Privacy Policy

Effective date: May 31, 2021

By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Coral's Services is at all times subject to our User Agreement, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the User Agreement.

We will use and share any Non-Public Information as defined by the Gramm-Leach-Bliley Act ("GLBA") that we collect from or about you related to your use of that product or service in accordance with our GLBA Privacy Notice.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting support@owncoral.com. At Coral, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data.

Table of Contents

What this Privacy Policy Covers
Personal Data
How We Share Your Personal Data
Tracking Tools, Advertising and Opt-Out
Data Security and Retention
Personal Data of Children
State Law Privacy Rights
Changes to this Privacy Policy
Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as“personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data we Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Profile or Contact Data
Examples of Personal Data We Collect

·   First and last name
·   Email address
·   Phone number
·   Mailing Address
·   Country of Residency
·   Date of birth

Categories of Third Parties With Whom We Share this Personal Data

·  Service Providers
·  Advertising Partners
·  Analytics Partners
·  Business Partners Parties You Authorize, Access or Authenticate

Identifiers
Examples of Personal Data We Collect

·   Social security number
·   Tax ID Number

Categories of Third Parties With Whom We Share this Personal Data

·  Service Providers
·  Advertising Partners
·  Analytics Partners
·  Business Partners Parties You Authorize, Access or Authenticate

Payment Data
Examples of Personal Data We Collect

·   Billing address, phone number, and email
·   Bank account information (including ACH/ wiretransfer information)

Categories of Third Parties With Whom We Share this Personal Data

·  Service Providers (specifically our payment processing partners, currently Plaid Inc., and Dwolla, Inc.)
·  Parties You Authorize, Access or Authenticate

Commercial Data
Examples of Personal Data We Collect

·   Investment history
·   Consumer profiles

Categories of Third Parties With Whom We Share this Personal Data

·  Analytics Partners

Online Identifiers
Examples of Personal Data We Collect

·  Unique identifiers such as email address and password

Categories of Third Parties With Whom We Share this Personal Data

·  Analytics Partners

Device/IP Data
Examples of Personal Data We Collect

·   IP address
·   ServerType of device/operating system/browser used to access the Services

Categories of Third Parties With Whom We Share this Personal Data

·  Analytics Partners

Web Analytics
Examples of Personal Data We Collect

·   Web page interactions
·   Referring webpage/source through which you accessed the Services

Categories of Third Parties With Whom We Share this Personal Data

·  Advertising Partners
·  Analytics Partners

Social Network Data
Examples of Personal Data We Collect

·   Advertising Partners

Categories of Third Parties With Whom We Share this Personal Data

·  Advertising Partners
·  Analytics Partners

Consumer Demographic Data
Examples of Personal Data We Collect

·   Age / date of birth
·   Zip code

Categories of Third Parties With Whom We Share this Personal Data

·  Service Providers

Professional or Employment-Related Data
Examples of Personal Data We Collect

·   Industry or company
·   Income

Categories of Third Parties With Whom We Share this Personal Data

·  Advertising Partners
·  Analytics Partners

Geolocation Data
Examples of Personal Data We Collect

·   IP-address-based location information

Categories of Third Parties With Whom We Share this Personal Data

·  Service Providers
·  Analytics Partners

Inferences Drawn From Other Personal Data Collected
Examples of Personal Data We Collect

·   Profiles reflecting user attributes

Categories of Third Parties With Whom We Share this Personal Data

·  Advertising Partners
·  Analytics Partners

Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data We Collect

·   Identifying information in emails or letters you send us Information relating to accreditation status (such as household income, net worth and investment goals)

Categories of Third Parties With Whom We Share this Personal Data

·  Service Providers

Categories of Sources of Personal Data
You

When you provide information directly to us.

·      When you create an account or use our interactive tools and Services. 
·      When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
·      When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically.

·      Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
·      If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.   

Third Parties

Vendors

·      We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

·      We may use vendors to obtain information to generate leads and create user profiles.

Advertising Partners

·      We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Social Networks

·      If you provide your social network account credentials to us or otherwise sign into the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us. 

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

·      Creating and managing your account or other user profiles.

·      Processing orders or other transactions; billing.

·      Providing you with the products, services or information you request.

·      Meeting or fulfilling the reason you provided the information to us.

·      Providing support and assistance for the Services.

·      Improving the Services, including testing, research, internal analytics and product development.

·      Personalizing the Services, website content and communications based on your preferences.

·      Doing fraud protection, security and debugging.

·      Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Marketing the Services

·      Marketing and selling the Services.

Corresponding with You

·     Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Coral or the Services.

·     Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

·     Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

·     Protecting the rights, property or safety of you, Coral or another party.

·     Enforcing any agreements with you.

·     Responding to claims that any posting or other content violates third-party rights.

·     Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

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Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use ourServices, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

·      Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

·      Functional Cookies. Functional Cookies are used to record your choices and settings regarding ourServices, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

·      Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use ourServices. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the GoogleAnalytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as(depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or“options” section of your browser’s menu. To find out more information aboutCookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account.Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the User Agreement, we do not knowingly collect or solicit Personal Data about children under 13  years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at support@owncoral.com.

State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@owncoral.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@owncoral.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Coral website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use theServices after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at support@owncoral.com or by mail at:

45 School Street, STE 202,
Boston, MA 02108