Privacy Policy

Last modified: July 9, 2019

Wefea, Inc. and Wefea Capital, LLC (collectively, “Wefea,” “we,” “our,” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy describes how Wefea collects and uses Personal Data about you through the use of our Site and through email, text, and other electronic communications between you and Wefea.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the websites www.wefea.com and www.slr67.net websites and the Wefea applications (collectively, our “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • on our Site;
  • in email, text, and other electronic messages between you and our Site; and
  • when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Wefea or any third-party; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

  1. Other Privacy Policies

For information about how we collect, use and share your financial information, please refer to our Financial Privacy Notice. By agreeing to this Privacy Policy you are also agreeing to our Financial Privacy Notice.

  1. Data Controller, Data Protection Officer, and Representative

Wefea is the data controller of the Personal Data you provide on the Site. At this time Wefea has not appointed a Data Protection Officer or a representative in the EU.

Wefea is the data controller of your Personal Data. At this time, Wefea has not appointed a Data Protection Officer or a representative in the EU. In the event Wefea does appoint a Data Protection Officer or a representative in the EU, Wefea will update this Privacy Policy. Wefea may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

  1. Children Under the Age of 18

Our Site are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Site. We will remove any information about a child under the age of 18 if we become aware of it.

Our Site are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Site. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Site or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of our Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at contactus@wefea.com.

  1. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of our Site (“Personal Data”):

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, credit/debit card numbers, bank or financial account numbers, date of birth, account numbers, driver’s license numbers or other government identifiers, salary or other personal financial information, Social Security Number, or any other identifier by which you may be contacted online or offline;
  • that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site, and SPECIFY TYPES OF INFORMATION; and/or your mobile application:
  • Usage Details. Details of the user’s access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that the end user accesses and uses on or through the App;
  • Device Information. Information about the user’s mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number;
  • Stored Information and Files. Can the App access metadata and other information associated with other files stored on the user’s device? This may include, for example, photographs, audio and video clips, personal contacts, and address book information; or
  • Real-time location data, as in location information collected through Google Maps, Apple Maps, Waze, or similar application.
  • about your internet connection, the equipment you use to access our Site and usage details.

We collect this information:

  • directly from you when you provide it to us;
  • automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
  • From third parties, for example, our business partners and affiliates.

Information You Provide to Us

The information we collect on or through our Site are:

  • information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing or purchasing our products and services, posting material, or requesting further services. We may also ask you for information when you participate in a promotion sponsored by us, and when you report a problem with our Site;
  • records and copies of your correspondence (including email addresses), if you contact us;
  • your responses to questions that we might ask you to answer;
  • details of transactions you carry out through our Site and of the provision of our services and products to you. You may be required to provide financial information before and during the use of our services; and
  • your search queries on the Site.

The Personal Data we collect from you is required to enter into a contract with Wefea, for Wefea to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

  • details of your visits to our Site. We may collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site; and
  • Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service by enabling us to:

  • estimate our audience size and usage patterns;
  • store information about your preferences, allowing us to customize our Site according to your individual interests;
  • speed up your searches; and
  • recognize you when you return to our Site.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.

  1. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

  • Consent. By using our Site, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Site;
  • Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Wefea and you; detect and correct bugs and to improve our Site; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; and develop our product and services;
  • To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you.
  • As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
  1. Special Categories of Information

We generally do not request you provide and do not process any special categories of Personal Data.

Wefea does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.

  1. Automated Decisions Making

We may process your Personal Data with automated decision making processes. A high-level description of the algorithms we use below.

Our processing of your personal data may include automated decision making, including profiling, which may produce a legal effect concerning you or similarly significantly affect you. The algorithms used for our automated decision making include using your salary information to determine if qualify for SLR 67 offerings or we may use information based on your location to connect you with an appropriate representative.

