Privacy Policy

LightPoint Financial Technology Privacy Policy

Updated June 2021

This privacy policy (the “Privacy Policy”) only applies to the information that LightPoint Financial Technology (LightPoint) gathers through its website www.lightpointft.com. This Privacy Policy does not apply to our specific service offerings that we offer to clients or to information collected offline, unless specifically noted.  The following discloses our information-gathering and dissemination practices for our Web Site. By using our Web Site, you consent to the collection and use of this information by LightPoint. Our Web Site is general-audience in nature and are not intended for individuals younger than the age of 18.

LightPoint is committed to protecting personal data and respecting your privacy. This privacy statement describes how we collect use, share, protect and otherwise process and personal information about you.

What information do we collect from you:

We may collect and process the following information (personal data) about you:

• Information that you give us:
  • This includes information about you that you give us by filling in forms on our website or other forms we may ask you to complete, corresponding with us by telephone, mail, email or other means. This may include, for example, your name, address, email address, work telephone number, mobile telephone number, information about your business relationship with us and information about your professional role, background and interests.
• Information that our website and other systems collect about you:
  • If you visit our website, it will automatically collect certain information about you and your visit, including the internet protocol (IP) address used to connect your device to the Internet and other information such as your browser type and version. We may also collect information about the pages on our site that you visit. Our website may also download “cookies” to your device. If you email, telephone, write or exchange other electronic communications with our employees and other staff members, our information technology systems may record details of those conversations and exchanges, sometimes including their content.

Tracking Technologies

We, and our third-party service providers, may use cookies, web beacons and other tracking technologies to gather Usage Data about visitors and how they use our Web Site. We use this information to improve our Web Site, to target advertisements to users, and for other business purposes. The tracking technologies we use include the following:

Cookies and Local Storage.  “Cookies” and local storage are pieces of information (data files) transferred to a browser when the user visits a site. These technologies are able to store a unique identifier for a device to allow an online service provider to recognize the device whenever the device is used to visit the site. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences, tracking your visits to our web pages, and facilitating your transactions. We use both session and persistent cookies (which remains on your computer after the browser has been closed). You may set up your computer to reject cookies by the privacy settings for your web browser although, in that case, you may not be able to use some of the features on our Web Site. You can find more information about cookies and how they work at www.allaboutcookies.org.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1×1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, to count visitors to the Web Site, to monitor how users navigate the Web Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Web Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Web Site, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

Social Network, Platform Integration and Third Party Links

The website may contain integration with social networks and other platforms. For example, the Web Site may contain buttons that direct users to our social networking pages (such as Facebook or Twitter), enabling you to “like” or “share” the Web Site’s content to other online services, or display tweets or other content from third party platforms on the Web Site, in accordance with the terms of that third party platform. If you choose to “like” or “share” content or to otherwise post information via the Web Site to a third-party website or other online service, that information may be publicly displayed and the third-party website may have access to information about you and your use of our Web Site.

In addition, the website may have links to third party websites. If you click on social networking buttons or third party links, you will be taken to those third parties websites, and your use of those third parties’ websites and platforms are subject to their privacy policies and practices. We are not responsible for the privacy or business practices of any third party.

Additional Information: We may also collect some information from other sources.

If we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you, such as your name, contact details or your role in the organization.

We sometimes collect information from other third parties, which can include third party data providers, or from publicly available sources for marketing and similar purposes.

How we may use your information:

• We may use your information for the following purposes:
• To send you marketing communications regarding our products and services;
• For ordinary business purposes;
• To set up demonstration of our product for you to review;
• To personalize and customize your experience with us; conduct research and analysis and fulfill orders and requests for our products, services or information for you and the organization you represent.
• To comply with our legal and regulatory obligations, and to bring and defend claims where the information is pertinent (including to allow us to pursue available remedies or limit the damages we sustain.)

At times we may be required to review the information about you held in our systems, including the contents of and other information related to your email and other communications with us for compliance and business-protection purposes described above.

This may include reviews for the purposes of disclosure of information relevant to litigation and/pr reviews of records relevant to internal or external regulatory investigations.

To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as asset out below.

Your emails and other communications may also be accessed occasionally by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left our organization).

We will only process your personal information as necessary to pursue the purposes described above and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.

