CFO SOLUTIONS, LLC

PRIVACY POLICY
Effective as of May 6, 2020

    We at CFO Solutions (“CFO Solutions,” “we,” “us,” or “our”) created this privacy policy (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of CFO Solutions in connection with our online platform and mobile application (the “Services”), which are made available to you through our website located at www.cfo2u.com and on your mobile device (the “Site”).

    By visiting our Site and/or using our Services, you are agreeing to the terms of this Privacy Policy and our Website Terms and Conditions/Website Terms of Use. We may from time to time change this Privacy Policy, so please check back periodically. 

WHAT INFORMATION WE COLLECT?

Personal Information

    If, upon visiting our Site, your use is limited to browsing our Site, we will not collect any personal information from you unless you voluntarily provide it to us. However, we may request personal information from you (“User”) at all other times (hereinafter referred to as “Personal Information”). For example:

• If you enroll in any and all accounts through the Site, we may ask that you provide us with certain personal information, including, your first name, last name, email address, credit card number, expiration date, mailing address, and telephone number. 
• If you purchase or pay for any goods or services through our Site, your credit card information will be transferred to Total System Services (“TSYS”) for processing. TSYS (as discussed in more detail below) employs a variety security and risk management technologies to facilitate secure on-line transactions and to protect your credit information. You can find more information about TSYS at https://www.tsys.com/, and https://www.tsys.com/privacy-policy.html. 
• If you post to our discussion forums that may exist from time to time, we will ask that you provide us with your name, e-mail address, and password. 
• If you want to enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we will need your name, e-mail address and other information as may be required by the rules of the specific contest.
• If you choose to participate in a customer survey conducted by us or by one of our business partners, we may ask for your name, e-mail address and other information as may be required by the particular survey.
• If you report a problem or submit a customer review, we will ask that you provide your name, e-mail address, membership number, address, phone number and fax number. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.

    If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at info@cfo2u.com.

    Like most websites, we may use automatic data collection technology when you visit the Site to record information that identifies your computer, to track your use of our Site, and to collect certain basic information about you and your surfing habits, whenever you visit our Site or Services or when you access the Services by or through a mobile device. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, mobile device you use, mobile device unique ID, Ip address of the mobile device, and similar information concerning your use of the Site and the Services (the “Usage Information”).

    We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Site, but may not be able to use some areas of the Site and/or the Services.

    We do not collect Personal Information in this way, but if you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.

HOW DO WE USE YOUR INFORMATION?

    We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Site for the following purposes:

• To identify you when you sign in to your account;
• To respond to your requests and to provide you with the Services;
• To respond to your inquiries and contact you about changes to the Site and/or the Services;
• To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving, and for billing and collection purposes;
• To send you information we think you may find useful or that you have requested from us;
• To enhance and improve the Site or the Service, such as through personalized features and content;
• To analyze the use of the Site and the Service and the people visiting to improve our content and Site and the Service;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
• For any other purposes disclosed at the time the information is collected or to which you consent; and
• As otherwise specifically described in this Privacy Policy.

HOW DO WE PROTECT YOUR INFORMATION?

    It is important to remember that whenever you voluntarily disclose personal information on-line, your information can be collected and used by others. If you transmit or post personal information on-line that is accessible to others, you will not be able to control how that information is used by others. When we receive the transmitted information, we take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unfortunately, notwithstanding any of the steps taken by us, it is not possible to guarantee the security and integrity of data transmitted over the Internet. We cannot guarantee and do not warrant the security of our databases, nor the guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. All such transmission of information is at your own risk. Moreover, though we are committed to having our Web Site comply with this Privacy Policy, you are ultimately responsible for maintaining the secrecy of your password and your personally identifiable information. If you are careless with your password, or you decide to share your password with third parties, you must be aware of the risk that such third parties will have access to all your personally identifiable information.

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

    CFO Solutions will retain your Personal Information only for as long as is necessary for the purpose set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. 

    CFO Solutions will also retain Usage Information for internal analysis purposes. Usage information is generally retained for a shorter period of time, except when this data is used to strengthen security or improve the functionality of our Services or Site, or we are legally obligated to retain this data for longer periods. 

WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

    We do not disclose your Personal Information to third parties for their direct marketing purposes.

    We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information. Some third-party programs include: Google analytics, Admob by Google, ad colony by Jirbo Inc., and Facebook,

    Third parties that have links on our Site may collect personally identifiable information about you. We are not responsible for the privacy policies or practices of such sites and the practices of these sites are not governed by this Privacy Policy. If you have questions about the privacy policies or practices of a third-party site, you should contact the site administrator or web-master of the specific site. We may from time to time partner with other companies to offer co-branded services as well as sweepstakes, contests and promotions. Any information that you provide in connection with the co-branded services or any jointly sponsored sweepstakes, contests or promotions will become the joint property of Company and its business partners. We will maintain your information in accordance with the terms of this Privacy Policy. However, this Privacy Policy does not govern the privacy policies and practices of our business partners. If you have questions about the privacy policies or practices of our business partners, you should contact them directly.

    If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets.

    We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of this Site, or anyone else that could be harmed by such activities.

DO WE SELL OR RENT YOUR PERSONALLY IDENTIFIABLE INFORMATION?

    No, as a general rule, we do not sell or rent your personally identifiable information to any one. If and whenever we intend to share your personally identifiable information with a third party (other than to a business partner as provided herein), you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer. However, we may from time to time rent or sell demographic information in the aggregate that does not contain your personally identifiable information.

HOW CAN YOU UPDATE, CORRECT, OR DELETE YOUR PERSONALLY IDENTIFIABLE INFORMATION?

    If you are from the European Economic Area (EEA), CFO Solutions’ legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it. 

    CFO Solutions may process your Personal Information because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with the law. 

    If you are a resident of the EEA, you have certain data protection rights. CFO Solutions aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed about what Personal Information, we hold about you and if you want it to be removed from our systems, please contact us at info@cfo2u.com.

    In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where CFO Solutions relied on your consent to process your personal information.

    Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

   If you are not from the EEA, but wish to amend, change, delete, or remove your Personal Information, please contact info@cfo2u.com and CFO Solutions will attempt to resolve your request if possible. 

ARE CHILDREN UNDER THE AGE OF 13 ALLOWED TO USE THE SITE AND “DO NOT TRACK” SIGNALS?

    We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Services. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Site and/or Services, and we recommend that parents discuss with their kids restrictions regarding the online release of Personal Information to anyone they don’t know. We strive to help parents ensure that their kids have a safe experience using our Services. Parents or legal guardians can review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.

    We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

WHAT IF I AM A RESIDENT OF CALIFORNIA?

    Some users and residents of the state of California, may have certain rights to their personal information.  These rights may be addressed in other areas of this privacy policy and may also include:

CA Resident Rights	What does this mean?
Right to know about personal information collected, disclosed, and sold	You have the right to be provided with clear and easy-to-understand information about how we use your personal information. This is why we are providing you this Notice and we may provide other forms of notice, as appropriate or required by law, in the Sites and Services. You also have the right to access and receive a copy of the personal information we hold about you.
Right to opt-out of the sale of personal information	You may request that we do not sell your personal information to third parties.
Right to request deletion	In some circumstances, you have the right to have your personal information erased or deleted.
Right to equal service and prices (“non-discrimination”)	Your choice to exercise your privacy rights will not be used as a basis to discriminate against you in services offered or pricing.

HOW CAN I OPT-OUT OF PROMOTIONAL EMAILS?

    If at any time, you no longer want to receive promotional e-mails and/or direct mailings, you may opt-out at any time by simply sending an e-mail request to info@cfo2u.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email.

WHERE IS THE SITE OPERATED AND WHERE IS MY INFORMATION STORED?

    The Site and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site or the Services, you consent to this transfer.

WHEN IS THIS PRIVACY POLICY EFFECTIVE AND WHEN CAN IT BE CHANGED?

    This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Site as soon as they go into effect. By accessing the Site or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US?

    If you have questions about this Privacy Policy, please e-mail us at info@cfo2u.com, “PRIVACY POLICY” in the subject line, or visit our contact page on the Site.  You may also send us mail directly at 3001 North Rocky Point Drive East, Suite 200, Tampa, FL 33607.