Privacy Policy

Effective on September 1, 2017

Our mission is to provide cloudbased CFO services for the next generation of growing businesses. We are committed to being transparent with you about the data we collect about you and how it is used and shared.  By using our Services, you consent to our use of your data under this Privacy Policy.

Table of Contents:
1. Introduction
2. Information We Collect
3. How We Use Your Data
4. How We Share Information
5. Your Choices & Obligations
6. Other Important Information

1. Introduction

Our registered users (“Members”) share their professional and business identities and business data, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find business opportunities. Content on some of our services is available to non-members (“Visitors”).

1.1 Data Controllers
You are entering into the Terms of Service with BenchmarkCFO, Inc., who will be responsible for your personal data provided to, or collected by or for, our Services.

1.2 Services
This Privacy Policy applies to BenchmarkCFO.com, BenchmarkCFO-branded apps, and other BenchmarkCFO-related sites, apps, communications and services (“Services”), including off-site Services, but excluding services that state that they are offered under a different privacy policy.

1.3 Consent
If you use our Services, you consent to the collection, use and sharing of your personal data under this Privacy Policy (which includes our Cookie Policy and other documents that may be referenced in this Privacy Policy) and agree to the Terms of Service. We may provide you choices that allow you to opt-out or control how we use and share your data.

1.4 Change
We may modify this Privacy Policy, and if we make material changes to it, we may provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. Your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

2. Information We Collect

2.1 Information You Provide To Us

Registration
To create an account you provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, we ask you for payment (e.g., credit card) and billing information.

Profile
You have choices about the information on your profile. Profile information helps you to get more from our Services, including helping other Members and business opportunities find you. It’s your choice whether to include sensitive information on your profile. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey, submit a document, or send invitations.

2.2 Information From Others

Content and News
You and others may post content that includes information about you on our Services (as part of blog posts, feed updates and comments, videos). We may collect public information about you, such as business-related news and accomplishments and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news).

Partners
We may receive personal data about you when you use the services of our customers and partners.

2.3 Service Use
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install one of our mobile apps, or share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

2.4 Cookies, Web Beacons and Other Similar Technologies
We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies and similar technologies. You can control cookies through your browser settings and other tools (see http://www.aboutads.info/choices and http://www.youronlinechoices.eu).

2.5 Your Device and Location
When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.

2.6 Messages
We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a BenchmarkCFO connection request, we track whether you have acted on it and will send you reminders. We may also use automatic scanning technology on messages.

2.7 Workplace Provided Information
An employer (or other person or entity procuring our Services for your use) may provide us information about their employees or contractors who make use of these Services.

2.8 Sites and Services of Others
We receive information about your visits and interaction with services provided by others when you log-in with BenchmarkCFO or visit others’ services that include our plugins (such as “Share on BenchmarkCFO”), ads, cookies or similar technologies.

2.9 Other
Our Services are dynamic and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we may notify you and may also modify this Privacy Policy.

3. How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide, support, personalize and make our Services (including ads) more relevant and useful to you and others.

3.1 Services
We use your data to authenticate you and authorize access to our Services.

3.2 Premium Services
We sell premium Services that provide our customers customized functionality and tools (including messaging and activity alerts) as part of our financial management solutions.

3.3 Communications
We will contact you through email, notices posted on our websites or apps, messages to your BenchmarkCFO inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

We may also enable communications between you and others through our Services, including for example invitations, groups and messages between connections.

3.4 Advertising
We target (and measure the performance of) ads to Members, Visitors and others both on and off of our Services through a variety of ad networks and exchanges, using the following data, whether separately or combined:

  • Data from advertising technologies on and off of our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Member-provided information (e.g., contact information, title and industry);
  • Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 2.3;
  • Information from others (e.g. advertising partners, publishers and data aggregators);
  • Information inferred from data described above (e.g., using job titles to infer age, industry, seniority, and compensation bracket; or names to infer gender).

We may show you ads called sponsored content which look like similar non-sponsored content, except that they are labeled ads or sponsored. If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the ad provider.