In exceptional circumstances, we may also be required by law to disclose or otherwise process your personal information.

We will tell you, when we ask you to provide information about yourself, if:

• The requested information is necessary for compliance with a legal obligation.
• It is purely voluntary and there will be no implications if you decline to provide the information.

If you are uncertain as to our need for information that we request from you, please contact us at info@lightpointft.com with your query.

Disclosure and Use of your Information

LightPoint may disclose personal information about you, where reasonably necessary and appropriate for the various legitimate purposes set out above:

• To other legal entities within our control;
• If we receive the personal information from you as a representative of one of our business partners or clients, to your colleagues within the organization that you represent;
• To third party service providers who host our website or other information technology systems
• Systems that hold or process your information on our behalf, under strict conditions of confidentiality and security;
• To business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit; in accordance with our legal obligations, including to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory or where we are otherwise required by law to disclose.

We do not share Personal Information with third parties for those third parties’ own direct marketing purposes without your express consent, unless you have accessed information on the Web Site about such third party, its products or services, in which case LightPoint may share your Personal Information with that third party.  We may share the information we have collected about you (including Personal Information) with third parties as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, and under the following circumstances:

• with our vendors and third-party service providers to perform certain services on behalf of the Web Site, such as hosting the Web Site or Web Site features, processing employment applications, sending email or other communications, and providing marketing assistance and data analysis;
• to comply with legal process or a subpoena, or at the request of a governmental entity conducting an investigation, and to protect and defend the legal rights or property of LightPoint, our Web Site or its users, or any other party;
• with its affiliates, primarily for business and operational purposes; and
• in connection with a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of assets), including during the course of any due diligence process; during such business transition your Personal Information will likely be among the assets transferred; by providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.

In addition, if you apply for a job through our website, LightPoint may ask you to provide self-identifying information (such as veteran status, gender and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”) and other federal, state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, LightPoint or its service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.

How we Keep your Personal Information Safe

LightPoint is committed to protecting your personal information submitted to us. We maintain an information security program, including internal policies addressing the acceptable use and access to confidential business information and personal information which may be contained within our information systems. We maintain physical, electronic and procedural safeguards reasonable designed to guard personal information from loss, misuse or unauthorized access, disclosure, alteration or destruction of the information that has been provided to us through our on-line services.

Although LightPoint does its best to keep your information safe, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Web Site and provide us with information at your own initiative and risk.

Please contact us for more information on our Information Security Policies.

Personal Information Retention

LightPoint will retain your data in accordance with our internal policies and for at least as long as required by applicable law.

We will delete the information that we hold about you when we no longer need it.

Note that we may retain some limited information about you even when we know that you have left the organization that you represent, so that we can maintain a continuous relationship with you and if you are representing a different company.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time in our sole discretion and any changes will be effective upon posting of the revised Privacy Policy unless otherwise specified. If there are material changes to the way we treat Personal Information, we will notify you by posting the updated Privacy Policy on our Web Site. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Your continued use of our Web Site following the updated Privacy Policy will mean you consent to those changes.

Contact Us

If you have questions or comments about our use of your information or about this Privacy Policy, please contact us by email at info@lightpointft.com

RESIDENTS OF THE EUROPEAN UNION (EU) AND EUROPEAN ECONOMIC AREA (EEA)

This section of the Privacy Policy applies only if you use our Web Site and are a resident of a country that is a Member State of the European Union or European Economic Area (collectively, “EU”), and it supplements the information in the Privacy Policy.

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes set out in our Privacy Policy. Our legal basis to process Personal Data includes processing that is: necessary for the performance of a contract between us (for example, to provide you with services you request and to identify and authenticate you so you may use the Web Site); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the Web Site and our services); and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time by contacting us (using the contact instructions below). Where we ask you for personal data, we will tell you if it is optional.  Otherwise, we are asking because it is necessary in order for us to provide the requested information or complete the requested transaction.

EU DATA SUBJECT RIGHTS

The GDPR provides certain rights for EU data subjects. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your Personal Data, and the right to access your Personal Data and update or correct it.  In some cases, you can also ask us to erase it, restrict or stop processing, or provide data in a “portable” form, if feasible.  You may withdraw consent (“opt-out”) if you have previously consented to any particular use of your information, such as receiving emails or text messages.  Requests should be submitted by contacting us, using the contact instructions below). We will make commercially reasonable efforts to provide you reasonable access to your personal information within 30 days of your access request to the contact address below.  If we cannot honor your request within 30 days, we will inform you when we will be able to provide such access. If for some reason access is denied, we will provide an explanation as to why access is denied.

