Privacy Policy

This policy is effective as of April 30, 2022

Last updated: October 24, 2022


Introduction

Your privacy is important to us. It is LevelField Financial’s policy to respect your privacy and comply with any applicable law and regulations.

While you use our Website, located at https://levelfield.us we are processing your Personal Information. You have the right to know what we do with it and the choices you have over your Personal Information.

In this Privacy Policy:

  • When we say “we”, “us” and “our”, we are referring to LevelField Financial, the organization that is responsible for processing your Personal Information in compliance with applicable regulations;
  • When we say “you”, “user” or “individual(s)”, we are referring to the person accessing our Website, and the person whose Personal Information we are collecting, using and disclosing;
  • When we say “processing”, we are referring to the collection, use or disclosure of your Personal Information;
  • When we say “service providers”, we are referring to organizations that process your Personal Information on our behalf.

If you have any questions or concerns about this Policy, please feel free to contact us at
[email protected]
1300 W. 19th Street
Suite 7948
Houston, TX  77008-9998

In this Privacy Policy, we will tell you:

  • What Personal Information we are collecting and in what circumstances we collect it;
  • The purposes for which we collect and use your Personal Information;
  • The organizations to whom we may disclose your Personal Information and the purpose of such disclosure;
  • What are your rights and how you can exercise them;
  • What happens if we make any change to this Privacy Policy.

1. What Personal Information do we collect and in what circumstances do we collect it?

We collect your Personal Information under the following circumstances:

  • You provide it to us directly;
  • We collect it from external sources, or
  • We collect it by using automated means.

1.1. The Personal Information you provide us directly

In short: During the various interactions we have with you, you may be required to provide us with Personal Information. For example, we collect Personal Information when you contact us via email or via social media, when you join our waitlist, or when you submit an application to open a LevelField account. The Personal Information we collect may vary whether you use our services or if you are a simple user of our website.

In detail: The Personal Information you provide to us directly are the following:

  • Name
  • Email
  • State and/or Country of Residence;
  • Demographic information, i.e., postal address, province, country of residence, telephone number;
  • Social security number, date of birth, government-issued ID (when you onboard with LevelField);
  • Payment details, i.e., credit card number, bank account number, debit card number, other financial information;
  • Engagement information, such as information on products and services that you purchase, or the promotional offers that you participate in; information relating to your purchase history; your commercial relationship with us;
  • User Content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our website (including information in alerts, folders, notes, and shares of content).

1.2. Personal information we collect from external sources

In short: In certain circumstances, we collect information about you from our trusted partners, such as our marketing partners or advertisers, or our Anti-Money Laundering (“AML”) service providers.

In detail: We may also collect information about you from third-party organizations, including analytics providers, advertising networks, and our AML vendors.

When you onboard with LevelField, we will as ask you to submit a copy of your government-issued ID as well as a selfie. To help us comply with our AML obligations and to detect any potential forgeries, our AML service providers will perform a risk assessment to help us determine if we can pursue the onboarding process. In this context, we may collect personal information on you from our service providers.

1.3. Personal information we collect automatically when you use our website

In short: During each of your visits to our sites and mobile applications, we collect information about your connection and your browsing activity through cookies.

In detail: Please consult our Cookie Policy for information on the Personal Information we collect through cookies and other tracking technologies.


2. For what purposes do we collect, use or disclose your Personal Information?

In short: We collect Personal Information for business or commercial purposes.

In detail: “Business purpose” means that we use your Personal Information for operational purposes such as delivery, better user experience, security.

“Commercial purpose” means that we use your Personal Information for advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial transaction.

