NAPKIN FINANCE PRIVACY POLICY

Last Modified December 30, 2020

Our Privacy Commitment

CardBlanc, Inc. (the “Company,” “we,” “us” or “our”) is committed to respecting the privacy rights and concerns of all users of the Company’s www.delphivim.comwebsite where this Privacy Policy is posted (the “Site”) (we refer to the Site, the services and the software made available by the Company, collectively, as the “Company Features”).  As such, we have established and implemented this Privacy Policy to inform visitors to the Site and users of the Company Features how we use and protect the information we collect through the Site and/or the Company Features.  By visiting the Site or using any of the Company Features, you consent to the Company’s collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy.  This Privacy Policy is effective as of the date set forth above and is only applicable to the Site and the Company Features and not to any other website that you may be able to access from the Site or the Company Features which may have its own data collection and use practices and policies.

This Privacy Policy answers the following questions:

• What information do we collect about you and how do we use it?
• Will we share your personal information with third parties?
• What choices do you have about the collection and use of your personal information?
• What security measures do we take to safeguard your personal information?
• What are my rights as a resident of California or the European Economic Area?

What information do we collect about you and how do we use it?

Types of Information We Collect

Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access certain areas of the Site, but if you do not want to disclose certain personal information to us, you will not be able to access certain aspects of the Company Features.

We collect personal information when you create an account through the Company Features or receive customer or technical support. We also collect personal information when you post comments with respect to using the Company Features.

To create an account for the Company Features, we require you to provide certain information to create your account, including your name and email address. You will also need to create a screen name and a password. Other information you may provide to us when creating a profile using the registration form provided to you through the Company Features include age, gender, telephone number and hobbies. You may also be required to provide billing address and credit card or other payment information. No information of this type will be collected unless you have registered for services that require it or voluntarily submit such information to us.

By utilizing your Facebook log-in credentials or by linking your account with any social network account, you expressly authorize the Company to (i) receive, and for Facebook, and/or such social network to share, certain of your information that is available on or through your Facebook and/or such social network account including, without limitation, your profile information, friends’ names, photos, privacy settings and certain other information that may be disclosed to you (and authorized by you) during the log-in process; and (ii) allow you to interact with your Facebook and/or other social network friends. You also authorize the Company to generate and publish on your Facebook and/or other social network news feed or timeline actions you take when using the Company Features. If linked, you agree to allow Facebook and/or other social networks to receive information concerning the actions you take in the Company Features.

Through the Company Features, you may be able to link to technology, software and services owned and controlled by third parties (the “Third Party Features”), including our third party payment processors and vendor partners.  You may be permitted or required to submit personal information to access Third Party Features.  Such use of Third Party Features and submission of information through Third Party Features will be subject to such applicable third party’s terms of use, terms of service and/or privacy policy.  You agree to look solely to the applicable third party and not to the Company to enforce your rights in relation thereto.

How We Use Your Personal Information

The personal information you provide to us will allow us to provide the Company Features; alert you of new services, features, or enhancements to the Company Features; verify your identity and for fraud prevention; handle your customer service questions or issues; process payments; request feedback regarding the Company Features; engage in analysis, research and reports regarding the Site and the Company Features; comply with applicable law and protect the safety, right, property or security of the Company and other users of the Site and Company Features; and provide you with information regarding the Company and its products and promotions. We also use your email address as part of the Company Features in sending you messages about the Company Features and other general announcements.

We keep track of your interactions with us including, but not limited to, your activity within the Company Features. We may also use your personal information to contact you when necessary.

We may use your personal information with non-personal information that we have collected in a manner such that the end-product does not personally identify you or any other user of the Company Features.  We may make your personal information non-personally identifiable by either combining it with information about other users (aggregating your personal information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable.  This process is known as de-identifying your information.  You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your non-personally identifiable information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect in providing the Company Features (the “Analytical Data”). You expressly authorize us to make any commercial use of the Analytical Data including, without limitation, sharing the Analytical Data with third parties, provided that we do not sell, trade, or otherwise transfer from us any part of the Analytical Data that personally identifies you.

