This Policy was last updated May 06, 2022
How We Define Personal Information
The Collection of Personal Information
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.
Personal Information You May Provide
We collect personal information from parents or guardians in order to facilitate the creation of custodial accounts or Uniform Gifts to Minors Act (“UGMA”) accounts at the Broker-Dealer for your children and to allow you to provide instructions to the Broker-Dealer in order for you to execute certain trades, including gifting financial investments to your friends and family. We collect personal information you provide in connection with our services. This information may include but is not limited to:
● Contact information such as name, email address, home address, phone.
● Identity Data, which includes, but is not limited to, first name, last name, username or similar identifier, title, date of birth, gender, tax identification or social security number or any other government issued identification number, and any form of identification that you provide to us so that we can verify your identity. Biometric and Sensory Data: includes facial scan images.
● Financial Data, which includes, but is not limited to, bank account and payment card details.
● Financial information such as bank or brokerage account numbers, types of investments, or other transaction information.
● Technical Data, which includes, but is not limited to, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
● Profile Data, which includes, but is not limited to, your username and password, your interests, preferences, feedback and survey responses.
● Usage Data, which includes, but is not limited to, information about how you use our website and services.
● Marketing and Communications Data, which includes, but is not limited to, your preferences in receiving marketing from us and our third parties and your communication preferences.
● Other Information, which includes, but is not limited to, information you may provide, such as information you provide when you contact us with questions, feedback, survey responses, participation in contests, promotions or other prospective seller marketing forms or devices, suggestions for improvements of our services or products, referrals, or otherwise communicate with us, and/or personal information you affirmatively disclose to us in connection with your interactions with us, including through your use of our services.
You have the ability to review and edit some contact information collected about you through our services.
In order to create an account with the Broker-Dealer for a child, we will need the parent of the child to supply the following information about the child:
● Child first and last name
● Child date of birth
● Child Social Security number
● Child address
For Village users that are not opening custodial investment accounts through our service, but are using the app to instruct the Broker-Dealer to send gifts to children (givers), we collect (in addition to other information):
● First Name
● Last Name
● Email Address
● Phone Number
● Financial information, such as bank or brokerage account numbers, credit card information, or other means of needed to send a financial gift to a child
Inviting Friends and Family Members
If you wish to refer friends or family members, you may share your referral link or QR code individually with those friends or family members. Village does not directly collect any personal information from your friends or family members when you share your referral link with them. Personal information is only collected if the referral chooses to sign up with Village. You will, however, receive certain communications from us about your referrals. For example, you will be notified if your friend or family member signs up for Village. We may also use the referral link for the purposes of instructing Broker-Dealer to credit their/your brokerage account with Broker-Dealer with any referral offer to which you may both be eligible. By sending a referral link to any party, you are disclosing to such party that you have a relationship with us and the Broker Dealer
Personal Information Automatically Collected
As is true of most digital platforms, we collect certain personal information automatically when you visit our online services, including, but not limited to:
● Technical Data and log file data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
● Location data, including your general geographic location based on your IP address or more precise location when accessing our services through a mobile device.
● Usage Data.
● Analytics data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”).
● “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our services, to monitor how many visitors view our services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Personal Information from Other Sources and Third Parties
We may obtain personal information from third party sources, which we often combine with personal information we collect either automatically or directly from you. We receive certain categories of personal information (as described above) from the following sources and third parties:
● Public databases and ID verification partners. We obtain information about you from public databases and ID verification partners to verify your identity and information you may provide us.
● Third party sources. We also obtain information about you from third party sources. Such information may include credit report information, identity verification information, fraud detection information, collection information, and information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
● Data append services, data brokers, and joint marketing partners. We receive personal information from these sources so that we can better understand which of our services may be of interest to you.
● External bank or brokerage account information providers. When you use certain services, we may collect from you, e.g., usernames, passwords, account numbers, and other account information for third-party websites and Internet banking and/or brokerage services. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf.
● Financial institutions. We obtain information about you from your financial institution to provide our service.
● We also receive: data from analytics providers such as Google; demographic data from advertising sources such as Facebook, Snapchat, Instagram, Twitter, and Google; data from merchants who you make transactions with using our services or who otherwise permit you to enroll in any cashback or discount program offered by such merchants; data from affiliate advertising networks; data from technical monitoring and error reporting service providers; and contact and document information from identity verification providers.
Use of Personal Information
We may use your personal information:
● To provide you with our services. For parents, we use the personal information you provide to set up and maintain your brokerage account at Broker-Dealer and deposit gifts into your brokerage account at Broker-Dealer for your child. Children’s information provided by parents is used to set up the brokerage account at Broker-Dealer in the child’s name. For givers, we use your personal information to process and deliver your instructions related to your gift to Broker-Dealer for it to provide the gift to your intended recipient.
We use your personal information if you choose to subscribe to our newsletter or sign up for our waitlist.
