This Policy explains what information we collect, how we collect it, and why we collect information when you use the System. We take your privacy extremely seriously, and we never sell lists or email addresses.

This Policy is effective from April 30th, 2022 (the “Effective Date”).

1. Introduction

Allow us to introduce ourselves and get a few definitions out of the way, so that this policy is clear and easy to understand. Mazira, LLC dba GoldFynch, the provider of the application programming interfaces (the "APIs") for the GoldFynch web platform (“Provider”), takes the privacy of users seriously. We developed this privacy policy (“Policy”) to describe how Personal Information is collected, used, disclosed, and protected by Provider when you visit or interact with the API services and any part of the System. When we say “you” or “Subscriber” or “Member,” we are referring to the person or entity that is registered with us to use the Services.

Please refer to the API Terms of Service for the meaning of any capitalized terms that are not defined in this Policy.

2. Scope

This Policy does not apply to any other website, product, or service operated by Provider, or to any of our offline activities. It details the specific points which differ from our general GoldFynch Privacy Policy, which also applies to the API Services. In the case of any overlap between this Policy and the general Privacy Policy, this Policy will take precedence. The general Privacy Policy also covers how we treat your information if you also use the GoldFynch website. This Policy applies to any information that we’ve collected, or will collect, about and/or from you in the course of your usage of the System. .

3. Changes and Updates to this Policy

We may change this Policy from time to time. If there are material changes to this Policy, we will notify you by email (sent to the e-mail address most recently specified in your account) or by means of a notice on this Website. If we make any material changes to this Policy, the changes will apply from the updated Effective Date mentioned above. We encourage you to check this Policy whenever you use our Website and services to understand how your Personal Information is used.

We do not treat information of any open account differently from that of any other open account. Therefore, if you object to changes we make to this Policy, please inform us; we will in such a case have to terminate your account with immediate effect.

4. Your Information

We gather information from you in various ways when you use the services. The information collected is of two general types, namely Personal Information and aggregate data. As used in this Policy, the term “Personal Information” means information that specifically identifies an individual (such as name, e-mail address, telephone number, address, credit card number, and Internet Protocol (IP) addresses for logged in users), and demographic and other information when directly linked to information that can identify an individual. Aggregate data refers to information such as overall patterns or demographic reports which do not describe or identify any individual user.

5. Data Transfer & Access to Information

We have no access to your code and likewise, you will not be provided access to the code for the API services. All data communication happens across a well-defined HTTP/REST protocol. We do not collect the Personal Information of your customers or users; all requests are routed through you, and only the IP address placing the requests (i.e. your IP address, and not your users’), the specific API request, and a timestamp will be recorded by us. Any other data sent to us as part of the request is volatile and completely erased within the mutually agreed-upon timeframe (defaults Minimum 1 hour, maximum 24 hours)

6. Information You Provide to Us

When you use the System, consult with our customer service team, send us an email, or communicate with us in any way, you’re giving us information that we collect. That information may include (but is not limited to) your IP address, name, physical address, email address, phone number, credit card information, operating system, as well as details like gender, occupation, location, birth date, purchase history, and other demographic information. By giving us this information, you consent to your information being collected, used, disclosed, transferred to the United States and stored by us, as described in our API Terms of Service and this Policy. In general, Personal Data will not be accessed, processed, or shared with employees, subcontractors or third parties without your prior written consent unless: (a) it is necessary to facilitate the services provided through the System (b) such disclosure is required by an applicable law or proper legal or governmental authority (c) we detect malicious data in the information we receive. In such cases, we will give you prompt written notice.

The following are examples of the sort of information we may collect from you.

• Registration information — When you create an account with us, we collect your name and email address, and other information used to authenticate your identity and connect your account.
• Payment information — If you purchase a subscription, we, or our payment-processing vendor, collect your credit card information and billing address insofar as is necessary or appropriate to fulfill the purpose of the user’s interaction with Provider.
• Access information —We gather data of the sort that web browsers and servers typically make available, such as internet protocol (IP) addresses, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the System, to track users’ movements around the site and to gather demographic information about our user base as a whole. Ordinarily, this is non-personally-identifying information. To the extent such information contains or is linked to personally identifiable information, such information will be protected in accordance with this Policy.
• We receive statistical data for the files sent to us by you for processing like the number of pages, sizes, the rate at which calls (requests) are being made, where the calls are being made from, and the general performance of our system against your workload.

7. How We Use Your Personal Information

In general, we use your Personal Information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Website and our services and to otherwise serve you and our users. For example, we may use your personal information:

• to request feedback and to enable us to develop, customize and improve the website, API, and our GoldFynch products and services;
• to conduct marketing analysis, to send you surveys or newsletters, to perform after-sales services;
• to send you informational and promotional content that you may choose (or “opt-in”) to receive, about services, products, activities, special events or offers from us or our partners and for other marketing, informational, product development and promotional purposes,
• to respond to your emails, submissions, comments, requests or complaints; to anticipate and resolve problems with our service; to respond to customer support inquiries, for assistance with our product and service development;
• for legal reasons such as arbitration;
• to bill and collect money owed to us;
• for other purposes about which we notify you;
• to send you System Alert Messages; and
• to enforce compliance with our Terms of Use and applicable law.

