INTELLIGRATION LLC PRIVACY STATEMENT

Last Updated: December 31, 2019

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.

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”).

IF YOU ARE A CALIFORNIA RESIDENT, this Privacy Statement also informs you about the personal
information we collect from and about you in other contexts, including personal information collected
online and offline in connection with our services and your interactions with us. California residents can
learn more about the personal information we collect from and about you, including how we may use
and share it, as well as your rights under California law, in the Privacy Statement’s Supplemental Notice
for California Consumers below (which is incorporated in and a part of this Privacy Statement).

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 vestlygame.com).
  • 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.

 

California residents can learn more about the personal information we collect from and about you,
including personal information collected online and offline, in the Supplemental Notice for California
Consumers below.
DO NOT TRACK (DNT): DNT is a concept that has been promoted by regulatory agencies such as the U.S.
Federal Trade Commission (FTC) for the Internet industry to develop and implement a mechanism for
allowing Internet users to control the tracking of their online activities across websites by using browser

settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet
browsers, technology companies, and regulators to develop a DNT technology standard. While some
progress has been made, it has been slow and no standard has been adopted to date. As such, we do
not generally respond to "do not track" signals.

 

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.

California residents can learn more about how we use the personal information we collect from and
about you, including personal information collected online and offline, in the Supplemental Notice for
California Consumers below.

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.

California residents can learn more about how we share the personal information we collect from and
about you in the Supplemental Notice for California Consumers below.

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.
  • Send an email to optout@vestlygame.com to opt-out of your data being shared with any third parties.
  • Send an email to delete@vestlygame.com to delete your account.

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.

MINORS

Our online services are not intended for or designed to attract children under the age of 13. Moreover, we do not knowingly collect any personally-identifiable information from anyone under the age of 18 without the consent of a parent or guardian, and you must be 18 years of age or older to submit any information to us.

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, vestly@intelligrationllc.com.

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.

INTELLIGRATION LLC PRIVACY STATEMENT
Supplemental Notice for California Consumers
Last Updated: December 31, 2019

What?

This Supplemental Notice for California Consumers (“Supplemental Notice”) is part of the Privacy Statement and supplements the information contained in the Privacy Statement. This Supplemental Notice applies solely to individuals who are residents of the State of California.

The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personal information Intelligration collects about them (online and offline) and whether this information is shared with third parties, as well as certain rights regarding Intelligration’s collection and use of their personal information. This Supplemental Notice provides the information required under the CCPA. Any terms defined in the CCPA have the same meaning when used in this Supplemental Notice.

Personal Information

In this Supplemental Notice, “personal information” (or “PI”) means any information that identifies, relates to, describes, or is capable of being associated with you or your household, whether directly or indirectly. In the chart below, we use the following Categories of Personal Information to describe the personal information we collect, use, and share about California consumers:

Commercial Information
Commercial information, including records of personal products or services used, stocks chosen, or other purchasing or consuming histories or tendencies.

Education Information
An individual’s education information, such as education level.

Financial Information
Financial information, including bank account number, credit or debit card number, or other financial information.

Identifiers
Identifiers, such as a real name, alias, postal address, date of birth, unique personal identifier, online identifier (e.g., social media usernames), internet protocol (IP) address, email address, account name, or other similar identifiers.

Inferences
Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies).

Geolocation Data
An individual’s precise geolocation data.

Network Activity Data
Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with our Mobile Apps.

Professional Information
An individual’s professional or employment-related information, such as job description and income range.

Protected Characteristics
Characteristics of protected classifications under California or federal law, such as gender.

Your Rights

If you are a California resident, you have the following rights under the CCPA with respect to your personal information:

  • Right to Notice.  Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it. This Supplemental Notice is intended to satisfy this requirement.You also have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of third parties with whom we shared the personal information, and the categories of third parties with whom we sold the personal information.
  • Right of Access.  You have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
  • Right to Deletion.  You have the right to request that we delete the personal information we collect from you.  However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right to Opt-Out of the Sale of Personal Information.  If Intelligration sells your personal information to third parties, you have the right, at any time, to direct us not to sell your personal information.We do not sell your personal information.
  • Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.

You can exercise your rights by emailing us at vestly@intelligrationllc.com.

We value the security and confidentiality of your personal information. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully. Along with your request, we ask that you provide you first and last name, email address used to register with our Mobile Apps, and username. You may also authorize someone else to submit these requests on your behalf.

California residents who are unable to review or access this Supplemental Notice due to a disability may email us at vestly@intelligrationllc.com  to access this Supplemental Notice an alternative format.

Categories of
PI Collected
Sources of PI Purposes for Collecting or Sharing PI Third Parties With Whom We Share the Category of Personal Information for a Business or Commercial Purpose
Identifiers
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • 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
  • investigate or discover fraudulent activities
  • 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
  • use in any other ways specified by us at the time your information is collected
  • social media sites
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
  • payment processors, financial institutions, prize issuers and others as needed to complete transactions and award prizes, and for authentication, security, and fraud prevention
  • third parties who assist with our information technology and security programs
Network Activity Data
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • monitor metrics such as total number of visitors, traffic, and demographic patterns
  • diagnose or fix technology problems
  • use in any other ways specified by us at the time your information is collected
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
  • third parties who assist with our information technology and security programs
Education Information
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • develop financial-related and trading-related algorithms and other automated procedures
  • build stock portfolios and other financial products and services
  • provide personalized content and information to you and others, which could include online ads or other forms of marketing
  • monitor metrics such as total number of visitors, traffic, and demographic patterns
  • use in any other ways specified by us at the time your information is collected
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
Geolocation Data
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • monitor metrics such as total number of visitors, traffic, and demographic patterns
  • diagnose or fix technology problems
  • use in any other ways specified by us at the time your information is collected
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
  • third parties who assist with our information technology and security programs
Professional Information
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • develop financial-related and trading-related algorithms and other automated procedures
  • build stock portfolios and other financial products and services
  • provide personalized content and information to you and others, which could include online ads or other forms of marketing
  • monitor metrics such as total number of visitors, traffic, and demographic patterns
  • use in any other ways specified by us at the time your information is collected
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
Financial Information
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • 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
  • provide personalized content and information to you and others, which could include online ads or other forms of marketing
  • use in any other ways specified by us at the time your information is collected
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
  • payment processors, financial institutions, prize issuers and others as needed to complete transactions and award prizes, and for authentication, security, and fraud prevention
  • third parties who assist with our information technology and security programs
Commercial Information
  • directly from consumer
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • 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;
  • provide personalized content and information to you and others, which could include online ads or other forms of marketing;
  • use in any other ways specified by us at the time your information is collected
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
  • social media sites
Inferences
  • directly from consumer
  • develop financial-related and trading-related algorithms and other automated procedures
  • build stock portfolios and other financial products and services
  • 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
  • third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors