Privacy Policy

 

EFFECTIVE DATE: MAY 1, 2023

 

 

This Privacy Policy and Notice at Collection (this “Privacy Policy”) applies to your use and access of all of the products and services made available to you by GreenPortfolio Inc. or its affiliates (the “GreenPortfolio Services” or “Services”) through our websites including, without limitation http://www.greenportfolio.com, http://www.mygreenportfolio.com and any downloadable mobile applications (collectively, the “Platform”).

 

 

 

This Privacy Policy describes how GreenPortfolio Inc. (“GreenPortfolio”,"greenportfolio.", "greenportfolio.com", “mygreenportfolio.com”, “we”, or “us”) collect and handle your information in connection with the Platform.  This Privacy Policy applies when you access, visit or otherwise make use of the Platform and is part of, and governed by, the terms and conditions set forth in our Terms of Use located online at www.greenportfolio.com/terms.  By using the Platform and Services, or by otherwise, accessing, visiting or using the Platform and Services, you consent to the terms of this Privacy Policy.

 

 

 

If you have any questions about this Privacy Policy, please email us at support@greenportfolio.com.

 

 

 

1. Information We Receive About You.

 

 

 

1.1.  Information You Provide to Us. We may collect information that you provide to us in connection with your use of the Platform or Services.  Such information may include your: name; email address; mailing address; phone number; date of birth; social security number; third-party financial account information (such as ID and password); your financial information, such as investments, income, expenses, investible assets, investing risk tolerance or other similar types of information;  age, gender, or similar demographic information when this information proves relevant to a particular financial product or service you may request; or other similar personal information.

 

When you login to your financial accounts in order to connect them to our Services, we will receive transaction and balance information from such accounts via Plaid. You can find Plaid's privacy policy here. At no point will we receive your login information to any of your financial accounts.

 

 

 

The purpose of collecting this information is to help provide you with the Services, provide information requested by you, enhance the Services, prevent and detect fraudulent or prohibited activity, assist with our marketing activities, develop new products, conduct internal business analyses, or for any other lawful purpose.  We may share this information as described in Section 2 below.

 

 

 

1.2.  Information Automatically Collected Through the Platform. GreenPortfolio, along with our third-party service partners, vendors and business partners may automatically collect information about you when you use the Platform or Services. The information automatically collected about you may include, but is not limited to, device ID, device type, browser type and version, geo-location information, computer and connection information, statistics on page views, traffic to and from the Service, ad data, IP address and standard web log information.

 

 

 

The purpose of collecting this information is to provide you with the Services, enhance the Services, prevent and detect fraudulent or prohibited activity, assist with our marketing activities, or conduct internal business analyses, or for any other lawful purpose.  We may share this information as described in Section 2 below.

 

 

 

1.3.  Information We Collect from Third Parties and Publicly Available Sources.  We may also collect information from third parties and publicly available sources.  Examples of these information sources include credit reports or background checks from vendors that you authorize us to receive information from (such as Equifax or Experian), and information obtained through third party services that provide a mechanism to share information you have provided to the applicable third party through the use of an application program interface (API), such as the Twitter or Instagram AP.  If we combine or associate information from other sources with information that we collect through the Platform and Services, we will treat the combined information in accordance with this Privacy Policy, the Terms of Use and applicable law.

 

 

 

The purpose of collecting this information is to help provide you with the Services, execute those actions requested by you, enhance the Services, prevent and detect fraudulent or prohibited activity, assist with our marketing activities, develop new products, or conduct internal business analyses, or for any other lawful purpose.  We may share this information as described in Section 2 below.

 

 

 

1.4.  Cookies and Web Beacons. We may use cookies, locally-stored objects and web beacons to automatically collect information about your use of the Platform or Service, and for the purpose of targeting and online behavior advertising, including on other sites or applications with which you interact.

 

 

 

Cookies are small bits of information that are transferred to and stored in separate files within your computer’s browser. The Platform and Services use both “persistent cookies” which remain on your computer after you have closed your browser as well as “session cookies” which exist only during a visitor’s online session and disappear from your computer when you close your browser.

 

 

 

Locally stored objects or “flash cookies” are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Locally stored objects are different than cookies because they are stored in different parts of your computer than cookies.

 

 

 

Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data.

 

 

 

You can set your browser to reject or disable cookies or to notify you when you are sent a cookie. However, if you reject or disable cookies, you may not be able to use all portions or all functionality of the Platform and Services. [Moreover, you may opt out from receiving some targeted advertising via certain of our partners by visiting the opt-out pages for the following: Network Advertising Initiative opt-out page (www.networkadvertising.org/choices), the Digital Advertising Alliance (www.aboutads.info), and the European Interactive Digital Advertising Alliance (http://youronlinechoices.eu). Furthermore, you may opt-out of the use of Google Analytics Cookies (https://tools.google.com/dlpage/gaoptout).

