Effective date: September 1, 2025
Welcome to Comingle. Comingle, Inc. (“Comingle”, “we”, “us” or “our”) respects the privacy of our website visitors and members (referred to as “you” or “your”). This privacy policy (as posted on our website www.comingle.us/privacy and as amended from time to time and effective as of the date posted) (“Privacy Policy”) describes the types of information we collect from you or that you may provide when you visit or use our comingle.us website (“Website”) use our mobile app, when and where available (“Mobile App”), or use our services (“Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. By “visitors” we mean visitors to our Website who are not yet customers, those who become customers, as well as those who do not become customers; whether you upload information to our Website, download it, or are merely visiting our Website. By “members” we mean the persons or companies who use our Services. This Privacy Policy applies to you as applicable to the category to which you belong. This Privacy Policy applies to the data collected by us, or those working on our behalf, through information you enter or from the data imported from sources authorized or approved by us. It does not apply to data collected through third-party websites, or to products, or services not approved by us. Use of our Services requires acceptance/consent to the privacy policy of Plaid (available here) and the privacy policy of Dwolla (available here), both of which are our Service Providers (as defined below).
By visiting our Website, using our Mobile App, or using our Services in any manner, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, process, share, retain, and transfer your information as described herein. If you do not agree with our policies and practices, your choice is to not use our Website, Mobile App, or our Services. Your use of our Website and our Services is at all times subject to our Terms of Service (available at http://www.comingle.us/terms and as amended from time to time and effective as of the date posted (the “Terms”)), which is incorporated by reference herein. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.
We are constantly working to improve our Website and Services and Mobile App, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates. Under certain circumstances, we also may elect to notify registered Users of changes or updates to this Privacy Policy by additional means, such as posting a notice on the Website or by sending you an email. Our Mobile App may require you to acknowledge your consent via a pop-up message and/or click-through box requiring your agreement to the amended Privacy Policy before you can proceed.
If you use the Website, or purchase or use our Services after any changes to the Privacy Policy have been posted, you agree to the new Privacy Policy. Our practices regarding information we collect now are subject to the Privacy Policy version in effect at the time we collect such information.
This Privacy Policy covers our treatment of your personal information. “Personal Information” generally refers to any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person. However, the definition of Personal Information may vary depending on the state or country in which you reside, and that state’s or country’s definition will apply to your Personal Information in the context of this Privacy Policy. Please see additional information below on the particular information we may collect.
Personal Information does not include information publicly available from government records or information excluded by applicable law. Personal Information also does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
We also may collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It also may include emails, text messages, or other electronic communications that you send to us separate from our Website or by way of our Service Providers (as defined herein). However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website or by another means as described above, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise. If, for example, you are applying for employment through our careers portal, either via our Website or offline, we or our Service Providers may obtain information from you and/or third parties about employment as part of a background check, among other information, as part of the application process.
Other than as stated herein, this Privacy Policy does not apply to information collected by 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 our Website. We are not responsible for the practices of sites linked to or from our Website, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.
We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for or use our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
We collect several categories of Personal Information from and about you as summarized below:
Identifiers
Demographic
Commercial information
Internet or other electronic network activity; device information
Professional or employment information
Other information
The Personal Information we collect through our Website, or from our representatives, business partners, Service Providers, affiliates, divisions, and subsidiaries may include the following:
At times, Our Website will provide access to our Careers Website portal, which has information about employment opportunities with us, and contains a link which directs you to our Service Provider’s website (but which may contain our branding) through which you can submit an application or other information for employment. This application will request certain Personal Information of you. The Career Opportunities Privacy Policy set forth at the end of this Privacy Policy applies to our Careers Website and information collecting/processing, in addition to this Privacy Policy. That Service Provider’s website has its own terms of use and privacy policy which you should review prior to submitting any Personal Information through that website. We may be provided your application, including some or all of the Personal Information (and other information) you submit.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:
We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, and/or, recognize you when you return to our Website.
The technologies we use for automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, IP address, and other technologies. We do not use cookies for advertising or tracking purposes. Each of these is discussed below.
Browser cookies are small files placed on the hard drive of your computer or mobile device. They may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Browser cookies are managed by the web browser (Chrome, Microsoft Edge, Safari, etc.) on your computer or mobile device. Different types of cookies which have different purposes are used on our Website.
Essential cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
Performance cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their site and whether your visit has led to the use or purchase of a Service from our Website, including the references for the Service purchased or used. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
Functionality cookies enable our Website to remember the choices you have made when browsing. For example, we can store your general geographic area (but not precise geolocation) in a cookie so that the Website corresponding to your geographic area is shown. We can also remember your preferences, such as the text size, font, and other customizable aspects of the Website. Functionality cookies also may be able to keep track of the products, pages, or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Some of our service providers are allowed to place cookies on our Website. Those companies also may provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.
