Last Revised: November 10th, 2022
1. Your Consent
2. Which information we may collect on our Users?
We may collect two types of data and information from our Users:
2.1 Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”). When you use the Platform, like most platforms, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity, the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Platform, the activities of the User on the Platform and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We also use third-party service providers such as Mixpanel to obtain detailed analytics on the User's behavior on the Platform. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain technologies such as cookies, as further detailed below.
2.2 Personal Information. The other type of information we collect is individually identifiable information (“Personal Information”), including:
2.2.1 Personal Information which is provided consciously and voluntarily:
Third Party Service Credentials: when you wish to update your Card information on Third Party Services, you will be required to provide us with the relevant login credentials to such Third-Party Services’ accounts. We will process and use such credentials solely in order to provide you with our services, namely, to update the Card information on such accounts. Such information may include, as applicable, your full name, account name, e-mail address, phone number, password, security questions, etc.
Information derived from your use of our Services: when you use the Platform, we are aware of your actions and interactions within our Platform and may retain such information and derive additional information based on such information, such as your preferences and habits.
Communications with Sunlight: Personal Information you provide to us as part of any communications with Sunlight, by any means, including by contacting us via the Platform.
2.2.2 Personal Information provided via the App: when you use the Platform, we will obtain your credit/debit card information and certain associated information (such as your name, ID number, address, etc.) from your account on the App in which the Platform is integrated.
2.2.3 Personal Information collected via technology:
Identifiers: during your use of the Platform, we will access, collect, process, monitor and/or remotely store online and/or device identifiers, such as Internet Protocol (IP) and MAC address, or other unique identifiers, for statistical, security and metric purposes.
Geolocation data: while using the Platform we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your general location for analytics and security purposes.
Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 2.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
2.3 Please note: We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
3. How Do We Collect Information about Our Users?
There are a few main methods that we use in order to collect information:
3.1 We collect information through your entry and use of the Platform. In other words, when you are using the Platform we are aware of it and may gather, collect and store the information relating to such usage. For example, when you use the Platform, we gather your Technical and Behavioral Information.
3.2 We collect information which you decide to provide us voluntarily. For example, we collect Personal Information when you provide us with your Third-Party Service accounts’ credentials.
3.3 We collect information from the App in which the Platform may be integrated. When you use the Platform, we will receive from the App into which the Platform is incorporated certain information, including your credit/debit card information.
4. What are the Purposes of the Collection of Information?
4.1 Non-personal Information is collected in order to:
Provide you with our Services;
Create statistics, for research purposes and for customization and improvement of our Platform;
Enhance the User's experience while using the Platform; and
Keep the Platform safe and secured and for prevention of fraud.
4.2 Personal Information is collected in order to:
Provide our Platform and Services;
Respond to your inquiry;
Ensure that the content on the Platform is presented in an optimal way for you and for your device (e.g., tablet, mobile phone);
Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes and to improve the Platform and Services;
Keep the Platform safe and secured and for prevention of fraud and crime;
Comply with our legal obligations and in order to be able to protect our rights and legitimate interests; and
Maintain our data processing records and general administrative purposes.
When you access or use the Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies") which may enable us, amongst others, to recognize your device from those of other Users of the Platform, to improve the Platform's performance, to deliver a better and more personalized service according to our Users' individual interests and the device or browser used, to track Users' use of the Platform, to gather information about the Users' approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics and to develop our Platform and Services.
Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Platform may be limited.
For detailed instructions regarding the blocking of Cookies, please refer to your browser's 'help', 'tool' or 'edit' sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.
Please note that the Platform includes the Mixpanel analytics tool. You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/.
6. Sharing Information with Third Parties
Service Providers: Note, that we collect, hold and/or manage Personal Information through Sunlight's authorized third party vendors of certain products or services (such as, cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. For more information regarding our Service Providers, please refer to Section 10 below.
6.2 For avoidance of doubt, Sunlight may use Non-personal Information and transfer and disclose it to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of the Platform.
7. Your Rights
The Platform is intended for Users over the age of sixteen (16). We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using the Platform. Please contact Sunlight at email@example.com if you have reasons to suspect that Sunlight collected Personal Information from minors under the age of sixteen (16).
We take reasonable measures to maintain the security and integrity of our Platform and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. Sunlight will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach to the extent so required by applicable law. TO THE EXTENT THAT SUNLIGHT IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, SUNLIGHT SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.
10. Third Party Service Providers
While using the Platform we may be using third party service providers, who may collect, store and/or process your Personal Information, as detailed herein. Such third parties service providers include the following:
Cloud Services, such as Amazon Web Services.
Analytics Services, such as Mixpanel.
11. International Data Transfer
Generally, we will store and process your Personal Information solely within the United States. However, to the extent we will transfer such information from the United States to other countries or jurisdictions around the world, we will put in place the necessary safeguards under applicable law to facilitate such transfer, and you hereby consent to such transfer of information (in jurisdiction where such consent is required, to such transfer).
12. Data Retention
Sunlight will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
14. Additional Disclosures for California Residents
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
14.1 Notice of Collection. In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: (a) Identifiers, including name, email address, device push token and online identifiers; (b) Customer records, including contact details and account details and Third Party Services’ credentials; (c) commercial or transactions information, namely, Card information; (e) Internet activity, including Technical and Behavioral Information and interactions with the Platform; (f) Geolocation data; (g) Inference drawn from the above information about your predicted characteristics and preferences; (h) any personal data included in your communications with us. For further details, please review the Section “What information do we collect?” above. We collect and use these categories of personal information for the business purposes described in the “How do we use the information we collect?” above.
14.2 Sale of Personal Information. We do not “sell” your information, as such term is defined under the CCPA.
14.3 Your Rights. You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us: (a) The categories of personal information we have collected about you; (b) The categories of sources from which the personal information was collected; (c) The categories of personal information about you we disclosed for a business purpose or sold; (d) The categories of third parties to whom the personal information was disclosed for business purposes or sold; (e) The business or commercial purpose for collecting or selling the personal information; and (f) The specific pieces of personal information we have collected about you. In addition, you have the right to delete the Personal Information we have collected from you.
To exercise any of these rights, please submit a request to: firstname.lastname@example.org. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
15. Got any Questions?