Last Updated: May 16, 2017

This Privacy Statement (“Privacy Statement”) applies to Intelligration LLC’s (“Intelligration,” “we,” “our,” or “us”) Vestly™ mobile application and any other mobile applications that collect data and display or link to this Privacy Statement (collectively, “Mobile Apps”).

This Privacy Statement does not apply to:

  • websites, mobile applications, products, services or other environments that do not display or link to this Privacy Statement or that have their own privacy statements; or
  • information collected from you offline.

Our Privacy Statement explains how we and some of the companies we work with collect, use, share and protect information in relation to our Mobile Apps, and your choices about the collection and use of your information.

Our Privacy Statement applies to all visitors, users, and others who access our Mobile Apps (“Users”).

Information We Collect

We collect the following types of information:

Information You Provide Directly or Allow Us to Access

  • When you create an account with us, you give us your username, password, e-mail address and any other information requested when registering. Because our apps run on mobile devices, you can also choose to share your location data.
  • If you login to our Mobile Apps using your Facebook account, you can give us permission to obtain information from Facebook (like your birthday, e-mail address, friends or contacts). The information we get from Facebook often depends on your settings or Facebook’s privacy policies, so be sure to check those. Any information that you allow us to get from Facebook will be subject to this Privacy Statement.
  • When using our Mobile Apps, you can share certain demographic information in connection with incentive offers and contests (for example, gender, age, occupation, salary range, years of experience in the stock market). Sharing this information allows us to personalize and enhance your experience with our Mobile Apps.
  • Any other information you provide to us or give us access to relating to our Mobile App games and contests (for example, stock picks or device contacts).
  • With respect to some of our Mobile Apps, you may be allowed to post content, including photos, stock picks, comments and other materials (“User Content”), and to share User Content publicly. Please note, this means that other Users may search for, see, use, or share any User Content that you make publicly available through our Mobile Apps, consistent with the terms and conditions of this Privacy Statement and our Terms of Use (which can be found at
  • When you communicate with us (for example, send us an e-mail), we will have all the Information contained in your communications. For example, if you contact us or respond to our Mobile App-related e-mails.
  • When you use our Mobile App to send your friends SMS invitations, you give us permission to access your phone contact list and relevant information. We may then store and save the contacts that you send SMS invitations to in order to allow you to easily resend invites to your contacts and distinguish to which contacts you have not yet sent an invitation.

Inviting and Connecting with Friends

If you login to our Mobile Apps using your Facebook account and give us permission to access your Friends list, you can easily invite your Facebook friends to participate in our Mobile Apps and connect with your friends through our Mobile Apps and Facebook. In addition, with your permission we may access your device’s contact list so that you can easily invite your contacts to participate in our Mobile Apps and connect with your friends on our Mobile Apps.

Analytics Information and Device Data/Identifiers

  • We use third-party analytics tools to help us measure traffic and usage trends for our Mobile Apps. These tools collect information sent by your mobile device or our Mobile Apps, including web pages you visit, add-ons, and other information that assists us in improving our Mobile Apps. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
  • When you use a mobile device like a tablet or phone to access our Mobile Apps, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may deliver information to us or to a third party partner about how you browse and use the Mobile App, and may help us or others provide reports or personalized content and ads. Some features of our Mobile Apps may not function properly if use or availability of device identifiers is impaired or disabled.

How We Use Your Information

In addition to some of the specific uses of information we describe in this Privacy Statement, we may also use information that we receive to:

  • develop financial-related and trading-related algorithms and other automated procedures;
  • build stock portfolios and other financial products and services;
  • track your progress and/or placement in our Mobile Apps contests or games, and issue you related prizes and offers;
  • help you efficiently access your information after you sign in;
  • remember information so you will not have to re-enter it during your visit or the next time you visit our Mobile Apps;
  • provide personalized content and information to you and others, which could include online ads or other forms of marketing;
  • provide, improve, test, and monitor the effectiveness of our Mobile Apps;
  • develop and test new products and features;
  • monitor metrics such as total number of visitors, traffic, and demographic patterns;
  • diagnose or fix technology problems;
  • respond to your inquiries;
  • contact you regarding Mobile App games or contests in which you participate or consider participating;
  • automatically update our Mobile Apps on your device; or
  • use in any other ways specified by us at the time your information is collected.

Sharing of Your Information

We will not rent or sell your information to third parties outside Intelligration without your consent, except as noted in this Privacy Statement.

Parties With Whom WE May Share Your Information

  • We may share User Content and your information (including but not limited to, information from device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Intelligration is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve our Mobile Apps (including by providing analytics) and Affiliates’ own apps and services (including by providing you with better and more relevant experiences).
  • We also may share your information, as well as information from tools like device identifiers and location data, with third-party organizations that help us provide our Mobile Apps to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide their service under reasonable confidentiality terms.
  • We may also share certain information such as device identifier data with third-party advertising partners. This information will allow third-party ad networks to, among other things, to deliver targeted advertisements that they believe will be of most interest to you.
  • We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

Parties With Whom YOU May Share Your Information

Any information or content that you voluntarily disclose when posting to our Mobile Apps, such as User Content, becomes available to the public. Once you have shared User Content or made it public, that User Content may be re-shared by others. Further, when you have chosen to link to your Facebook account to our Mobile Apps, you can share your activity on our Mobile Apps on Facebook.

Change of Control

If we sell or otherwise transfer part or the whole of Intelligration or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and e-mail address, User Content and any other information collected through our Mobile Apps may be among the items sold or transferred. We will use our best efforts to ensure that the buyer or transferee will have to honor the commitments we have made in this Privacy Statement.

Responding to Legal Requests and Preventing Harm

  • We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards.
  • We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm.
  • Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

Storing and Protecting Your Information

  • Your information collected through our Mobile Apps may be stored and processed in the United States or any other country in which Intelligration, its Affiliates or Service Providers maintain facilities.
  • We use commercially reasonable safeguards to help keep the information collected through our Mobile Apps secure and take reasonable steps to verify your identity before granting you access to your account. However, [Intelligration] cannot ensure the security of any information you transmit to us or guarantee that information collected through our Mobile Apps may not be accessed, disclosed, altered, or destroyed.
  • Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to e-mails between you and Intelligration, at all times. Your privacy settings may also be affected by changes the social media services you connect to Intelligration make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

Your Choices About Your Information

  • Unsubscribe from commercial e-mail communications from us by clicking on the “unsubscribe link” provided in such communications. As noted above, you may not opt out of Service-related communications.

Links to Other Websites and Services

We are not responsible for the practices employed by any websites or services linked to or from our Mobile Apps, including the information or content contained within them. Please remember that when you use a link to go from our Mobile Apps to another website or service, our Privacy Statement does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our Mobile Apps, are subject to that third party’s own rules and policies.

How to Contact Us

If you have any questions about this Privacy Statement or our Mobile Apps, please contact us: Intelligration LLC, 1732 1st Ave, #29598, New York, NY 10128,

Changes to Our Privacy Statement

Intelligration may modify or update this Privacy Statement from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Intelligration or our Mobile Apps after any modification to this Privacy Statement will constitute your acceptance of such modification.