At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Certain features of our Website may use local stored objects to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
We do not use any cookies for cross-site advertisement targeting or data monetization.
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party Service Providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from Service Providers like identity verification services for our fraud prevention and risk assessment efforts.
We use tools provided by Google as described below.
Google Analytics. We use, and/or some of our third-party Service Providers may use, Google Analytics or other analytics service to help us understand the use of our Website and Services. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Website and Mobile App to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such Service Providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.
For any comments, reviews, or other content regarding us that you post on our Facebook or other social media sites, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc. (collectively, “Content”), you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, publicly display, perform, publish, transmit, transfer, distribute, translate, reproduce, rearrange, edit, redact, modify, aggregate, summarize, abstract, adapt, and create derivative works of the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed.
If we permit you to post Content, by posting any Content, or submitting Content for posting, you agree to with the following “User Content Posting Guidelines”:
To the extent our Website contains areas where you can post or submit to be posted Content such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post or submit any Content that:
We use information, including any Personal Information, that we collect about you or that you provide to us for one or more of the following purposes:
We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.
We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and/or, (f) help you efficiently access your information after you sign in.
We may collect, use, and retain “sensitive” Personal Information as follows:
The Personal Information we collect through our Website, or from our representatives, business partners, Service Providers, affiliates, divisions, and subsidiaries may include the following:
At times, Our Website will provide access to our Careers Website portal, which has information about employment opportunities with us, and contains a link which directs you to our Service Provider’s website (but which may contain our branding) through which you can submit an application or other information for employment. This application will request certain Personal Information of you. The Career Opportunities Privacy Policy set forth at the end of this Privacy Policy applies to our Careers Website and information collecting/processing, in addition to this Privacy Policy. That Service Provider’s website has its own terms of use and privacy policy which you should review prior to submitting any Personal Information through that website. We may be provided your application, including some or all of the Personal Information (and other information) you submit.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:
We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, and/or, recognize you when you return to our Website.
The technologies we use for automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, IP address, and other technologies. We do not use cookies for advertising or tracking purposes. Each of these is discussed below.
Browser cookies are small files placed on the hard drive of your computer or mobile device. They may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Browser cookies are managed by the web browser (Chrome, Microsoft Edge, Safari, etc.) on your computer or mobile device. Different types of cookies which have different purposes are used on our Website.
Essential cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
Performance cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their site and whether your visit has led to the use or purchase of a Service from our Website, including the references for the Service purchased or used. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
Functionality cookies enable our Website to remember the choices you have made when browsing. For example, we can store your general geographic area (but not precise geolocation) in a cookie so that the Website corresponding to your geographic area is shown. We can also remember your preferences, such as the text size, font, and other customizable aspects of the Website. Functionality cookies also may be able to keep track of the products, pages, or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Some of our service providers are allowed to place cookies on our Website. Those companies also may provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.
At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Certain features of our Website may use local stored objects to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
We do not use any cookies for cross-site advertisement targeting or data monetization.
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party Service Providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from Service Providers like identity verification services for our fraud prevention and risk assessment efforts.
We use tools provided by Google as described below.
Google Analytics. We use, and/or some of our third-party Service Providers may use, Google Analytics or other analytics service to help us understand the use of our Website and Services. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Website and Mobile App to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such Service Providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.
For any comments, reviews, or other content regarding us that you post on our Facebook or other social media sites, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc. (collectively, “Content”), you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, publicly display, perform, publish, transmit, transfer, distribute, translate, reproduce, rearrange, edit, redact, modify, aggregate, summarize, abstract, adapt, and create derivative works of the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed.
If we permit you to post Content, by posting any Content, or submitting Content for posting, you agree to with the following “User Content Posting Guidelines”:
To the extent our Website contains areas where you can post or submit to be posted Content such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post or submit any Content that:
We use information, including any Personal Information, that we collect about you or that you provide to us for one or more of the following purposes:
We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.
We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and/or, (f) help you efficiently access your information after you sign in.
We may collect, use, and retain “sensitive” Personal Information as follows:
Our Services may include sending you Short Message Service (“SMS”) messages as described in this section, to which you hereby consent. We may deliver up to three SMS messages per day to your cellphone or other wireless device unless you communicate further with us and we need to or can respond, so message frequency may vary. Additionally, we may also contact you by SMS messages with billing and payment reminders, surveys, informational and service-related communications, including important security updates, about your membership, purchases, Website updates, conduct surveys, or informational and service-related communications, as well as for marketing and awareness purposes. You may request us to stop sending text messages by replying “STOP” to the SMS text message you received. After you send the SMS message “STOP” to us, we will send you a SMS message to confirm that you have been unsubscribed. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us, or by any reasonable means. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. For help, please reply to a text with HELP. Message and data rates may apply, depending on your cell phone plan. Carriers are not liable for delayed or undelivered messages.
We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:
Disclosures to Service Providers We may disclose your Personal Information to third parties for the purpose of providing or improving the Services to you. We may disclose your Personal Information to third-party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links), processing credit card payments, or managing our conferences and other events. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
Required Disclosures. Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process (e.g., subpoena), including, but not limited to, in order to respond to any government, regulatory, or licensing request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, service providers, or partners, or investigate and prevent violation of the law; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations or to investigate, prevent, or take action regarding suspected or actual illegal activities; (e) assist government enforcement agencies or to meet national or other security requirements; (f) to protect the security or integrity of our Website, Services, or Mobile App; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others. We will attempt to notify you, where reasonably practicable, about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law or regulation, or (ii) we believe that providing notice would be futile, ineffective, create a risk of harm to an individual or group, or create or increase a risk of acts of fraud done upon us or our users. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
We may share De-Identified Personal Information with third parties for any purpose except as prohibited by applicable law, including, but not limited to, the following. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content.
You consent to (and shall not object) our disclosure, transfer, assignment, and/or sale of your Personal Information, De-Identified Personal Information, and other information you provide to us, as well as the rights you have granted or consented to in this Privacy Policy (collectively, “Transferred Information”) to a potential or actual buyer or acquirer of assets or equity of our company or other successor for the purpose of considering or undergoing a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.
We have implemented technical, administrative, and organizational security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, destruction, alteration and disclosure. Your Personal Information is stored behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website and Mobile App software are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website, software, and Mobile App safe.
Any payment transactions involving credit or debit cards will be performed using our third-party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.
Our agents, contractors, Service Providers, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us, or as permitted pursuant to our agreement with them.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, or hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. Please help keep your account safe by using a strong password, or, better yet, a strong pass phrase. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that your account has been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
The safety and security of platform login information also depends on you. You are responsible for keeping confidential all login credentials to our Website to which you are provided access. You agree to not disclose any such login credentials with any third party. If you become aware of any potential compromise of your login credentials, you must immediately change the relevant password. You agree to and do hereby release and forever discharge us and our affiliates, subsidiaries, parents, officers, directors, employees, successors, assigns and contractors (collectively, “Company Group”), and you will indemnify, defend, and hold Company Group harmless, from any and all past, current, and future liability, claims, demands, damages, losses, fines, penalties, assessments, private rights of action, or other actions, of whatever kind of nature, either in law or equity, as well as costs (including, but not limited to, attorneys’ fees and costs), which arise from any failure of you to maintain the security of your email or other accounts which results in unauthorized access by a third party to such account and the transfer of funds by us in reliance of instructions purporting to originate from you.
In general, our retention of Personal Information is reasonably necessary and proportionate to achieve the purposes for which the Personal Information was collected or processed, or for another disclosed purpose that is compatible with the context in which the Personal Information was collected, and not further processed in a manner that is incompatible with those purposes. The time period for which we retain your Personal Information depends on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a registered member or account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration. We will also retain Usage Data for analytics purposes. “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service 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 or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Following termination or deactivation of your user account, we may retain your information and all User Content you posted to public areas of the Website (where allowed). , but will maintain it in accordance with this Privacy Policy, the Terms, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination or deactivation of your user account without notice to you.
We may retain De-Identified Personal Information for as long as we deem appropriate.
Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Mobile App, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
The following in this section applies to California residents, but certain aspects may also apply to residents of Virginia or of other states, depending on your state’s laws.
CalOPPA applies only to companies which collect Personal Information of California residents.
CalOPPA requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on DNT, see here. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
You can visit our Website anonymously by adjusting the settings in your browser.
We do not allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ click and/or browsing patterns.
By providing us with your phone number and/or email address , you consent to our sending you Service-related notices, including any notices required by law (e.g., notice of data privacy or security incidents), by email, text, or by calling you, in lieu of communication by postal mail. You also agree that we may send you notifications by email, phone, or text, of activity regarding our Services, the Website, the Mobile App, your Personal Information, or any aspect of our relationship, to the email address or phone number you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
If you have any questions about this Privacy Policy or our privacy practices, please contact us: by email at comingle+privacy@comingle.us, or by phone at 1-805-334-0178.
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. You consent to our and our service providers’ transmission, processing, and/or transfer of your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
If you are a citizen or resident of the UK, European Economic Area (“EEA”), Switzerland, or other countries or regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff, contractors, or Service Providers operating outside the countries who work for us.
If you are a resident of a country other than the United States, you acknowledge and consent to our (and our Service Providers) collecting, transmitting, processing, transferring, and storing your Personal Information out of the country in which you reside.