  1. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

  • provide our Site to you;
  • provide you with information you request from us;
  • enforce our rights arising from contracts;
  • notify you about changes; and
  • provide you with notices about your account

We use information that we collect about you or that you provide to us, including any Personal Data:

  • to present our Site and their contents to you;
  • to provide you with information, products, or services that you request from us or that may be of interest to you;
  • to fulfill any other purpose for which you provide it;
  • to provide you with notices about your account and your purchases, including expiration and renewal notices;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to notify you about changes to our Site or any products or services we offer or provide though them;
  • to allow you to participate in interactive features on our Site;
  • in any other way we may describe when you provide the information; and
  • for any other purpose with your consent.

With your consent, we may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Site and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request at contactus@wefea.com. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

  1. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

  • our subsidiaries and our affiliates;
  • our third-party service providers that we use to support our business;
  • to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
  • to comply with our legal obligations;
  • to enforce our rights; and
  • with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated and de-identified information about our users without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

  • to our affiliates;
  • to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services, payment processing services, and marketing services.
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Wefea, Inc.’s or Wefea Capital, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Wefea, Inc. or Wefea Capital, LLC about our Site’s users is among the assets transferred;
  • to third parties (including our affiliates) to market their products or services to you if you have consented to these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide the information; and
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wefea, Inc. or Wefea Capital, LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  1. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. We will only share your Personal Data with unaffiliated or non-agent third parties for promotional purposes with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to contactus@wefea.com.
  • Promotional Offers from Wefea. We will only use your contact information to promote our own or third parties’ products and services with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to contactus@wefea.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Wefea as a result of a product or service purchase, product service experience, or other transactions.
  • Targeted Advertising. We will only use information that we collect or you provide to deliver advertisements according to our advertisers’ target-audience preferences with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to contactus@wefea.com.

You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

  1. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

  • Access and Update. You can review and change your Personal Data by logging into the Site and visiting your “Account” or “User Profile” page. You may also notify us through the Contact Information below or through our Site’s live chat feature of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
  • Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
  • Portability. To the extent the Personal Data you provide Wefea is processed based on your consent that we process it through automated you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
  • Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
  • Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our terms of use.
  • Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
  • How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below and through the live chat feature of our Site. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
  1. Your California Privacy Rights

Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes.

If you use our Site when you are under the age of 18, you may request that we remove your User Contributions under certain circumstances. We do not advertise or market any goods and services that are identified as being inappropriate for children under the age of 18.

[** Wefea: This is applicable if you share personal information of California residents with third parties, including wholly owned or commonly owned affiliates, for the third party to market its own products and services to the California resident. If this is applicable, in addition to a "Privacy Policy" link on your homepage you must also include a "Your California Privacy Rights" link on your homepage (or better, in the footer of each web page) pointing to this section. **]California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Site that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding such activities in 2018). You may request this information once per calendar year. To make such a request, please send an email to contactus@wefea.com.

  1. Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

  1. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Site confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

  1. Consent to Processing of Personal Data In Other Countries Outside the European Economic Area

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

If you are a resident of the European Economic Area (“EEA”), in order to provide our Site, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by Wefea to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Site, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Site. To ensure your Personal Data (other than Personal Data you provide directly to us on our Site) is treated in accordance with this Privacy Policy, Wefea uses Data Protection Agreements between Wefea and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below. [** NTD: This should be modified if Wefea uses a different legal method of transfer, like Privacy Shield or some other method. **]

  1. Data Retention Periods

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

  • on our backup and disaster recovery systems;
  • for as long as necessary to protect our legal interests; and
  • and to comply with other legal requirements.

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

  • on our backup and disaster recovery systems;
  • for as long as necessary to protect our legal interests; and
  • and to comply with other legal requirements.

Wefea will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:

  • for as long as necessary to comply with any legal requirement;
  • on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
  • for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
  • for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
  1. Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Site. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Site’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by through a notice on the Site’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

  1. Contact Information

If you wish to contact us, you may do so through the contact information below.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may do so by using the information below.

To Contact Wefea (Controller)

By mail:

Wefea, Inc. and Wefea Capital, LLC

4695 Chabot Dr., Suite #200

Pleasanton, CA 94588

By email: contactus@wefea.com

By phone: (925)-218-1839