Cookies

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Site to allow us to provide information to make your online experience more convenient. For example, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are on subsequent visits, speeding up your experience of the Company Features.  You can learn more about Cookies and how we use them in our Cookie Policy.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, you browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Currently, there is no universally agreed-upon standard for what a company should do when it detects a DNT signal, and while we attempt to honor the request of “do not track” signals sent by your browser when you visit the Site, we cannot guarantee that we will be able to act on your DNT request.    You can learn more about Do Not Track here.

Children’s Privacy

This Site is not intended for use by children under the age of 16. We do not knowingly collect personal information from children under 16, or allow them to create an account for the Company Features. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times.  If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us at privacy@napkinfinance.com to request the deletion of that information.

Will we share your personal information with third parties?

Sharing of Information

We use your personal information to send communications to you about new services, features, or enhancements to the Company Features that may be of interest to you and to handle your customer service questions or issues.  We will also share the personal information we collect from you under the following circumstances:

• Protection of rights.  We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Service for the Company Features, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Company Features, or (iv) such action is appropriate to protect the rights, property or safety of the Company, its employees, users of the Company Features or others.
• Asset or equity transfers.  If we become involved in a merger, acquisition or other transaction involving the sale of some or all of the Company’s assets or equity, user information, including personal information collected from you through your use of the Company Features, could be included in the transferred assets.  You agree that we may transfer your personal information in the event of such a sale or transaction. 
• Service Providers.  We may share your personal information with service providers that we engage for the purpose of processing information on our and your behalf. This can include service providers such as credit card processors, email marketing vendors, or cloud service providers. Additionally, we may partner with other companies to process, analyze, and/or store data including, but not limited to, Analytical Data.  While providing services for us, these companies may access your personal information.  To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures, and such companies will be prohibited from using your information for any purpose outside of the services they provide to the Company.
• Your Posts.  The photos and comments uploaded and posted by you will be shared with other users of the Company Features.
• Facebook, Twitter, Instagram and other social media networks. We will share certain information with Facebook, Twitter, Instagram or other social media networks linked to your account for the purpose of creating news feeds and other social media activities related to your use of the Company Features, as described in more detail above in the section: “Types of Information We Collect.”

Additional Information You Should Know About Third Parties

The Site may contain direct links to websites operated by our marketing partners, social media organizations, and other entities, including links that describe certain Company Features being “powered by” the companies providing services in connection with such Company Features. We may receive certain personal information about you from these third party links, as set forth in this Privacy Policy.  We do not share your personal information with these third parties. However, these third party websites may collect information about you when you visit them or otherwise communicate with them.  This Privacy Policy does not cover the information practices of third party websites linked to the Site or accessible through the Company Features.  Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information.  You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

When you have clicked on a third party logo or URL displayed on our Site or accessible through the Company Features which links you to a different website, our Privacy Policy no longer applies and you must read the privacy policy of the third party to see how your personal information will be handled on their website.

What choices do you have about the collection and use of your personal information?

Control of Your Information

You may update or delete your personal information or modify your account preferences for the Company Features by accessing the account interface provided through the Company Features or by emailing us at privacy@napkinfinance.com.  Please note that when you delete your account, we may retain your account information for a reasonable period of time afterward for the purpose of internal account management and fraud prevention activities.

Opting Out of Receiving Communications from Us

If you no longer want to receive our emails or other announcements, you may unsubscribe by following the instructions provided through the Company Features (for example, using an “unsubscribe” link from an email message we have sent you).  Please note that you cannot unsubscribe from certain correspondence from us, including messages relating to your account transactions.

Mediation

You agree that, in the event any dispute or claim arises out of or relating to this Privacy Policy, you and the Company will attempt in good faith to negotiate a written resolution of the matter directly between the parties.  You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California with a mutually agreed mediator in an attempt to resolve the dispute.  Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorneys’ fees, even if you would otherwise be entitled to them.

What security measures do we take to safeguard your personal information?

The personal information that you provide to us is stored on servers located in the United States which are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information.  In addition, we restrict access to personal information to Company employees and agents who need to know this information in order to develop, operate and maintain the Company Features.  However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure.  As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the Company Features and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk.  Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

Your California Privacy Rights

This section of the Privacy Policy applies solely to California residents. We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Section.

