Last Modified: 07/29/2019
Your privacy is important to us.
This Agreement specifically incorporates by reference, the entirety of our Terms of Service.
- “Personal Data” means any information relating to a natural person who can be identified, directly or indirectly, by using such information.
- “Services” means any services that are made available by the Company for use or sale on the Website.
How We Collect Information
Through your use of our Website, you will be subject to different types of Personal Data collected and different manners of collection. We will collect and process your Personal Data in a lawful, fair, and transparent manner and, where appropriate, with your knowledge or prior explicit consent. Personal Data will be relevant to the purposes for which they are to be used, and to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
Types of Personal Data Collected
We comply with data minimization principles. We collect and process only the minimal amount of Personal Data that is necessary for performing the operations requested by you. We do not attempt to collect any Personal Data from you that are not strictly necessary for performing the requested operations. The following types of Personal Data will be collected by the Company through the Website:
- REGISTRATION: You, as a User of the Website and its Services, may be asked to register an account to use the Website or access any of the Services thereon. During the process of your registration, you will be asked to provide authorization via Google (if you opt for registration through Google) or Facebook (if you opt for registration through Facebook). You will also be asked to provide authorization for your Robinhood account. We use this Personal Data to provide the Services to you and ensure the security of BlueChip and its Website.
- BILLING: If you elect to use any of our paid Services, you will be asked to provide billing information, such as, but not limited to, your credit card number and billing address. This Personal Data will be used specifically for providing you with the Services you have purchased. The payment and billing information may be stored for the time period as required by applicable law for lawful purposes (e.g., accountancy records).
- CRYPTO AND FINANCIAL INFORMATION: To use our Services, you will be asked to provide information necessary for Application Programming Interface (“API”) access through Robinhood’s platform.
- ORDER AND INVOICE DATA: In order to assure payment for BlueChip’s Services, invoice and order data may be maintained. Such data will only be retained for the period of time necessary to secure payment.
- USE: Through your use of BlueChip’s Website, you may be asked questions about how to improve the Website or you may, at some point, communicate with representatives of BlueChip. We will receive your e-mail address, as well as the contents of your communications, answers to questions, and any other form of contact between you and BlueChip. We will use Personal Data contained in such communications only for the purposes of providing you with the requested information and for improving the Website and its Services.
- AUTOMATIC COLLECTION: We may collect information from you through automatic tracking systems on your device or through the BlueChip API, or other web and mobile analysis software. We may also receive certain usage data, such as your IP address and referral source. We use this information for our legitimate business interests, including analyzing usage of BlueChip’s Website.
- COMBINED OR AGGREGATED INFORMATION: We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update the Website for your and other consumers’ use.
We may collect non-personal data, such as browser types, operating systems, and the URL addresses of websites clicked to and from our Website, including referral links we may post on our Website in order to analyze what kind of users visit our Website, how they find it, how long they stay, from which other websites they come to our Website, what pages they look at, and to which other websites they go from our Website.
How Information Is Used
We respect data protection principles and process Personal Data only for specified, explicit, and legitimate purposes for which such Personal Data were provided. We primarily use your Personal Data to enable your use of BlueChip’s Website and supply the services requested by you. We may also use your Personal Data for the following purposes:
- Asking you about your experience with us;
- Communicating with you about your user account with us;
- Analyzing our aggregate user data;
- Securing payment for our Services;
- Enforcing our Terms of Service;
- Providing customer services to you;
- Advising you about updates to BlueChip, the Website, or related items; or
- Providing you with information about services that are similar to the Services used by you.
Please note that we do not collect any sensitive data about you (e.g., your health information, opinions about your religious and political beliefs, or racial origins). Should we intend to process any sensitive data collected from you, we will seek your explicit consent in advance.
How Information Is Stored And Kept Secure; Protection of Personal Data
We protect your Personal Data by using reasonable security safeguards against loss or theft, unauthorized access, disclosure, copying, use, or modification. Your Personal Data is contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the Personal Data confidential. We implement a variety of security measures, such as encryption when users enter, submit, or access their Personal Data to maintain the safety of your Personal Data. BlueChip also encrypts the authorized Robinhood access token in storage and does not retain Robinhood account passwords. Please note, however, that no system involving the transmission of information via the Internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data seriously and we take reasonable steps to ensure the ongoing confidentiality, integrity, and availability of your Personal Data. Nevertheless, we are not liable for any loss, theft, unauthorized access, disclosure, copying, use, or modification of your Personal Data that occurs outside our reasonable control.