If you have any privacy-related concern, please contact us at info@lightpointft.com. If you have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Data Protection Authority and lodge a complaint.

RETENTION

We retain your Personal Data while you have an account with us and while you continue to visit our Web Site. We will retain your Personal Data for as long as it is reasonably necessary for the purposes set out in the Privacy Policy and the purposes for which it was collected, and additionally, for as long as necessary to comply with legal and regulatory requirements, professional accounting and audit standards, legal or insurance claims, or regulatory proceedings; to protect against and assist in the prosecution of fraud or crime; to comply with our contractual obligations and our business policies; as allowed by law to protect our legitimate interests and to protect our property and enforce our terms for use for the Web Site or our services.

THIRD PARTY ONLINE ADVERTISING

As discussed in our Privacy Policy, we work with online analytics and advertising companies, and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. The European Digital Advertising Alliance (“EDAA”) has developed a guide to online behavioural advertising and has developed an opt out page to manage online behavioural advertising preferences with participating EDAA member companies available at www.YourOnlineChoices.com.

CONSENT TO TRANSFER

As noted in our Privacy Policy, we operate the Web Site in the United States and other jurisdictions, and by visiting the Web Site or providing us with any Personal Data, you consent to the collection, transfer and processing of your data in the United States and other jurisdictions, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

CONTACT US

You can contact us via email at info@lightpointft.com.  For all EU Data Subject Rights requests sent by email, you must put the statement “Your EU Data Subject Rights” in the subject field of your request and include in the request the name of the Services with respect to which you are requesting the information, as well as your contact information.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE

This California Consumer Privacy Act Notice, in conjunction with the preceding portions of this privacy policy, provides information for certain California residents in connection with the California Consumer Privacy Act of 2018 (“CCPA”).  Under the CCPA, and for purposes of this California Consumer Privacy Act Notice portion of this Privacy Policy and Notice, “Personal Information” generally means information that identifies, relates to, or describes a California resident or household and includes the categories listed below.  Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months.

Information Collected.

We collect the following categories of Personal Information: 

1. Identifiers, such as (but not limited to) name and online identifiers;
2. Personal information, as defined in the California customer records law, such as (but not limited to) contact information and financial information;
3. Characteristics of protected classifications under California or federal law, such as (but not limited to) age, gender, and marital status; 
4. Commercial information, such as transaction information;
5. Internet or network activity information, such as browsing history and interactions with our websites;
6. Geolocation data, such as device location;
7. Audio, electronic, visual and similar information, such as call and video recordings;
8. Professional or employment-related information, such as work history, prior employer and reference contact information; and
9. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on a California consumer’s particular interactions and relationship with us, we may not collect each of the above categories of Personal Information about each consumer.

Sources of Personal Information.

We collect this Personal Information directly from California residents themselves, as well as from other sources, such as public databases, your employer and its employees, our affiliates, third-party sources of demographic information, and social media platforms.

Purposes.

We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, to communicate with our customers, prospective customers, vendors, employees and other associated entities and persons, and to otherwise accomplish our business purposes and objectives.  Our business purposes and objectives include, for example, developing, improving, supporting, servicing and maintaining our products, services, customer relationships and employee relationships; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies (including responding to requests from California residents under the CCPA); maintaining records; and exercising and defending legal claims.

Disclosures of Personal Information.

We may disclose the categories of Personal Information listed above to our affiliates and to third parties, such as our service providers, for our operational business purposes.

Depending on a California consumer’s particular interactions and relationship with us, we may not have disclosed each of the above categories of Personal Information about each consumer.

Sales of Personal Information.

We have not “sold” Personal Information for purposes of the CCPA. 

For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you have the following rights:

(1) Right to Know.

You have the right to request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting Personal Information about you; and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.

(2) Right to Request Deletion. 

You have the right to request that we delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please email us at info@lightpointft.com or call us at 833.575.7577.  We will respond to your request consistent with applicable law. 

(3) Right to Be Free from Discrimination.  You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.