information with Becoming-Bankable Partners to keep them informed about your use of the Platform, your interactions with us and Third-Party Services providers through the Platform, and any additional purchases made through the Platform.
• For Business Transfers. We may share or transfer your Personal Information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• As Aggregated Information. We may disclose aggregated information about our Users and information that does not identify any individual to our business partners or any other third party.
• To Enforce Our Terms of Use. We may disclose your Personal Information to enforce and administer our Website Terms of Use and/or End User Agreement and any other agreements we entered with you.
• To Protect Our Rights. We may disclose your Personal Information to protect the rights, property, or personal safety of our company, its employees, its members, and members of the public.
• For Legal Compliance. We may disclose your Personal Information to comply with applicable law, a court order, or legal process, including to respond to: (a) notices of intellectual property infringement, (b) claims that your actions or content uploaded by you to the Platform violates the rights of third parties, (c) government or regulatory requests, and/or (d) investigate the use of or respond to alleged violations or infringement of third-party content.
• With Your Consent. We may disclose your Personal Information for any other purpose with your consent.

4. How We Secure Your Personal Information

We use commercially reasonable technical safeguards to secure any Personal Information we collect about you. The secure server software (“SSL”) we use on our Site encrypts all information you input before sending it to our Site. The security of your Personal Information is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. If you have any questions about security on our Platform, you can contact us at info@becoming-bankable.com. 

5. How You Can Manage Your Personal Information

After receiving proof of your identity, you may request that we delete or change any or all of your Personal Information, if any, that we have stored about you (subject to certain exceptions). Requests should be emailed to info@becoming-bankable.com, and we will do our best to respond to your request within thirty (30) days of receipt.

Please note that the procedures outlined in this Section do not apply to Personal Information collected by Third-Party Services providers. To manage Personal Information collected by Third-Party Services providers, you must contact that applicable provider directly.

6. Retention of Your Personal Information

We may retain the Personal Information we have of you, if any, for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will also retain statistical data for internal analysis purposes for any period of time we choose unless we are legally obligated to retain this data for longer periods.

This Section does not apply to the retention of Personal Information by Third-Party Services providers. To learn more about the retention policies of Third-Party Services providers, you should contact the applicable provider directly.

7. Consent to Processing of Your Personal Information in the United States

Please be aware that your Personal Information may be processed by us (and third parties on our behalf) outside of your home country, including in the United States, where data protection and privacy regulations may not offer the same level of protection as privacy laws in your country. By accessing and using our Platform, you consent to the transfer of all information you provide to us in the United States. We will take all the steps reasonably necessary to ensure that your data is treated securely and according to this Privacy Policy, and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place, including the security of your Personal Information.

This section does not apply to Personal Information controlled by the applicable Third-Party Services providers purchased or accessed through the Platform. The collection and use of your Personal Information, including the location of such Personal Information, is determined according to the applicable policies of such Third-Party Services providers.

8. Opting-Out of Marketing Emails

We may provide you with marketing emails if you provide us with your email address and consent to the receipt of such messaging. If you no longer want to receive marketing emails from us, you may click the “Unsubscribe” link in an email, follow the instructions provided in any email we send, or contact us at info@becoming-bankable.com.

This section does not apply to marketing emails sent by Third-Party Services providers. To opt out of the receipt of emails and other marketing materials from Third-Party Services provider, you must contact the applicable provider and follow their instructions for opting out.

9. Third-Party Content

We may provide links to third-party websites or applications on the Platform, but this Privacy Policy does not apply when you access such websites. When you click on links that take you to external websites, you will be subject to their privacy policies, we have no control or responsibility over their data collection, use, or disclosure practices. If you access and transmit information to third-party websites, you do so at your own risk. You should carefully review the privacy policy of any third-party website you visit before using it or disclosing your Personal Information to its provider.

