Privacy Policy

Our Commitment to Privacy

Paperclip, a Gerald Technologies, Inc. (Gerald) service, knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy easy to find, we make it available from the home page of the Paperclip website at hellopaperclip.com (the "website") and through our mobile applications. You may also email us at privacy@hellopaperclip.com with any privacy-related questions you have.

Applicability of Privacy Policy

This privacy policy applies to all information we collect through our Services from current and former Paperclip users, including you. "Services" means any products, services, content, features, technologies, or functions, and all related websites, mobile apps, other applications, extensions, and services offered to you by Gerald Technologies, Inc. in connection with a Paperclip account. When you are no longer our customer, we continue to share your information as described in this policy. This policy only applies to the Services and does not apply to the practices of any other Gerald Technologies, Inc. service.

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information any information that has been aggregated and/or anonymized so that it does not identify a specific user.

The Information We Collect

When you visit the website or use one of our mobile applications or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service.

If you open a Paperclip account, we may collect the following information from you:

• Account Information text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
• Identification Information your name, street address, email address, date of birth, phone number, SSN (or other governmental issued verification numbers), and other information you share during the registration process.
• Device Information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, keystrokes, application and website activity, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
• Credentials for your access to Gerald and connected third party websites. 
• Transaction Information and Retail Information from the retail sites you visit, including the pages you visit, the product information you view, and transactional information about the purchases you make through the Services. We may also collect limited information regarding your purchases on a retail site while using Paperclip (for example, the order total and the fact that an order was completed) for purposes including internal analytics, commission collection, and rewards programs we establish for Paperclip.
• Geolocation Information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to share your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
• Financial & Insurance Information bank account online login information, bank account and routing numbers, and credit cards linked to your Paperclip account, bank transaction information, insurance account information, insurance account credential, employer information, as well as other information that you directly give us on our site. Gerald does not share financial information with third party social networking services such as those listed in the prior bullet.
• Publicly Available Information we may gather information about you from government databases and from online sources.
• To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to us exercising your data rights. If we are unable to verify your identity or ownership rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents.
• We may collect information about you from service providers who help us verify your identity and/or supplement the information you have provided and ensure the accuracy of your information. For example, we use third-party service providers to validate your mailing address, phone number or provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider or email provider.
• Other Information in such cases we always transparently ask you to provide your information at your disposal and we always define the purposes of using that information in advance (e.g., name of the company you work for, your job title or position or information about your dependents etc.)

We are committed to providing a safe, secure and all around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.

Information from Children

The Services are not for use by children under 18.  The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us at privacy@hellopaperclip.com if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

How We Use Cookies

When you visit or use our Services, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer; customize Services, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our Services.

Certain Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of certain Services may be limited or not possible.

Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

How We Protect & Store Personal Information

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Paperclip password with anyone.

If Gerald learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that Gerald may communicate with you electronically. Gerald may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@hellopaperclip.com.

How We Use the Personal Information We Collect

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

• provide the services and customer support you request;
• provide you with personalized product advertisements and marketing; 
• enable you to use third party credentials to connect to third party apps and websites;
• process transactions and send notices about your transactions or your network activity;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially fraudulent, prohibited or illegal activities, and enforce our Terms of Use through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Transaction Information, Social Web Information and Geolocation Information;
• create an account connection between your Paperclip account and a third-party account or platform;
• customize, personalize, measure, and improve our services and the content and layout of our website;
• send you updates about new products and services that we are offering to customers;
• make our products, services and websites better;
• to track price changes and update our product catalog;
• compare information for accuracy and verify it with third parties;
• perform other duties as required by law; and
• if you elect to share your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content. 

Analytics Services and Targeted Ads

We use third-party analytics services. These services may track details about your online activities over time and across different sites. These services help us to improve our Service and the products and services that we offer you. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities. If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the Network Advertising Initiative or the Digital Advertising Alliance.  You may opt-out of Google Analytics collection by downloading the browser plugin “Google Analytics Opt-out Browser Add-on” here.

How We Share Personal Information Within the Gerald Network

To process payments on Paperclip, we need to share some of your personal information with the company that you are paying. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to companies when you transact with, on, or through Paperclip. 

We work with vendors to enable them to accept payments from you using Paperclip. In doing so, a vendor may share information about you with us, such as your mobile phone number, email address, or Paperclip username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a Paperclip customer and that the vendor should enable Paperclip as a form of payment for your purchase.

Regardless, we will not disclose your credit card number or bank account number to anyone you have paid through Paperclip, except with your express permission or if we are required to do so to comply with a subpoena or other legal process. 

When we collect credentials for third party applications connected to our Services, we store and process those credentials using a third party service. 

How We Share Personal Information with Other Parties

Gerald does not share your personal information with third parties for their promotional or marketing purposes.

