Effective Date: April 9, 2025
This Privacy Policy outlines how 50/Fifty Inc. and its subsidiaries or affiliates (collectively, "50/Fifty," "we," "our," or "us") process the information we collect about you through our websites, mobile apps, trading platform, and other online services (collectively, the "Services") and when you otherwise interact with us, such as through our customer service channels. If you are a California resident, please also see the "Notice to California Residents" section below.
We collect the following personal information you provide when you use our Services, like when you sign up for a 50/Fifty account ("Membership"), or have taken steps to register for Membership, request a transaction, enroll in a promotion or program, or otherwise engage or communicate with us:
1. Identity Data includes your full name, date of birth, gender, social security number, and other data on government-issued identification documents.
2. Contact Data includes your email address, mailing address, and telephone numbers.
3. Financial Data includes your bank account and payment card details, as well as information about your account balances, financial transaction history, credit history, tax information, and credit scores.
4. Profile Data includes your username and password, trades or orders made by you, and your interests, preferences, feedback, and survey responses.
5. Usage Information includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, your username, and other content you provide ("Usage Information").
6. Additional Information includes information that you submit via focus groups, contests, sweepstakes, job applications, customer support, or other similar means.
As is true of many Digital platforms, we collect certain personal information automatically when you visit our online services, including:
1. Location Data.
2. Usage and Device Data Collected Automatically Through Tracking Technologies.
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
1. Third-Party Data includes data that we collect from business partners, marketing, and vendor partners.
2. Account Linking. 50/Fifty offers account linking and aggregation services ("Linking Services") through Plaid Inc. ("Plaid").
3. Third Party Services. If you link, connect, or log in to your 50/Fifty Account with a third-party service (e.g. Google, Apple), the third-party service may send us information such as your profile information from that service.
4. Publicly Available Data includes your contact information and other information from publicly available sources.
We use and process the information we collect for purposes described in this Privacy Policy or as otherwise described to you on our Services or in connection with our Services. For example, we use your information to:
A. Create and process your account and deliver the Services to you, including to allow you to register for the Services and participate in trading activities and for 50/Fifty to authenticate your identity.
B. Send you transactional information, including confirmations, invoices, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages.
C. Communicate with you such as to respond to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback.
D. Conduct research and analytics to understand our visitors and customers and tailor our product offerings.
E. Provide you with updates about products and services offered by us and selected partners, as well as facilitating new contests, sweepstakes, promotions, and rewards.
F. Make suggestions and recommendations to you about things that are similar to those about which you have inquired or that may otherwise be of interest to you.
G. Monitor, administer, and enhance our Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
H. Enhance the safety and security of our Services, Platform, and Members, and investigate or provide notice of fraud or unlawful or criminal activity.
I. Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements.
J. Comply with applicable laws and legal obligations.
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information we collect. We may share your personal information in the instances described below.
For further information on your choices regarding your personal information, see the "Control Over Your Information" section below. We do not sell or rent your personal information to third parties, aside from substantial corporate transactions (described below).
A. Authorized third-party vendors and service providers. We share personal data with certain authorized and vetted contractors, subcontractors, third-party vendors, and service providers who help us run and protect our business.
B. Substantial corporate transactions. We may share personal data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
C. With your consent. We may share personal data with third parties when we have your consent.
D. Legal purposes. We may share personal data as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions.
Our Services may contain links to third-party websites and platforms. These third-party services have their own privacy policies, and we are not responsible for their practices.
We participate in interest-based advertising, where third-party networks collect data to serve targeted ads. You may opt out of interest-based advertising through your device settings or browser options.
You can manage your personal information through:
Under the California Consumer Privacy Act (CCPA), California residents may request:
If you access our Services from outside the United States, your data may be processed in a jurisdiction with different data protection laws. By using our Services, you consent to this data transfer.
Our Services are not intended for individuals under the age of 18. We do not knowingly collect or process data from minors. If we discover that a minor has provided personal information, we will take immediate steps to delete it.
We may update this Privacy Policy periodically. We will notify users of significant changes via email or in-app notifications. Continued use of our Services after updates constitutes acceptance of the revised policy.
By using the 50/Fifty platform, you acknowledge that you have read, understood, and agree to this Privacy Policy.