 

 

 

 

 

2. GreenPortfolio’s Disclosure of Information to Third Parties. We may share information as follows:

 

 

 

We may share information with third-party service providers who help us operate and support the Platform and Services, assist with marketing activities, conduct research and analytics, or assist with product development and actuarial analyses. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

 

 

For information you post on the Platform, such as photos, comments, or your profile, we may share this information with other users of the Platform and Services.

 

 

We may share information with our parent company, subsidiaries and corporate affiliates, joint venturers or other companies under common control with us.

 

 

We may share information with companies that acquire our business or assets.

 

 

We may share information with business partners who may wish to offer you products or services that may be of interest to you.

 

 

We may share your information when you report a complaint about a product or third party partner featured on the Platform with such third party.

 

 

We may use and share non-personal, de-identified, pseudonymous, or aggregated information we collect under any of the above circumstances. We may also share it with other third parties to develop and deliver targeted advertising on our Site and on websites or applications of third parties, and to analyze and report on advertising you see.  We may combine non-personal information we collect with additional non-personal information collected from other sources.  We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other business purposes.  We may share information with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other GreenPortfolio user to legal liability, or to protect our rights or property, or during emergencies when safety is at risk. We may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and we may provide access to your information to our legal counsel and other consultants in connection with actual or potential litigation.

 

 

We may share your information when you request answers or advice through our Services with third parties, experts, advisors and other agents.

 

 

We may share information with third parties when we forward Digital Millennium Copyright Act (“DMCA”) infringement notifications and counter-notifications as described in the Terms. DMCA infringement notifications and counter-notifications (including any personal information included as part of the notifications) will be forwarded as submitted to us without any deletions.

 

 

We may share information at your direction or with your authorization.

 

 

By submitting a request through our Services, you consent to the disclosure of your information to third parties in order for us to carry out your request. The collection and use of your information by third parties is subject to each third party’s specific privacy policy and terms of use. GreenPortfolio has no control over the means by which third parties further use or disclose your information.

 

 

 

In the event that you submit a request through our Services, a third-party provider may contact you directly with quotes or information by means of email, telephone, fax or otherwise.  Furthermore, you may receive telemarketing calls as a result of submitting such request, even if you are on the National Do Not Call Registry or any similar registry.

 

 

 

Please do not submit a request for information or services if you do not want your personal information shared as described herein. Upon submission of a request through the Services, we your information will be shared in the manner described above and the terms of the third party’s privacy policy will apply to that party’s use of your information.

 

 

 

3. No Spam, Spyware or Spoofing. GreenPortfolio and our users do not tolerate spam. To report GreenPortfolio-related spam or spoof emails to us, please forward the email to support@greenportfolio.com. You may not use our communication tools to send spam or otherwise send content that would violate the Terms.

 

 

 

4. Security. GreenPortfolio takes reasonable measures to protect the information you provide to us or submit through the Platform or Services against loss, theft and unauthorized use, disclosure, or modification. However, we cannot guarantee or warrant the security of any information you transmit to GreenPortfolio or submit through the Platform or Services, and you do so at your own risk. No internet or email transmission is ever fully secure or error-free. Emails sent to or through the Platform or Services may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email. If you have reason to believe that your interaction with us is no longer secure, please notify us of the situation as soon as possible by contacting us at the addresses listed below; if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the situation, even in those situations in which it is appropriate for use to do so. Users should take care with how they handle and disclose their Personal Information and should avoid sending Personal Information through insecure communication channels, such as email. Please refer to the Federal Trade Commission’s website at https://www.consumer.ftc.gov/topics/online-security for information about how to protect yourself online.

 

 

 

5. Accessing, Changing and Managing Your Information (for Non-California Residents). You may change and update the information you provide through the Platform, or change your preferences concerning how we use your information, as follows:

 

 

 

5.1. Changing or Updating Your Information. You may make changes to the user information you have provided in connection with your GreenPortfolio account by logging in to your account and changing the applicable information or by contacting us at support@greenportfolio.com. If you choose to terminate your account, you may also request that we delete your public-facing information by contacting us at support@greenportfolio.com. Following receipt of a request from you, we will take reasonable steps to update or correct your information, or delete your public-facing information if requested. However, unless prohibited by applicable law, postings or comments you provided and which are associated with your public profile prior to closing your account, will remain accessible.

 

 

 

5.2. Email Communications. You can make changes regarding receiving email communications from us within your GreenPortfolio account. You can also choose not to receive email communications from us by following the “unsubscribe” instructions in any email communication you receive from us.

 

 

 

6. California Privacy Rights. This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.  If you are a California resident, the CCPA may apply to the Platform and Services as they relate to business products featured on the Platform.

 

 

 

6.1. Eligible Requests. We take reasonable steps to help ensure that the Personal Information we collect from you is accurate, complete and current. In addition to accessing your Personal Information through the app or website, you may also request access to your Personal Information, request that erroneous or inaccurate Personal Information be updated, or (in certain circumstances) request deletion of your Personal Information, by contacting us via email at support@greenportfolio.com or by writing us at the mailing address listed below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

 

 

In the event that you request deletion of your data, we will retain the deletion request and may retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our service or our users, or take other actions otherwise permitted by law.  In addition, if certain information has already been provided to third parties (excluding processors) as described in this Privacy Policy, retention of that information may be subject to those third parties' policies.