We may share your personal information with:

• Our parent company, Gerald Technologies, Inc., and affiliates and subsidiaries it controls, but only for purposes allowed by this document.
• Third-party companies that integrate with our Services to provide you with third-party offers, products and services ("Platform Partners").  If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct Gerald to share your information, including personal information, to the Platform Partner providing the service or offering. In some cases, if you click through to go to a Platform Partner’s site, you will automatically be sending your personal information to that Platform Partner. When this happens, you will still have to submit your application on the Platform Partner’s site. Remember that any information you provide to a Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions
• Companies that Gerald plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
• Law enforcement, government officials, or other third parties if Gerald is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Paperclip Terms of Use, or as otherwise required by law.
• Third-party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendors behalf.
• Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, advertising, marketing, customer service, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
• Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
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Gerald does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of Gerald and is subject to the terms of use and privacy policies of such third parties.

We may disclose “blinded” aggregated data and user statistics to prospective partners and other third parties.  Blinded data is data that does not identify an individual person.

Co-Branded Areas

We may provide certain parts of our Service in association with third parties, such as promotional partners. These co-branded areas will identify the third party. If you choose to use these co-branded areas, we may share your information with the identified third party, and that third party may also collect information from you, in addition to the information that we collect, as described above. You should review the privacy policies of those identified third parties to understand how they collect and use information.

Third-party Sites & Services

Interactions With Other Sites & Services

Our Service may allow you to use your account from other online services. If you use accounts from other services on our Service, those third parties may share information about you with us, and we may share information that we collect with them. Our Service may also include features from third parties that allow you to interact with other online services, including social media. For example, we may use third parties to allow you to send messages, tweets, or make postings on social media sites, like Facebook. If you use these features, then we may share information about you with those third parties, and they may collect additional information. You should review the privacy policies for such third parties to understand how they collect and use information.

Links To Third-Party Sites

Our Services may contain links to (or allow you to link to) other third-party services or websites. Gerald does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information.

Third-Party Tracking And Do Not Track

Third parties may use tracking technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites. This Policy does not apply to these third-party technologies because we may not control them and we are not responsible for them. Do Not Track is a technology that enables users to opt out of tracking by websites they do not visit. Currently, we do not monitor or take any action with respect to Do Not Track technology.

How You Can Access or Change Your Personal Information

You can review and update your personal information in your account settings at any time by logging in to your account.

If you want to stop using our Paperclip Extension, we have provided instructions on how to do so [here].

Changes to Our Privacy Policy

Gerald Wallet is always improving. As the Services evolve we may occasionally update this privacy policy. If we modify this privacy policy, we will post the revised privacy policy to the website, and we will also revise the "last updated date" stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our mobile application or website or by sending you an e-mail. It is your responsibility to periodically review this privacy policy; users are bound by any changes to the privacy policy by using the Services after such changes have been first posted.

How to Contact Us

If you have questions or concerns regarding this privacy policy, or any feedback pertaining to your privacy and the Services that you would like us to consider, please email us at privacy@hellopaperclip.com.

California Consumer Privacy Act Notice

In this notice, we are addressing specific disclosure requirements under the California Consumer Privacy Act of 2018 for California residents. This notice should be read together with the Paperclip Privacy Policy and applies to all California residents who visit our Sites or use the Services.

California Residents Privacy Rights

We may from time to time elect to share certain information about you collected by us on the Service with third parties for those third parties direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. California residents have rights to request access to certain personal information collected about them over the past 12 months, or deletion of their personal information, subject to certain exceptions, and may not be discriminated against because they exercise any of their rights under the California Consumer Privacy Act. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2020 will receive information about 2019 sharing activities) or to request to opt-out of such future sharing. To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. We may require you to provide additional personal information to verify your identity before we process your request; we may not process your request if we are unable to verify your identity. You may make this request in writing at privacy@hellopaperclip.com. We will not discriminate against you for exercising any of your privacy rights. We will also be modifying this policy to comply with the new California Privacy Rights Act ("CPRA") so check back for updates.  

To learn about the categories of personal information that we use, please see the section of this policy called “The Information We Collect.” The personal information that we have collected in the past 12 months falls into the following categories as set out under California law:

• The contact information you provide (identifiers).
• If you shop through the Paperclip mobile app or extension, other individual information like billing address, credit or debit card information – this category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories.
• We don't track your location, but your IP address gives us a general idea of the city, state, and country (geolocation information).
• Shopping and Paperclip usage data – (internet activity).
• Purchases on sites when using Paperclip (commercial information).
• Financial and Insurance information (financial information).

To learn about the limited ways in which we disclose data for our business purposes -- that is, to a service provider -- and the categories of those service providers, please see the section of this policy called “How We Share Personal Information with Other Parties”

Please note that, while we provide tools to manage your privacy as described in this policy, we do not support “Do Not Track” browser settings at this time.

California residents also have the right to request this information in an accessible alternative format. If you have a disability and would like to access this privacy policy in an alternative format, please contact us by email or mail as detailed below.

Nevada Privacy Rights

Opt-Out Requests

Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your personal information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your personal information should we change our practices in the future, you must send a request by e-mail at privacy@hellopaperclip.com.  Make sure to state that you are a Nevada resident.   

How to Contact US

If you need further assistance, please send an e-mail with your questions or comments to privacy@hellopaperclip.com or write us at: 

Gerald Technologies, Inc.

Attn: Privacy 

245 8th Avenue, #1085

New York, NY 10011

©2022 Gerald Technologies, Inc.

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