Privacy Policy

Last Modified: 03/19/2018

Protecting your privacy is very important to us. Our goal is to treat the personal information you furnish us with the utmost respect and in accordance with this Privacy Policy. We request that you carefully read this Privacy Policy and our Terms of Use before using the website. By visiting, viewing or using the website in any manner, you are agreeing to the terms set forth in this Privacy Policy, as well as the Terms of Use for the website.

This policy describes the types of personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”) we may collect from you or that you may provide when you visit our website and our practices for collecting, using, maintaining, protecting and disclosing that information. PII includes information such as your name, address, phone number, ZIP code, email address and similar information. Non-PII is non-personally identifiable information, and may include, for example, your IP address, browser type, domain names, access dates and similar information.

 

Personal Information We Collect and How We Collect It

You can visit us on the internet without telling us who you are or revealing any information about yourself, including your email address. In this case, our web servers may collect the name of the domain you used to access the internet (such as aol.com) and the website you came from and visit next. This information is used by us and our business partners to measure the number of visits, average time spent, page views and other statistics about visitors to our website in general. We also use this data to monitor site performance and to make the site easier and more convenient to use.

There are times when we may ask you for information about yourself to assist us in meeting your various needs. In these cases, your browsing will no longer be anonymous to us. To provide these services, we may need to ask you directly to provide, among other things, your name, Social Security number, physical address, ZIP code, email address and phone number.

If you opt-in to text messaging/SMS services we may text message you to the number we have received from you until or unless you opt-out. We do not share your mobile number with anyone. SMS consent is not shared with third parties. Details of our SMS Privacy Policy can be found at the end of this Privacy Policy.

Please note that we do not knowingly solicit information from children and we do not knowingly market our products or services to children.

 

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information, for any purpose including, but not limited to:

  • Providing you with materials you have requested
  • Contacting you for the potential purchase of insurance or other financial products
  • Personalizing our contact with you
  • Operating, providing, improving and maintaining our website
  • Developing new products and services
  • Preventing abusive and fraudulent use of our website
  • Sending you administrative messages, content and other services and features in which we believe you may be interested
  • Any other administrative and internal business purposes permitted by law

 

Protection of Your Information

We maintain a variety of security measures to protect against the loss, misuse and alteration of information under our control. Although we make good-faith efforts to maintain the security of such information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure or alteration. Further, we cannot guarantee that our security measures will prevent unauthorized persons from accessing or obtaining this information. We assume no liability to you or any other party in relation to the unauthorized access, use or alteration of any information provided to us.

 

Notification in the Event of Data Breach

As previously stated, although we make good-faith efforts to maintain the security of your information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure or alteration. In the event your personally identifiable information is breached by an unauthorized party, we will comply with your applicable state law in notifying you of the breach.

 

Accessing or Correcting Your Information

You may access the data collected by us about you by sending a request to the address listed below. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the identity of the person seeking the correction.
If you wish to access, remove or correct any personally identifying information you have supplied to us or if you have any questions about this Privacy Policy, you may contact us by sending a letter via the U.S. Mail to: 10089 Willow Creek Rd., #200, San Diego, CA, 92131. Please understand that to protect your privacy and security, we may also need to take reasonable steps to verify your identity before granting access or making corrections.

 

Sharing Information and Consumer Choice

We do not share your mobile phone number with anyone.

SMS consent is not shared with third parties.

However, we may share other non-mobile phone number data to the extent provided by applicable law, with our affiliated companies and third parties for the purpose of fulfilling your requests as well as offering you other services that may be of interest to you. It is not shared with any third party, unless requested by you or permitted by law. Under no circumstance will we sell your information or transfer your information to any ad network, ad exchange, data broker or other advertising or monetization related service. We may also aggregate statistics that we gather about our customers, sales, traffic patterns and services, and provide these statistics to third parties; however, when we do, these statistics will not include any personal information that identifies individuals.

 

Cookies

If you are browsing, a cookie is used to help us measure the number of visits, average time spent, page views and other statistics relating to our website. This cookie, by itself, does not reveal to us your email address or who you are. If you decide to register online with us, we may collect additional information to provide tailored offerings or content to you. In this case, we use cookies to recognize you on subsequent visits and make your online experience more convenient.