● To communicate with you about your account, such as to enable security functions such as two-factor authentication or to notify you about gifts or other account activity. Such communications may be made by email or, with your consent, by sending text messages to your mobile device.● To fulfill your requests for our products, programs, and services, to respond to your inquiries about our services, and to offer you other products, programs, or services that we believe may be of interest to you.
● To improve our services and run our services. We may use personal information to research, analyze, and understand how users access and use our services, both on an aggregated and individualized basis, in order to help us improve our services and develop new products. We also use personal information to operate, maintain, test, improve (including developing new products and services), enhance, update, monitor, diagnose, fix, and improve our services.
● To personalize your experience.
When you use our services and sites, as well other third-party sites and services. In this case, we might use tracking technologies like cookies.
● For marketing purposes. We may use your personal information to communicate with you regarding certain products, services or promotions offered by us or certain third-party products and services we believe you may be interested in, provided that you have not already opted out of receiving such communications.
● To send you locally relevant options. We can only do this if you make your location available to us. If you do, this can help us enhance the security of our sites and services, and customize our services by sending your relevant coupons and otherwise personalizing content for you (e.g., through appropriate ads and search results).
● To make it easy for you to find and connect with others. For example, if you let us access your contacts, we can suggest connections with people you may know.
● To detect, investigate, and prevent fraud and security issues. We use your personal information as necessary to protect us, our customers, and our business partners, including by investigating and preventing fraudulent activities, unauthorized access to the services, and other illegal activities.
● To verify information you have provided to us or to protect against fraudulent or illegal activities, including using information to validate your address through third party databases.
● To comply with all applicable laws and regulations.
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to comply with applicable anti-money laundering laws, to report to credit bureaus, and to respond to subpoenas or requests from the respective government authorities.
● To enforce and carry out contracts and agreements between us and you.
● To register you as a new customer.
● To assess each proposed transaction that you request through or in connection with services.
Sharing Personal Information
We may disclose your personal information in the following ways:
● Service providers. We share your personal information with service providers that we have engaged to perform services on our behalf, including to third parties, in connection with the services we provide to you. This includes service providers that: conduct research and analytics; create content; provide customer, technical or operational support; conduct or support marketing (such as email or advertising platforms); host the services; maintain databases; send or support online or mobile advertising; allow you to conduct transactions in connection with the services; and otherwise support or help us provide the services. Service providers also include payment processors, payment networks, external bank account information providers, credit reporting and scoring agencies, providers of identity services, risk investigation and mitigation service providers, hosting, technology and communication providers, security and fraud prevention consultants, risk investigation and mitigation service providers, support and customer service vendors and product fulfillment and delivery providers. You acknowledge that such third parties will have access to your personal information on a need basis, in connection with the services rendered by us.
● Advertising and marketing partners. We share your personal information with other third parties, including advertising/analytics partners who enable the delivery of interest-based advertising to users, as well as vendors that provide specific services we do not.● Business Transaction or Reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction.
● Legal Obligations and Rights. We may disclose personal information to third parties, such as legal advisors and law enforcement:
● In connection with the establishment, exercise, or defense of legal claims;
● To comply with laws or to respond to lawful requests and legal process;
● To detect, suppress, or prevent fraud;
● To reduce credit risk and collect debts owed to us;
● To protect the health and safety of us, our customers, or any person; or
● As otherwise required by applicable law.
● Consent. We may disclose personal information about you to certain other third parties with your consent.
● We may share your personal information as appropriate to carry out any other legitimate business purposes permitted by law, such as sharing with our service providers and other partners that provide support to us when providing services to you.
What We Collect When Using Cookies
How We Use That Information
Your Choices About Cookies
Your Choices About Online Ads
Links to Other Websites and Services
The Site may contain links to outside services and resources, the availability and content of which Village does not control. We are not responsible for examining or evaluating, and we do not warrant the offering of these services and resources or the content of these websites. Village does not assume any responsibility or liability for the actions, products, and content of these and any other websites. Any concerns regarding any such services or resources should be directed to the service or resource.
Protecting Personal Information
While we take reasonable steps to protect your personal information, nothing on the internet is 100% secure. For these reasons, we cannot guarantee that all of your personal information will never be disclosed in ways you do not expect, or which are not described in this Policy. While we protect our systems and services, we cannot guarantee the security of your information during transmission and any transmission is at your own risk. Also, you are responsible for keeping your password(s) and account information safe and private. You are also responsible for making sure your personal information is accurate and up-to-date.
Children's Personal Information
Our Site and online services may permit parents and guardians to provide instructions and receive service from Broker-Dealer related to brokerage accounts opened and maintained on behalf of minor children under the age of 13. Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
Transfer of Information
Our services are currently designed for use only in the United States. If you are using our services from another jurisdiction, your information may be processed in the United States or other countries that may not provide levels of data protection that are equivalent to those of your home jurisdiction.
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at email@example.com. California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to firstname.lastname@example.org.