Should a Personal Data breach occur, we will inform the relevant authorities without undue delay and immediately take reasonable measures to mitigate the breach. We will notify you about such a breach via e-mail as soon as possible but no later than within seven (7) business days.
Your Personal Data will be kept for as long as it is necessary to provide you with the requested services. When your Personal Data is no longer necessary to deliver the requested services, we will delete your Personal Data, unless we are obliged by law to retain such Personal Data for a specific period of time.
There are two types of cookies, namely, persistent cookies (i.e., cookies that remain valid until their expiration date, unless deleted by the user before that date) and session cookies (i.e., cookies that are stored on a web browser and remain valid until the moment when the browser is closed). We use both persistent cookies and session cookies.
- Authentication and authorization;
- Understanding and saving User’s preferences for future visits;
- Keeping track of advertisements; and
- Compiling aggregate data about traffic and interactions in order to offer better experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
Most Internet browsers accept cookies automatically, although you are able to change your browser settings to control cookies, including whether or not you accept them, and how to remove them. You may also be able to set your browser to advise you if you receive a cookie, or to block or delete cookies.
We honor Do Not Track (“DNT”) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place. Users can also choose to visit our Website anonymously, but you may not be permitted to access any of the Services.
How Information May Be Shared or Disclosed
We may disclose your information if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such a disclosure or transfer is limited to the situations when the Personal Data is required for the purposes of (1) provision of the Services, (2) pursuing our legitimate interests, (3) law enforcement purposes, or (4) if you provide your prior explicit consent. Please note that some third-parties may be located outside of the jurisdiction in which you reside.
Such reasonable disclosure cases may include, but are not limited to:
- Satisfying any local, state, or federal laws or regulations;
- Responding to requests, such as discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
- Bringing legal action against a User who has violated the law or violated our Terms of Service;
- As may be necessary for the operation of BlueChip and our Website;
- Generally cooperating with any lawful investigation about our Users; or
- If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our Terms of Service or other applicable rules.
We may utilize third-party service providers, from time to time or all the time, to help us with our Website and to help to serve you. Such third-party service providers may include:
- Data storage companies (e.g., Amazon Web Services and other cloud storage providers);
- User information logistics providers (e.g., Google Analytics or other analytics companies which help us track general user information and usage);
- Web hosting companies;
- Newsletter providers; and
- Other parties who assist us in operating BlueChip and conducting our business.
Please note that we allow third-party behavioral tracking which may include non-personal data.
Transmittals From Us
From time to time, we may send you informational communications related to BlueChip, such as announcements or other information. You may also receive information from us that is specifically about your use of BlueChip’s Website, Services, or about your account with us, including information about security breaches or other privacy-related matters.
By providing any personal information to us, or by using BlueChip’s Website or Services in any manner, you have created a commercial relationship with us. As such, you agree that any e-mail sent from us or third-party affiliates, even unsolicited e-mails, shall specifically not be considered SPAM, as that term is legally defined.
Before visiting and providing any information to any such third-party websites and applications, you should familiarize yourself with the applicable privacy practices and take reasonable steps necessary to protect your Personal Data.
Accessing, Correcting, and Erasing Personal Data
We take reasonable steps to ensure that the Personal Data collected and processed by us is accurate, complete, and up-to-date. Thus, we ask you to keep your Personal Data as current as possible and update your Personal Data through the Website if necessary.
You may at any time review or change the Personal Data in your user account by logging into it through the Website and updating your data. You may terminate your user account by sending an e-mail request to BlueChip at firstname.lastname@example.org. Upon your request to terminate your user account, we will deactivate or delete your account and information from our active databases.
If you would like to access, modify, or delete your Personal Data that are processed through our Website, please send us an e-mail to email@example.com. We will answer your request within a reasonable timeframe.
Updates, Modifications, or Revisions
California’s “Shine the Light” law (Civil Code § 1798.83) permits Users of our Website that are residents of California to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. If you are a California resident and would like to request such information, please submit a written request to firstname.lastname@example.org. The data collection and management of California residents is additionally regulated by the California Consumers Protection Act (CCPA). This act provides California residents with additional protections, such as the ability to request information regarding the data stored as well as the ability to have such information deleted. BlueChip will be in compliance with the CCPA once it comes into effect in 2020.
Complaints About Handling of Personal Data
You have the right to submit a complaint to us about the way in which your Personal Data has been handled by contacting email@example.com.
After you submit such a complaint, we will send you an e-mail confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe.