- Visit the website www.qure.finance (our "Website") and Our practices for collecting, using, maintaining, protecting, and disclosing that information.
- Download, access, or use the Qure.Finance mobile application (the "App", collectively with the Website, the "Services").
- Use any of Qure.Finance's investment advisory services or other finance tips and recommendations (the "Products"), which are accessible on the Services.
- On the Services.
- In email, text, and other electronic messages between you and the Services.
- Through mobile and desktop applications you download from the Services, which provide dedicated non-browser-based interaction between you and the Services.
- Us offline or through any other means, including on any other website operated by Qure.Finance or any third party including Our affiliates and subsidiaries; or
- Any third party, including Our affiliates and subsidiaries, including through any application or content (including advertising) that may link to or be accessible from [or on] the Services.
Children Under the Age of 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Services or through any of its features, register on the Services, make any purchases through the Services, use any of the interactive or public comment features of this Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If We learn We have collected or received personal information from a child under 18 without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under 18, please contact Us and We will endeavor to delete that information from Our databases.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see [Your California Privacy Rights] for more information.
Information We Collect About You and How We Collect It
In the course of operating the Services and providing the Products, We collect or receive the following types of information:
1. Personal Information
When you register to become a Client, you will be asked to provide Us with certain information about you, such as, your name, date of birth, Tax ID number, citizenship, visa information, home address, telephone number, email address, bank account number, bank routing number, bank account login credentials, bank name, employer name, employment status, job position, whether you are a "politically exposed person," whether you are a "control person" (pursuant to FINRA Rule 3210), annual income range, total net worth range, and other information as appropriate for Our legitimate business needs (collectively and together with information referenced in Sections 2 through 6 below, the "Personal Information"). We may also collect Personal Information when you voluntarily provide Us with Personal Information as a Visitor.
2. Nonpublic Personal Information
3. Initial Questionnaire Information
4. Card and Bank Information
5. Transaction Information
6. Geolocational Information
Certain features and functionalities of the Services may be based on your location. In order to provide these features and functionalities while you are using a mobile device, We may, with your consent, automatically collect geolocation information from your mobile device, wireless carrier, or certain third-party service providers. Such information is collectively called the "Geolocational Information." Collection of such Geolocational Information occurs only when the App is running on your mobile device. You may decline to allow Us to collect such Geolocational Information, in which case Qure.Finance will not be able to provide certain features or functionalities to you.
7. Other Information.
We may automatically collect or receive additional information about you, your use of Our Services, your interactions with Us and Our advertising, as well as information regarding your computer or other devices used to access Our Services (collectively, the "Other Information"). Such Other Information may include, but is not limited to, the following:
A. From Your Activity
- IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
- Browser type and language;
- Referring and exit pages and URLs;
- Date and time; and
- Details regarding your activity on the Services, such as search queries and other performance and usage data.
B. About Your Device
- Type of device;
- Universally Unique Identifier ("UUID");
- Advertising Identifier ("IDFA" or "AdID");
- Operating system and version (e.g., iOS, Android or Windows);
- Wireless carrier; and
- Network type (WiFi, 3G, 4G, or LTE).
We may, from time to time, ask you to participate in surveys on Our Services. Participation in these surveys is completely voluntary. These surveys may be conducted by Our third-party service providers. Such third-party service providers are authorized to use your information only as necessary to provide these services to us. We will use survey results to continue to improve the Services and the Products. We will use your personal information from Our surveys to send you information about Our products and services and about third-party products and services. We may combine your survey information with other data We have about you. We may also anonymize and aggregate the survey information and sell it to third parties.
Information Collected by or Received from Third-Party Sources
The technologies We use for this automatic data collection may include:
- Flash Cookies. Certain features of Our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on Our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of Our the Website [and Our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Qure.Finance, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but We may tie this information to personal information about you that We collect from other sources or you provide to us.
Information Collected by or Through Third-Party Advertising
How the Information is Used and Shared
You authorize Us to use the Personal Information, the Third-Party Information, and the Other Information (collectively, the "Information") to provide and improve Our Services and Products; to help Us improve the content and functionality of Our Services and Products; to provide trade recommendations; to advise you about your portfolio; to solicit your feedback; and to inform you about Our products and services and those of third parties.
You also authorize Us to use and/or share Information as described below.