Company collects certain types of personal information about you during your relationship with us, as stated above. In particular, our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months and has used this information to provide the services and Company Features:

within the last twelve (12) months and has used this information to provide the services and Company Features:

Category	Collected
A. Identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	YES
C. Protected classification characteristics under California or federal law.	YES
D. Commercial information.	YES
E. Biometric information.	NO
F. Internet or other similar network activity.	YES
G. Geolocation data.	YES
H. Sensory data.	NO
I. Professional or employment-related information.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NO
K. Inferences drawn from other personal information.	YES

California residents also have the right to request certain information that we collect about you, including:

1. The categories of Personal Information we have collected from you;
2. The categories of sources from which we collected the Personal Information;
3. The business purpose we have for collecting or selling that Personal Information;
4. The categories of third parties with whom we share such Personal Information;
5. The specific pieces of Personal Information we have collected about you;
6. The categories of Personal Information about you that we sold, and the categories of third parties to whom the personal information was sold, by category or categories of Personal Information for each category of third parties to whom the information was sold;
7. The categories of Personal Information that we have disclosed about you for a business purpose; 
8. The category or categories of consumers’ Personal Information that we have sold, or if we have not sold consumers’ Personal Information; and
9. The category or categories of consumers’ Personal Information that we have disclosed for a business purpose, or if we have not disclosed that information for a business purpose.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

As a California resident, you also have the right, at any time, to tell us not to sell your Personal Information – this is called the “right to opt-out” of the sale of Personal Information.  At the current time, we do not “sell” your information as that term is defined in the CCPA. 

You may make a CCPA request to us at the contact information below. We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice a year. Please include “California Privacy Rights” in the subject line. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. We may require additional information to verify your identity before we can respond. 

Email Address:  privacy@napkinfinance.com

Your Rights Under the General Data Protection Regulation

This section of the Privacy Policy applies solely to residents and citizens of the European Economic Area (“EEA”).  Residents and citizens of the EEA have certain additional data protection rights under the General Data Protection Regulation (“GDPR”).  For purposes of GDPR, Company acts as the controller of personal information received from you and the Company’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information the Company has collected and the specific context in which it is collected.  Company may collect and process your Personal Information for one of the following reasons: to perform a contract with you or because you have given us permission to do so.

Individual rights available under GDPR include: 

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You have the right to withdraw your consent at any time where Company relied on your consent to process your personal information.

You may make a written request to us at contact@napkinfinance.com to exercise these rights. We may require you to confirm your identity and your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time. We may require additional information to verify your identity before we can respond.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

International Transfers of Information

Because Company works with global companies and technologies, we may transfer, store, or process your Personal Information outside of the country in which it was originally provided.  This may include transfers to third parties, such as service providers or affiliated entities, who are located outside of the United States or the European Union, where data protection laws may not offer the same level of protection as those within the U.S. or EEA.  When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in plan to protect your Personal Information.  Our transfers of your personal data outside of the EEA are safeguarded by data processing agreements (“DPAs”) incorporating Standard Contractual Clauses or similar language.

Retention of Information

Company will retain your Personal Information only for as long as necessary for the purposes set out in this Privacy Policy.  We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.  Company will also retain certain usage data for internal analysis purposes.  Usage data is data collected automatically, either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).  Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security of the Site or to improve the functionality of the Site. 

For independent advice about data protection and privacy under GDPR, please contact the Information Commissioner’s Office (ICO).  The ICO oversees how businesses and organizations comply with data protection legislation in the UK.  Similar supervisory authorities may exist in your country, and you may make a complaint to them if you believe we have not handled your privacy request properly. 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Fax: 01625 524510

Email: casework@ico.org.uk

Website:  https://ico.org.uk

Notification of Changes

This Privacy Policy may change from time to time and we will post all changes on the Site.  Any changes become effective on the data posted.  If you do not agree to the changes in this Privacy Policy or the Terms of Service, do not use the Site.

Questions? Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at privacy@napkinfinance.com.

Terms of Use

Please read the Terms of Service governing the use of the Site and the Company Features. This Privacy Policy is expressly incorporated into and made a part of the Terms of Service.