USA Privacy Policy

Introduction

1. We at Curve respect your privacy and are committed to protecting your personal data. The purpose of this privacy policy is to give you a better understanding of:

  • what information we collect from you and why;

  • how we use your information;

  • how your information is stored and shared;

  • your rights; and

  • other useful privacy and security related matters.

2. We recommend you take the time to read this policy.

Data Controller

3. Curve US Inc of the State of Delaware, with offices at 175 Pearl Street Suite 309 Brooklyn NY 11201 is the data controller responsible for your personal data (collectively “Curve”, "we", "us" or "our" in this privacy policy). We are a US registered company.

Personal data we collect about you

4. Personal data means any information that can be used to identify you (either on its own, or when aggregated with other data). It does not include data where your identity has been removed completely or anonymised.

5. We also sometimes refer to “processing”. This means any operation we perform on your personal data, such as collection, organising, storing, updating, using, disclosing and deleting. When you become a Curve customer, we may process different kinds of personal data, which we have grouped together as follows:

Identity data: First name, last name.

Contact data: ZIP Code, and email address.

Marketing and communications data: Additional personal data you provide when you contact us, such as your social media handle, details of messages/ emails you send to Curve, your preferences in receiving marketing from us and communication preferences.

Third-party service data: When you connect your Curve account with a third-party service, your account username is held at the third-party service.

6. We also collect aggregated data such as statistical or demographic data. This may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How is your personal data collected

7. We use Direct interactions methods to collect personal data from and about you. You may give us your identity data, contact data, profile data, communications data and third-party service data by filling in forms on our Curve website, corresponding with us by post, phone, email support or otherwise.

As you interact with our website, we may also use automated technologies or interactions to automatically collect technical data about your electronic devices, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

How and why we use your personal data

8. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform any contract we have entered into with you;

  • where we need to comply with a legal or regulatory obligation; or

  • where it is necessary for our legitimate interests and only if your interests and rights do not override those legitimate interests.

Purposes and legal bases for which we will process your personal data

9. We have set out below, in a table format, a description of the purposes of our processing of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are processing your data.

Purpose/activity

Register your interest in Curve products, so that we can:

  • Inform you about our product launch;

Type of personal data

  • Identity data;

  • Contact data.

Lawful basis for processing, including basis of legitimate interest

  • Consent: if you have given clear consent for Curve to process your personal data for the specific purpose of keeping you informed about the new Curve product launch.

Curve communication and opting out

10.If you need help with managing the communications you receive from Curve (including marketing emails and mobile push notifications), please contact us at support-us@curve.app or via the Curve mobile application. You will also be able to unsubscribe from emails by clicking the “Unsubscribe” link in any email you receive from us.

Cookies

11. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

12. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile phone if you agree. Cookies contain information that is transferred to your computer's hard drive. We use session cookies which are cookies which expire once you close your web browser.

13. We use three types of cookies: strictly necessary, analytical/ performance and targeting cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including necessary cookies) you may not be able to access all or parts of our website.

Change of purpose

14. We will only use your personal data for the purposes and reason for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where this is required by law.

Sharing your personal data with third-party recipients

15. In order to fulfil the purposes for processing your personal data, as set out above, we need to share your personal data with a limited number of carefully selected third-parties.

16. We necessitate all third-party recipients to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-parties to use your personal data for their own purposes (such as marketing or reselling) and we only permit them to process your personal data for specified purposes and in accordance with our instructions.

17. We may disclose your personal data to the following categories of third-party recipients:

Hosting: We share your personal data with cloud storage providers to safely and securely store your personal data.

Analytic tools: We share your personal data with analytics and search engine service providers that assist us in the improvement and optimisation of the Curve product.

Administration and support tools: We share your personal data with customer support software providers.

Emailing: We share your personal data with emailing service providers.

Integrations: We may provide you integrations with third-party providers and we may share your personal data with them to provide you these services.

Business reorganisation/sale: We may share your personal data with third-parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

18. The majority of our third-party processors are based in the United States however, when your personal data is transferred outside the United States for further processing by the recipients described above, we ensure the right safeguards are implemented.

Data security

19. We have put in place appropriate and industry standard security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees who have a legitimate reason to view and process it.

20. All parties with access to your personal data are all subject to a strict duty of confidentiality.

21. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulatory bodies of any breaches where we are legally required to do so.

How long will you keep my personal data for?

22. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Your rights

23. Under the General Data Protection Regulation (GDPR), You, as a data subject have a number of rights which are detailed below:

24. Request access to your personal data that we hold about you (commonly known as a “data subject access request” or DSAR). This enables you to receive a copy of the personal data we hold about you or are otherwise processing.

25. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. We will need to verify the accuracy of the new data you provide to us.

26. Request erasure of your personal data that we hold about you. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

27. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

28. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

29. Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

30. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Contact

31. If you have any further questions or would like to exercise any of the rights set out above, please contact us at support-us@curve.app. We always welcome your comments or suggestions, including thoughts on how we can improve or clarify this privacy policy.

32. It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.

Other important information

You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.

In accordance with California law, we will not share information we collect about you with companies outside of Curve, unless the law allows.


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