Privacy Policy

Defiance Analytics (“we,” “us,” or “our”) has adopted this privacy policy (“Policy”) with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to provide service to you in an accurate and efficient manner and to be compliant with all applicable laws. To do so, we must collect and maintain certain personal information about you. We want you to know the nature of the information we collect and how we use and safeguard that information. 

This Policy applies when you use our website and any other services we operate that link to this Policy (the “Services”).  In addition, Section IV provides information about lead generation data we collect and process in connection with the e-mail services we provide to our customers.  However, the Policy does not apply with respect to personal information that we process on behalf of our customers.  

I. Sources and Information We Collect:

We collect personal information directly from you, automatically (including through cookies, pixels and similar technologies), and from third parties and publicly available sources.  The includes, as applicable:‍

• Information about your computer, Internet connection, page interaction information, and page response times that we may obtain through the use of cookies; 
• Your contact information (including email and business address and phone number), such as when you request additional information from Defiance Analytics, or its affiliates, via online forms, inquiries at trade shows, or by direct contact with a company representative.  [We also may collect such information in connection with lead generation services that we provide our customers.];
• Information about your interest in certain financial products and Services or content that may relevant for your work, based on your interactions with us and the materials we provide; and 
• Login details, such as email address and password, if you utilize Services that require login credentials.

• Internet, electronic activity, and other information automatically from the devices and browsers that you use, including Information about your computer or other device(s), Internet Protocol (“IP”) address, time zone setting and location; browser type and version; browser plugin types and versions; operating system and platform; Internet service provider and Internet connection, page interaction information, page response times, pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and content you interact with within the Services; and the technology on the devices you use to access these Services.
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We may aggregate or de-identify the information described above, or otherwise receive such information in deidentified form.  Aggregated or de-identified data that we do not attempt to reidentify is not subject to this Policy.

II. How We Use Information: 

We use personal information we collect for the following reasons:

• To administer our website, help diagnose programs, and track the number of visitors to our website;
• To provide our products and Services to you and other customers and to provide you with information you have requested;
• To contact you regarding financial products and Services that you may be interested in or that are relevant for your work;
• To operate, maintain, improve our Services;
• To create aggregated statistical data and other aggregated and/or inferred non-personal information about products, Services, and content that may be of interest to you, which we may use to provide and improve our Services;
• To keep our Services safe and secure; and
• To comply with applicable laws and regulations, and to exercise our legal rights or defend against legal claims.

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III. Information We Disclose:

We may disclose personal information to parties including:

• Authorized third-party vendors and service providers. We may disclose information we collect to third-party vendors and service providers that provide services to us for a variety of business purposes, such as customer service, advertising and marketing, maintaining or services accounts, and verifying customer information.
• Customers.  As described in Section IV, we also may provide certain information to our customers, such as in connection with lead generation services we provide our customers.
• Corporate affiliates. We may disclose information we collect with our corporate affiliates.
• Business transfers. We may disclose information we collect in connection with a substantial corporate transaction, such as a sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy. 
• Legal purposes. We may disclose information we collect to respond to subpoenas, court orders, legal process, law enforcement request, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of Defiance Analytics, our affiliates, users, or the public. This may include to, among others, persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); our attorneys, accountants, and auditors; and as otherwise required or provided by law.
• Other recipients. We may disclose information we collect for any other purposes disclosed to you at the time we collect the information or pursuant to your authorization or consent.

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IV. Lead Generation and Other Services

We collect [publicly available] contact and professional information about financial advisors as part of the provision of lead generation services for our customers.  We may share this information with our customers as part of our services.  

In addition, we process personal information on behalf of our customers.  Where that is the case, our customers are responsible for providing appropriate notice to the relevant individuals about the data that we handle on their behalf, for obtaining any required consents for processing, and for enabling you to exercise your consumer rights in accordance with relevant privacy laws. 

V. Cookies, Pixels, and Similar Technologies

This section explains what cookies are, how we use cookies, how third -parties we partner with may use cookies on Our Website, and your choices regarding cookies.
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What are cookies?

Cookies, pixels, and similar tracking technologies (collectively, “cookies”) are small text files or code sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the website or a third party to recognize you and make your next visit easier and the website more useful to you.

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
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How Defiance Analytics uses cookies

When you use and access Our Website, we may place a number of cookie files in your web browser. We use cookies for the following purposes: (i) To enable certain functions of Our Website, (ii) to provide analytics about the use of our Services, (iii) to store your preferences, and (iv) for the other purposes described below. These include third-party cookies such as Google Analytics, for analyzing usage statistics; for sampling user behavior on Our Website to improve usability; and Hubspot, for storing the information you supply by completing a form so you need only enter it once, and for subsequent tracking of your activity on Our Website.

We use both session and persistent cookies on Our Website and we use different types of cookies to run Our Website: 

• Essential cookies are required to enable basic website functionality. They are used to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure, such as to authenticate users and prevent fraudulent use of user accounts;
• Analytics cookies help us understand how our website performs, how visitors interact with the site, and whether there may be technical issues. They are also used to track information how Our Website is used so that we can make improvements. We may also use analytics cookies to test new pages, features or functionality of Our Website to see how visitors react to them.
• Marketing cookies are used to deliver advertising that is more relevant to you and your interests.‍
• Personalization cookies allowing the website to remember choices you make (such as your user name, language, or the region you are in).
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Your choices regarding cookies

If you would like to block cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you block cookies or refuse to accept them, you might not be able to use all the features we offer on Our Website, you may not be able to store your preferences, and some of our pages might not display properly.

VI. Retention of Your Information:

We retain personal information for as long as necessary to fulfill the purpose(s) for which it was collected, and thereafter as necessary to comply with applicable laws and contractual obligations.
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VII. Security of Your Information:

We restrict access to your personal information to those employees who need to know that information to contact you or to otherwise assist in promoting certain financial products. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your personal information. We store your information on servers located in the United States.
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VIII. Viewing, Modifying, and Deleting Your Information:

If you would like to access, correct, amend, or delete any personal information we have related to you, or if you would like us to stop processing your personal information, we invite you to contact us at support@defianceanalytics.com or 78 SW 7th St. 8th Floor Miami, FL, 33130. We will respond to your request in accordance with applicable law, including any applicable exceptions or exemptions. 
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IX. Links to Third-Party Websites:

While browsing our website, you may encounter links to third-party websites, such as websites on which you can purchase our products. We make no guarantees about your data privacy on such third-party websites. You should review the privacy policy of any third-party website prior to giving any information to that website.
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X. Communications and Choice / Opt-Out:

From time to time, we may contact you regarding financial products in which you may be interested, or as otherwise necessary to comply with applicable laws or agreements. We may contact you via email, telephone, text messages, and postal mail. Please note that emails and text messages are not necessarily a secure method of communication, and we will never ask for your login information or credit card information by email or text message.

XI. Children

This website is not intended to be used by children, and we do not knowingly collect or sell any information from children, as defined by applicable law.

XII. Contact Us

If you have any questions about this support@defianceanalytics.com.

XIII. Changes to Our Privacy Policy

We may modify this Policy from time to time. Any changes to this Policy will be posted at this URL and will be effective when posted. Please check back periodically to keep apprised of any changes made to our Policy.
‍XIV. California Privacy Rights Under the CCPA

The California Consumer Privacy Act of 2018, as amended by the CCPA Regulations (“CCPA”), provides California consumers with certain rights regarding their personal information.

The section “Information We Collect” explains the specific details of personal information Defiance Analytics collects. The CCPA also requires listing categories of personal information collected. As defined by the CCPA, we collect, or have collected in the past 12 months, the following categories of personal information:

• Identifiers (such as name, email address, postal address, phone number, IP address)
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as name, contact information, employment)
• Commercial information (such as transaction information, purchase history, payment information)
• Internet or other electronic network activity information (such as browsing history, search history, online behavior)
• Professional or employment-related information (such as job title and your business contact information)
• Inference data about you (such as additional features, products, or services we think would be of interest to you)
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Personal information, as defined by the CCPA, does not include publicly available information from government records and de-identified or aggregated consumer information.

We use and disclose the categories of personal information we collect from and about you consistent with the business purposes discussed in the section “Information We Collect.”

The CCPA also sets forth obligations for businesses that “sell” personal information to third parties.  We do not “sell” personal information and have not sold any personal information in the past 12 months.

If you are a California resident, you may have the following consumer rights under the CCPA in addition to the choices identified in the section above on “Viewing, Modifying, and Deleting Your Information”:

• Right to know about personal information collected, used, disclosed, or sold. You have the right to request that we disclose to you the categories of personal information we collect or disclose (or have collected or disclosed in the past 12 months) about you, the categories of sources of such information, the business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share/disclose personal information.  This information is also explained throughout this Policy.
• Right to request deletion of personal information. You have the right to request the deletion of your personal information we have collected from you, subject to certain conditions and limitations under the law.
• Right to Opt-Out of the sale of personal information. The CCPA provides consumers with the right to opt-out of the sale of their personal information. We do not share, sell, rent, or trade User personal information with third parties for their commercial purposes as defined under the CCPA.
• Right to non-discrimination for exercising a consumer privacy right. We will not discriminate against you for exercising any of your rights under the CCPA.
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To exercise any of your rights as set out above, please contact us by emailing support@defianceanalytics.com or by contacting us at 78 SW 7th St. 8th Floor Miami, FL, 33130. You may be required to verify your identity before we are able to fulfill your request, and we may request information from you for that purpose. You can designate an authorized agent to make a request on your behalf. To do so, you will need to provide a written authorization or power of attorney signed by you for the agent to act on your behalf. You will still need to verify your identity with us. Certain information may be exempt from requests under applicable law.
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