Ad Choices
We may adhere to self-regulatory principles for interest-based advertising and may participate in industry opt outs from such ads. This does not opt you out of receiving advertising – you will continue to get generic ads or ads by advertisers not listed with these self regulatory tools.

Info to Advertisers
We do not share your personal data with any third-party advertisers or (other than hashed or device identifiers, to the extent they are personal data in some countries) ad networks for their advertising without your separate permission. However, if you click on an ad, the ad poster will know you visited the page that you clicked on. Also, advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we may seek to contractually require such advertisers to obtain your explicit, opt-in consent before doing so.

3.5 Marketing
We use data and content about Members for invitations and communications promoting membership, engagement, and our Services.

3.6 Developing Services and Research

Service Development
We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

Other Research
We seek to create economic opportunity for members and to help them be more productive and successful. We use the data available to us to research social, economic and workplace trends and policies that help bridge the gap in various industries and geographic areas. In some cases, we may work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys
Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys and you have choices about the information you provide. You may opt out of survey invitations.

3.7 Customer Support
We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

3.8 Aggregate Insights
We use your information to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our users, their profession or industry, the number of ad impressions served or clicked on, or the demographic distribution of visitors to a site.

3.9 Security and Investigations
We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our Terms of Service or this Privacy Policy and/or attempts to harm our Members or Visitors.

4. How We Share Information

4.1 Our Services

Profile
You may be able to make your profile visible to other Members and customers of our Services.

Posts, Likes, Follows, Comments, Messages
Our Services may allow viewing and sharing information including through posts, follows, likes and comments.

  • When you share a post (e.g., an update, video or blog), the default (which you can change) may be to share it publicly. Others who are not your connections may be able to find (including through search engines) and see your post.
  • When you like, comment on or share another’s post, others will see it, including the person who initiated the post.
  • In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile unless you change the default settings.
  • Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
  • When you follow a person or organization, you are visible to others and that “page owner” as a follower. We provide aggregate insights about the followers and viewers to the respective page owners.
  • We let senders know when you act on their message, subject to your settings where applicable.

4.2 Communication Archival
Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We may enable such archiving outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.

4.3 Others’ Services
When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may be able to link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your BenchmarkCFO contacts into its own service. You may revoke the link with such accounts.

Subject to your settings, excerpts from your profile may appear on the services of others (e.g., search engine results and social media aggregators). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

4.4 Related Services
We will share your personal data with our affiliates to provide and develop our Services. We combine information internally across the different Services covered by this Privacy Policy. For example, BenchmarkCFO could personalize your feed or recommendations based on your activity history, because we are able to identify you across different Services using cookies or similar technologies.

4.5 Service Providers
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated to not to disclose or use it for other purposes.

4.6 Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of BenchmarkCFO, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

4.7 Change in Control or Sale
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5. Your Choices & Obligations

5.1 Data Retention
We retain the personal data you provide while your account is in existence or as needed to provide you Services. Even if you only use our Services sporadically, we will retain your information and keep your profile open until you decide to close your account. In some cases we may choose to retain certain information in a depersonalized or aggregated form.

5.2 Rights to Access and Control Your Personal Data
We may provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We may offer access to the personal data we have about you.

5.3 Account Closure
If you choose to close your BenchmarkCFO account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

6. Other Important Information

6.1. Security
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6.2. Cross-Border Data Transfers
We process data both inside and outside of the United States.

BenchmarkCFO may participate in the EU-U.S. and Swiss-U.S. Privacy Shield frameworks.

6.3. Direct Marketing and Do Not Track Signals
We currently do not share personal data with third parties for their direct marketing purposes without your permission.

6.4. Contact Information
If you have questions or complaints regarding this Policy, please first contact us at support@benchmarkCFO.com.  You can also reach us at:

BenchmarkCFO, Inc.
Attn: Legal Dept. (Privacy Policy and Terms of Service)
1041 Market Street #215
San Diego, CA 92101