We process your Personal Information for the following purposes

  • Business purposes:
    • Providing you with our platform’s core features and services;
    • Contacting and communicating with you;
    • Auditing our interactions with you (counting ad impressions to unique visitors, verifying positioning and quality of ad impressions);
    • Security (detecting security incidents, protecting against malicious or fraudulent activity, and prosecuting offenders);
    • To debug and repair our system;
    • Performing our services (either by us or by our service provider, e.g., maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payment), risk assessment (via our AML service providers);
    • Internal Research for Tech Development, e.g., carrying out consumer satisfaction surveys
    • Quality and Safety Maintenance and Verification (improvement, upgrade or enhancement of the service or device owned, manufactured).
    • Carrying out satisfaction surveys;
    • Management of unpaid bills and disputes.
  • Commercial purposes:
    • Enabling you to customize or personalize your experience of our website
    • For analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms;
    • Advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
    • Sending of personalized information on our activity, on our publications;
    • Sending of marketing, advertising and promotional offers relating to our products and services by post, e-mail, mobile notifications, on social networks or any other medium;
    • Personalized customer loyalty or prospecting actions;
    • Setting up of contests or other promotional operations;
    • Collection of customer opinions;
    • Development of trade statistics;
    • Sharing, exchanging your Personal Information with business partners so that they may contact you with offers they think might be of interest to you;
    • Sending of marketing, advertising and promotional messages relating to the products and services of our partners by postal mail, e-mails, mobile notifications, on social networks or any other medium;
    • Setting up of contests or other promotional or event operations with commercial partners.

3. To whom do we disclose your Personal Information

In short: In certain circumstances, we disclose your Personal Information to external organizations (e.g., our service providers, or social media platforms, our business partners…) or public authorities. We do not sell, rent or disclose your Personal Information to any third party if you choose to opt-out from that sale.

In detail: We have disclosed your Personal Information to the categories of recipients listed below in the past 12 months:

  • Disclosure for Business purposes:

In the preceding twelve (12) months, we have shared your Personal Information to the following categories of third-parties:

  • service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, payment systems operators, and AML service providers.

  • a parent, subsidiary, or affiliate of our company;

  • Disclosure for commercial purposes:

In the preceding twelve (12) months, we have sold your Personal Information to the following categories of third parties.

  • third party service providers for the purpose of enabling them to provide their services, including analytics, marketing providers;
  • advertising networks;
  • data analytics providers; and
  • social networks.

If you decide to subscribe to the products or services of our business partners and you allow them to access some of your information, in particular by logging into their sites or applications, their privacy policies will be applicable to you. We have no control over the collection, use and disclosure of your information when carried out by our business partners on their own website.

  • Public authorities, judicial or administrative authorities

We may disclose your Personal Information when we are required or authorized by law to cooperate with local, national or international law enforcement or other authorities for the reporting of and/or investigation of improper or unlawful activities, or if we need to comply with court orders.

We may also disclose your Personal Information to credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you.


4. How can you exercise your rights of access and deletion?

In short: Subject to certain exceptions and restrictions, you have the right to ask us to delete your Personal Information, or to provide you with information on the Personal Information that we have collected, our sources of collection, the business and commercial purposes for which this information was collected, and the categories of third parties with whom this information has been shared.

In detail: If you wish to exercise these rights, please follow the following instructions, and contact us at [email protected] or at the following phone number: (346)-443-2311.

Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as a government-issued ID.

You may designate an authorized agent to exercise your rights on your behalf. We may ask you or the agent to provide proof that the agent has received your authorization to act on your behalf, such as a written and duly signed certificate stating you authorize the agent to act on your behalf.

We will respond to your request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


5. How can you ask us not to sell your Personal Information?

In short: As explained above, we may sell your Personal Information to third-party organizations. You can object to such sale of your Personal Information.

In detail: You can opt out of the sale of your Personal Information by clicking on the “Do not sell my Personal Information” link . We will stop the sale of your Personal Information no later than 15 days following your request.

We will not discriminate you in case you decide to exercise your rights, which means that we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. What happens if we make changes to this Policy?

In short: We may update this Policy to reflect changes to our information practices. The review of our Privacy Policy will take place at least every 12 months.

In detail: We will post any changes to this page and, if the changes are significant, we will provide a more prominent notice. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

If you have any questions or concerns about this Policy, please feel free to contact us at [email protected]
1300 W. 19th Street
Suite 7948
Houston, TX  77008-9998

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details above and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

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