10. Third-Party Services

Users of our Platform have the option to purchase and use third-party services, including, without limitation, OwnersPath Business Success System (“OwnersPath”) and business coaching services provided by Mauch Consulting LLC dba Bankable Business Services (“BBS”) in partnership with ESBA through the OwnersPath Business Success System Additionally, you may have purchased access to the Platform through an authorized Becoming-Bankable reseller (“Partner”). Collectively, OwnersPath, BBS, our Partner, and any third-party services provider you provide Personal Information to through or related to the Platform are referred to as “Third-Party Services” in this Privacy Policy. Each Third-Party Services provider may have their own policies and procedures related to their collection and use of Personal Information, and this Privacy Policy does not apply to such collection and use by Third-Party Services providers.

11. Personal Information of Minors

The Platform is intended for individuals 16 years old or older. If you are under the age of 16, you may not access and use the Platform. If we learn or have reason to suspect that you are a User who is under the age of 16, we will have to remove you from the Platform. If you believe we might have any information from or about a child under the age of 16, please contact us at info@becoming-bankable.com.

SUPPLEMENTAL NOTICE TO CALIFORNIA RESIDENTS

Californian Users may have additional rights afforded them under California Privacy Laws (defined below).

12. Additional Definitions Applicable to California Privacy Laws

“CCPA” or “California Consumer Privacy Act” means California Civil Code § 1798.100 et seq.

“Consumer,” “Business,” “Sell,” and “Service Provider” will have the meanings given to them in the CCPA.

13. California Consumer Privacy Act (“CCPA”)

 If the processing of your Personal Information is subject to the CCPA, you have the right to:

• Request us to disclose the categories and specific pieces of Personal Information we collect, use, disclose, and sell;
• Know the categories of Personal Information that we collect and the purposes for which we collected or used such Personal Information, and whether that information is sold or shared;
• Know the categories of sources from which the Personal Information was collected;
• Know the categories of third parties with whom we share or to whom we sell your Personal Information;
• Know whether we collected or sold your Personal Information for business or commercial purposes;
• Request deletion of Personal Information we collected from you, subject to certain exceptions;
• Opt out of the sale of their Personal Information; and
• Not receive discriminatory treatment by us for exercising their rights set out in the CCPA.

14. Categories of Personal Information Disclosed for a Business Purpose

Personal Information may be collected, used, or disclosed for business and commercial purposes, including the following examples:

• To operate and improve our Platform;
• To provide you with our Platform, respond to your inquiries, and give you the necessary support;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Information or as otherwise outlined in the CCPA;
• For internal administrative and auditing purposes; and
• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

In the past 12 months, we have not disclosed any Personal Information for a commercial or business purpose.

15. Do Not Sell My Personal Information

As a California consumer, you have the right to opt out of the sale of your Personal Information. To make such a request, please contact us by email at info@becoming-bankable.com.

In the past 12 months, we have not sold your Personal Information.

16. California Requirements for Minors

If you are under the age of 16, you have the right to request and obtain the removal of content or information you have publicly posted under the California Business and Professions Code Section 22581. Be aware that your request does not guarantee the complete or comprehensive removal of content or information posted online, as the law may not permit or require removal in certain circumstances.

17. Do Not Track Features

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser. However, at this stage, there is no uniform technology standard for recognizing and implementing DNT signals. As such, we do not currently respond to or support DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

18. California’s Shine the Light Law

Under California’s Shine the Light Law, California Consumers may request the type of Personal Information we disclose to third parties for their direct marketing purposes and a list of those third parties (if any).

We have not disclosed Personal Information to third parties for direct marketing purposes.

To make any requests regarding your California Privacy Rights, please contact us by email at info@becoming-bankable.com.

SUPPLEMENTAL NOTICE TO INDIVIDUALS THAT RESIDE OUTSIDE OF THE UNITED STATES

The Platform is intended for use by Users located only in the United States. If you are located outside of the United States, please do not access or use the Platform. If you do so, we cannot guarantee that the collection, use, retention, or sharing of your Personal Information will comply with applicable data protection laws, such as the EU General Data Protection Regulation and similar laws of other countries and jurisdictions.

19. Contact Information

If you have any questions or complaints about this Privacy Policy or our handling of your Personal Information, please contact us at info@becoming-bankable.com.