- We will access, use, and share the Information as required to fulfill Our contractual obligations to you or subsequent requests for support by you
- To track your purchases, match your purchases with the Other Information We have about you and provide suggestions to you about potential product recommendations, services recommendations, trade recommendations, saving money, and other financial services and offers that We believe may help you;
- Qure.Finance, like many businesses, sometimes hires other companies to perform certain business-related functions on Our behalf. Examples of such functions include website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions. When We employ another company to perform a function of this nature, We only provide it with the information that it needs to perform its specific function. These companies are authorized to use your Information only as necessary to provide these services to us;
- We may share some or all of your Information with any other companies that We control, are controlled by, or are under common control with us;
- As We develop Our businesses, We might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, launch of a new subsidiary, dissolution, or similar event, the Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on Our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information;
- In an ongoing effort to better understand Our Clients, the Services, and the Products of Qure.Finance, We may analyze certain Information to compile information about Our Client demographics, interests and behaviors and to create data analytics on an aggregate basis. This aggregate information does not identify you personally. We may share this aggregate information with Our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Services, the Services and Our products and services to current and prospective business partners and investors and to other third parties for other lawful purposes;
- Qure.Finance may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Qure.Finance, (iii) act in urgent circumstances to protect the financial security of users of the Services or the public against fraud or other harm, or (iv) protect against legal liability;
- Qure.Finance may from time to time enter into agreements with third parties, such as employers or affiliate membership groups, pursuant to which the third-party may pay a portion or all of fees of its employees or members, and may on occasion make direct or indirect contributions to Qure.Finance account of its employees or members. This is generally implemented by distributed "promotional codes" that are sponsored by the employer or affiliate membership group. If you use the benefit provided by an employer or affiliate group, you consent to additional anonymized reporting with respect to the participation, contribution rates, engagement, etc., of the employees or members, and consent to personalized reporting (i.e., where you may be specifically identified) solely and exclusively to (x) confirm your use of Qure.Finance to your employer or affiliate membership group, and (y) if the employer or affiliate membership group makes a contribution to your Qure.Finance account, to confirm receipt of the specific amounts contributed. In addition, if the benefit the employer or affiliate group provides includes embedding the Qure.Finance experience in a broader experience hosted by the employer or affiliate, by using such benefit you consent to Qure.Finance embedding the Qure.Finance experience in the hosted experience, and understand that your Personal Information may be shared in order to implement the hosted experience; and
- We may share your Information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate market research data for Us which will not identify you personally. Such third parties will provide Us market research data to help Us better segment Our Client base and understand what products and services would likely work best for Our Clients.
Sharing of Your Information with Non-affiliated Third Parties
We will not share your Information with non-affiliated third parties that may use your Information to market to you, without obtaining your opt-in consent. For example, We may offer you with a product opportunity that requires Us to share your Information with non-affiliated third parties that may use your Information to market to you. We will obtain your opt-in consent to such sharing of your Information when We present you with the terms of such offer.
If you have opted-in for this kind of sharing of your Information, then you may: (i) choose to opt-out of such sharing by contacting Us at [support@Qure.Finance.com]; or (ii) request certain information regarding Our disclosure of your Information to such non-affiliated third parties by contacting Us at [support@Qure.Finance.com].
Accessing and Modifying Information Communication Preferences
If you have provided Us any Personal Information, you may access, remove, review, and/or make changes, by making the change(s) in your registered account settings page. If you experience difficulties, please contact customer support at [support@Qure.Finance.com]. We will respond to your request as soon as possible.
When you sign up for Our Services, We will send periodic emails to you regarding the Services or to tell you about services We believe will be of interest to you.
If at any time you wish not to receive any future newsletters or marketing communications or you wish to have your name deleted from our mailing lists, please follow the unsubscribe instructions included in these emails or contact Us at [support@Qure.Finance.com]. We will use commercially reasonable efforts to process such requests in a timely manner. Note however that as a user of the Services We and/or Our custodian(s) will send you administrative and transactional communications that are reasonably necessary to provide the Services, such as billing, brokerage or service notifications and you cannot opt out of receiving such communications.
We may also deliver notifications to your phone or mobile device. You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.
By providing your phone number you consent to Qure.Finance calling or texting you using an automated telephone dialing system and/or prerecorded messages, even if you incur charges for receiving such communications. For example, We may send you informational text messages to your mobile device. You can revoke your consent to receiving informational text messages at any time by replying "STOP" or following any other instructions included in these text messages.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
How We Protect Your Information
The security of your information is important to us. When you enter sensitive information (such as bank account information) in Our Services, We encrypt the transmission of that information using secure socket layer technology (SSL). We and Our custodian also use third-party ID verification to ensure Our users' true identities are validated.
We take commercially reasonable technical, administrative, and physical safeguards to protect 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 or the databases of the third parties with which We may share such information, nor can We guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to Us may not be secure, and you should therefore take special care in deciding what information you send to Us via email. If you have any questions about security on Our website, you can contact Us at [support@Qure.Finance.com].
We do not email you or send you other electronic communications to request nonpublic information or account information (such as username and password). If you receive an unsolicited email or other electronic communication that appears to be from Qure.Finance but you suspect it may be from some other source or fraudulent, please email Us at [support@Qure.Finance.com].
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits Our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) We disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which We shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to Us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with one the Services or Products, you have the right to request removal of unwanted data that your publicly post on the Products or Services. To request removal of such data, please contact Us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the on the Services, but please be aware that the data may not be completely or comprehensively removed from all Our systems (e.g. backups, etc.).
Qure.Finance does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser "Do Not Track" settings and/or signals.
CCPA Privacy Notice
The California Code of Regulations defines as "resident" as:
1. Every individual who is in the State of California for other than a temporary or transitory purpose and
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as "non-residents." If this definition of "resident" applies to you, We must adhere to certain rights and obligations regarding your personal information.
Federal Privacy Notice
Qure.Finance is required by federal law to provide consumers with information regarding Our collection and sharing of nonpublic personal information. Please see Our Privacy Notice for more information.
The Services and Products are intended for natural persons who are citizens or other lawful residents of the United States and who are located in the United States. The Services, the Products and their servers are controlled and operated in the United States. Please take notice that your Personal Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, country, or other governmental jurisdiction where the privacy laws may not be as protective as in your country of origin. If you are located outside the United States and choose to use the Services and/or the Products, you do so at your own risk.