8. How We Share Your Personal Information

We will share your Personal Information with third parties only in the ways that are described in this Policy. We do not sell your Personal Information to third parties.

• Service providers — We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your Personal Information and website usage information with our service providers and other third parties that provide products or services for or through the website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, email service providers, analytics companies, distribution companies, fulfillment companies, credit card/payment processing companies and other similar service providers that use such information on our behalf). Note that we may use a service such as Google Analytics to review website use. In such cases, any information that such a service has keyed to your IP number will be correlated with the logs of your visits to our site for whatever purpose that service's policy allows.
• Organizational contract — If you are an individual registered to use the API services, and the domain of the primary email address associated with your account is owned by your employer and that email address was assigned to you as an employee of that organization, and that organization wishes to establish a GoldFynch corporate account and add you to it, then certain information concerning past use of your individual account may become accessible to that organization’s administrator including your email address.
• Aggregate statistics — We may disclose non-personally identifiable aggregate statistics regarding user behavior as a measure of interest in, and use of, our website and emails to third parties in the form of aggregate data, such as overall patterns or demographic reports, which do not describe or identify any individual user.
• Legally compelled disclosure — We may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with a judicial or court order or comply with legal process served on us or Affiliated Parties; (b) protect and defend our rights and property, our services, the users of the services, and/or our affiliated parties; or (c) act under circumstances to protect the safety of users of our services, us, or third parties.
• Business transfer — If Provider, or substantially all of its assets, were acquired, or in the unlikely event that Provider goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge and agree that such transfers may occur, and that any acquirer of Provider may continue to use your Personal Information as set forth in this Policy.

9. User Access and Choice to Opt-In/Out

If your Personal Information changes in any way, we invite you to correct, delete or update it as soon as possible. You can make updates to your profile information by logging into your account at any time. You can also request changes or access to your information by emailing support@goldfynch.com/p>

If you no longer desire our service, you may email support@goldfynch.com to delete your account. We will respond to your request within 30 calendar days.

We may send you communications or data regarding our website and services, including but not limited to (i) notices about your use of the System and our services, including any notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our products and services. You may opt out of receiving promotional emails from us by following the opt-out instructions provided in those emails. You may also opt out of receiving promotional emails and other promotional communications from us at any time by emailing support@goldfynch.com with your specific request. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current account and services. To stop receiving emails entirely, you would have to deactivate your account. Please email support@goldfynch.com from the email address associated with your account with a request to deactivate your account and we will respond to your request within 30 calendar days.

10. Your Rights for Protection of Personal Data Under the EU GDPR (General Data Protection Regulation)

If you are a resident of the EEA, you have the data protection rights listed below:

• If you wish to make a correction, access, update, or request deletion of your Personal Information, you can do so at any time by emailing privacy@goldfynch.com.
• You can also object to the processing of your Personal Information, ask us to restrict the processing of your Personal Information, or request porting of your Personal Information. To exercise any or all these rights, email privacy@goldfynch.com.
• As always, you have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" link in the marketing emails we send you. If for some reason you receive other marketing material from us, please contact us at privacy@goldfynch.com.
• If we have collected your Personal Information (we have always only done so only with your consent,) you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to an authority in charge of data protection about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If applicable, our GDPR Data Protection Addendum contains further details about how and why we use your information and how we comply with GDPR requirements.

11. Information Security

We have employed reasonable physical, organizational, and technical safeguards to protect the information we collect from you to prevent its loss, misuse and unauthorized access, disclosure, alteration, and destruction. In addition, highly confidential personal information such as credit card number and password that we request from you on our website is protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the internet.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we take reasonable efforts to guard Personal Information we knowingly collect directly from you, no security system is impenetrable. It is your responsibility to ensure that you keep all login and user information issued to you by us (“Credentials”) safe and that it is not accessible to unauthorized individuals. Please inform us immediately if your Credentials have been compromised in any manner whatsoever. It is your responsibility to safeguard access to the API service, log out at the end of a session of API requests, and clear any stored data related to API requests. You are expected to protect passwords and security keys assigned to you to protect against unauthorized access. If you have specific needs or obligations regarding any passively-collected Personal Information you choose to enter into our System, please satisfy yourself that such information is maintained at adequate levels of protection to meet those needs or obligations before you upload it to the System.

12. Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please email us at privacy@goldfynch.com, or write to us at:

Mazira LLC

Attn.: Privacy Officer

136 S Dubuque Street

Iowa City, IA 52240