Thank you for using GoldFynch for your e-discovery needs. 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 March 14th, 2023 (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 GoldFynch service (“Provider”) takes the privacy of GoldFynch 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 Website(s) the GoldFynch products and services, and any part of the System. This Policy does not apply to any other website, product, or service operated by Provider, or to any of our offline activities. 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 GoldFynch Terms of Service for the meaning of any capitalized terms that are not defined in this Policy.

2. 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 the 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.

3. Scope

This Policy applies to any Personal Information and Aggregate Data that we’ve collected, or will collect, about and/or from you in the course of your usage of the GoldFynch website and System. Our Terms of Service governs the information and files uploaded by you during your use of the System (“Customer Data”). See the Terms of Service for definitions and details of all three types of data.

4. Your Information

We gather information from you in various ways when you use the Website and services. The collected information that is governed by this Policy 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 we collect about a group or category of services or Users from which individual user identities have been removed (such as the sort of data that web browsers and servers typically make available, e.g. public IP address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.) For more details of each, along with examples of such data, see their definitions in our Terms of Service (Section 11. "Definitions")

5. 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 and your Subscribers’ 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 Terms of Service (detailed in Section 8. "Customer Data & Privacy") and this Policy.

The following are examples of the sort of information we may collect from you. For more, see our Terms of Service (Section 11.

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 GoldFynch cases and account(s).
Upload/Attachment information — When you use the GoldFynch System to upload and manage documents, images and other electronic files, we collect and keep some of the information about a file (e.g. filetype, size, filename, date).
Payment information — If you purchase a GoldFynch subscription or other services, 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, browser type, internet service provider (ISP), 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 GoldFynch 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.

6. Cookies, Web Beacons and Tracking

When you use the GoldFynch System, we may store “cookies,” “tags,” or “scripts,” which is a small amount of data sent from a website and stored on your computer. We and our analytics service providers (like Google) use those cookies to collect information about your visit and your use of our Website or System. You can modify your browser setting to reject our cookies or to prompt you before accepting a cookie by editing your browser options. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of the Website and GoldFynch services may not function properly. For example, you may not be able to sign in and access certain web page features or services. We may also use cookies and web beacons to collect information regarding your web browsing activities such as the address of the page you are visiting, the address of the referrer page you previously visited, the time and duration for which you view the page, your browsing environment and your display settings.

Among other things, the use of cookies and web beacons enables us to: improve our Website and communications with you by seeing which areas and features are most popular; count the number of computers accessing our Website; personalize and improve your experience; record your preferences: and allow you to visit our Website without re-entering your Customer ID and/or password. Most browsers automatically accept cookies as the default setting.

Third Party Cookies — Provider uses third parties to track and analyze usage and volume statistical information from individuals who visit the Website. Provider uses this information to serve users better. The use of cookies by our service providers is not covered by this Policy. We do not have access or control over these cookies.

Information from the use of our Mobile Apps: When you access our System through the web browser of your mobile device or through any future mobile app, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you opt into these notifications and no longer want to receive them, you may turn them off through your operating system. We do not access or track any location-based information from your mobile device unless you have given us permission to do so. We may use mobile analytics software to help us better understand how customers use our application. We may collect information about how often you use the application and other performance data. We don’t collect or link that data with any personally identifiable information.

7. How We Use Your Personal Information and Aggregate Data

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 and our GoldFynch products and services;
to conduct marketing analysis, to send you surveys or newsletters;
to contact you about services, products, activities, special events or offers from us or our partners, and for other marketing, informational, product development, and promotional purposes;
to send you a welcoming email and to contact you about your use of the Website and services;
to inform you of updates to products and services from us that better meet your needs;
to send you informational and promotional content that you may choose (or “opt in”) to receive;
to respond to your emails, submissions, comments, requests or complaints, and respond to customer support inquiries for assistance with our product or about our service development;
to perform after-sales services;
to anticipate and resolve problems with our service;
to send you System Alert Messages;
to store tags you enter or upload into your tags list for your private use;
to enable collaboration or file sharing with other users you designate;
to bill and collect money owed to us;
for legal reasons such as arbitration;
for other purposes about which we notify you; and
to enforce compliance with our Terms of Use and applicable law.

We retain the right to use, reproduce, or otherwise exploit Aggregate Data in any way, including for the purpose of supporting and developing the System, as our sole discretion.

8. How We Share Your Personal Information and Aggregate Data

We will share your 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 GoldFynch registered user, and the domain of the primary email address associated with your GoldFynch 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 Data/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. Information relating to aggregate statistics may be collected using third-party cookies and other third-party tracking devices.
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 Website, the users of the Website, and/or our affiliated parties; or (c) act under circumstances to protect the safety of users of our Website, 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 and Aggregate Data 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 on GoldFynch at any time. You can also request changes or access to your information by emailing support@goldfynch.com

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 our Websites and 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 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. You will also need to log out at the end of a session and close your browser to protect against unauthorized access. If you have specific needs or obligations regarding any passively-collected Personal Information you choose to include in documents you store on 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. Third Parties

Our Website may include links to other websites whose privacy practices may differ from ours. If you submit Personal Information to any of those sites, your information is governed by their respective privacy policies. Our Website also includes social media features, such as social media buttons or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Such features and mini-programs are either hosted by a third party or hosted directly on our Website and your interactions with them are governed by the privacy policy of the company providing it.

13. 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

Privacy Policy