 

 

 

In some instances, we may share your personal information with third parties for direct marketing purposes.  You can opt-out of this type of data-sharing by sending us an email at support@greenportfolio.com or writing us at the mailing address listed below.

 

 

 

6.2. Procedures for Request. We will respond promptly to your requests in accordance with applicable law and will try to respond to all legitimate requests within forty-five (45) days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. For your protection, we may only implement requests with respect to the personal information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain personal information for a longer period for recordkeeping purposes, such as retaining records relating to your purchases for warranty or accounting purposes.

 

 

 

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Platform because such information may be required in order for you to register as a user, purchase products or services, participate in a contest, promotion, survey, or sweepstakes, ask a question, or initiate other transactions.

 

 

 

You have the right to be free from discrimination for exercising your rights under the California Consumer Privacy Act.  GreenPortfolio does not discriminate against California residents for exercising their rights under the CCPA by:

 

-Denying you goods or services.

 

 

-Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

 

 

-Providing you a different level or quality of goods or services.

 

 

-Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

 

6.3. Submitting Verifiable Consumer Requests. When exercising the data rights described above, we will request that you submit a “verifiable consumer request.” The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

 

 

 

To verify a consumer request, consumers will be asked to provide their:

 

Name;

 

 

Phone Number;

 

 

Email Address;

 

 

Mailing Address; and

 

 

Matching pieces of personal information maintained by the Company in a signed declaration.

 

 

In response to the requests, consumers will be asked to confirm more than one data point of personal information maintained by the Company to verify their identity. We cannot provide personal information to consumers if we cannot verify your identity or authorization to make the request.

 

 

 

6.4 Authorized Agents. You may be permitted by applicable law to designate an authorized agent to exercise certain rights on your behalf. With the exception of authorized agents with power of attorney pursuant to Probate Code sections 4000 to 4465, consumers will be required to verify their own identity directly with the Company and provide written permission for an agent to act on their behalf.

 

 

 

6.5 Legal Exceptions Under the CCPA. The CCPA includes certain exceptions, which if they apply, exempt your personal information from the CCPA. This is not an exhaustive list, but the following types of data are exempt from the CCPA and may apply to personal information we have about you: (i) personal information or PHI covered by HIPAA; or (ii) personal information covered by the Gramm-Leach-Bliley Act.  If you make a CCPA Request that is subject to an exception, we will notify you of the basis for the exception in response to your request.

 

 

6.6 Requests Regarding Direct Marketing Partners. Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at support@greenportfolio.com or writing us at GreenPortfolio Inc, 365 W 125 St. #68, New York, NY 10027, attention: Privacy Policy.

 

 

 

7. Jurisdictional Issues. The Platform and Services are operated from the United States. GreenPortfolio may transfer, process or store your information with trusted affiliates, subsidiaries or contractors outside the U.S. in order to provide you with responsive, secure and accurate services.  Your agreement to the terms of this Privacy Policy or your submission of information in connection with the Platform and Services represents your agreement to this practice. If you do not want your information transferred to or processed or stored accordingly, you should not use the Platform or Services. If you elect to use the Platform or Services by outside of the United States, please be advised that you are doing so at your own risk and that you will be transferring information outside of your respective region to the U.S. for storage and processing.

 

 

 

8. Changes to Privacy Policy. We will make changes to this Privacy Policy on occasion. We will post the amended terms on the Platform and notify you of any material changes by posting a notice displayed on the Platform or by sending you an email at the address you have provided us. Please review this Privacy Policy or the Platform periodically in order to ascertain whether any changes have been made.

 

 

 

9. Third Parties. The Service may contain links to websites that are not owned or operated by GreenPortfolio. Please be aware that we are not responsible for the privacy practices of these websites. If you visit these websites or provide any information directly to parties other than GreenPortfolio (even if those websites display the GreenPortfolio brand), different policies may apply to the collection and use of your information. We encourage you to investigate and ask questions before accessing third-party websites or disclosing information to third parties.

 

 

 

10. No Use by Children. The Platform and Services are not intended for use by children under the age of 13. We will never knowingly collect information directly from children under the age of 13. If you are under the age of 13, you may not use the Platform or Services and please do not provide us with information of any kind whatsoever. If we become aware that a user is under the age of 13 and has submitted information to the Platform or Services, we will remove his or her information from our files and deactivate his or her account. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received personal information from a child under the age of 13, please contact us immediately at support@greenportfolio.com.

 

 

 

11. Retention of Your Information. We retain your information for as long as it is relevant for our operations, to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce the Terms of Use, or take other actions permitted by law. The information we retain about you will be handled in accordance with this Privacy Policy.