Cookies are small pieces of data stored by your internet browser on your computer's hard drive. They cannot be used to collect data from your hard drive, obtain your email address or personal identifying information about you. You may set your browser to notify you when you receive a cookie or to prevent cookies from being sent. Please note, however, that by not accepting cookies, you will limit the functionality we can provide you when you visit our site.

 

Handling of ‘Do Not Track’ Signals

The California Online Privacy Protection Act provides that a website operator must:

“Disclose how the operator responds to web browser ‘do not track’ signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services, if the operator engages in that collection.”

It is important for you to know that we do not engage in the type of collection referenced in the California law.

 

Changes to This Privacy Policy

We reserve the right to modify or supplement this Privacy Policy statement at any time. If we make any material change, we will update our website to include such changes. A notice that our privacy policy has been updated will be displayed on our website homepage. You are responsible for periodically visiting our website and this privacy policy to check for any changes.

SMS Privacy Policy

Colva Capital is committed to protecting your privacy. This Privacy Policy (the “Policy”) governs how we treat the Personal Information that we collect and receive from you in connection with your use of the SMS Service (“Service”), which we make available to you through a third-party service provider. This Policy is incorporated into the Terms of Service.

By using the Service, you agree to the terms of this Policy. Colva Capital reserves the right, in its sole discretion, to modify or change this Policy at any time with or without prior notice to you. The date of the last update will be posted at the top of this Policy for your convenience. This Policy, and any changes, are effective as soon as posted. Your continued use of the Service following the posting of any changes to the Policy constitutes your full acceptance of those changes.

“Personal Information” is information that individually identifies you, such as your mobile phone number or user/screen name, as well as the any Personal Information that you choose to include in messages you send through the Service.

What Personal Information is collected about you

Through the use of the Service, Colva Capital will receive the following information from our third party service provider: your mobile phone number when you send a text message to us, the text of messages that you send to other users of the Service, any user or screen name that you select in connection with the Service, as well as any comments or feedback regarding the Service that you send to us.

How Colva Capital uses Personal Information about you

We use Personal Information to (a) provide you with the Service, (b) process and respond to inquiries, (c) improve the Service, (d) if necessary, contact you with important announcements or messages, (e) conduct research, and (f) provide anonymous reporting for internal and external clients and partners.

Each message that you send through the Service (either to us or to other users of the Service) is stored on our servers. We retain these messages on our servers. Colva Capital utilizes servers and services owned by third parties.

Disclosure of your information

We will not rent or sell your Personal Information to other companies or individuals, unless we have your consent. We may use or disclose such information in any of the following limited circumstances:

  • We have your consent.
  • We need to enforce our Terms of Service.
  • We provide such information to trusted businesses or persons for the sole purpose of processing Personal Information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Policy and appropriate confidentiality and security measures.  If the third party fails to comply with our terms, Colva Capital is not accountable in any way for any liability or reimbursement.
  • We provide such information to third parties who have entered into non-disclosure agreements with us.
  • We provide such information to a company controlled by, or under common control with, Colva Capital for any purpose permitted by this Policy.
  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights, or the legal rights of others, or defend against legal claims.
  • We believe it is necessary to share Personal Information to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Colva Capital’s Terms of Service, or as otherwise required by law.
  • We transfer Personal Information about you if Colva Capital is, or its assets are, acquired by or merged with another company.

We may share aggregated information with others without further notice. An example of this would be the number of people who used the Service in a given month or the total number of texts sent in a given week.

Security

Colva Capital takes precautions to ensure the security of your Personal Information, including ensuring that our third party service providers protect the security of your Personal Information. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information despite our efforts. You should note that in using the Service, your information will travel through third party infrastructures which are not under our control (such as a third party SMS delivery platform or your carrier network).

We cannot protect, nor does this Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users.

Opting in

A mobile user might opt-in by:

  • Entering a phone number online,
  • Sending an Mobile Originating (MO) message containing an advertising keyword,
  • Filling out a paper form that includes their phone number, or
  • Signing up at a point-of-sale location.

Opting out

Colva Capital’s third-party service provider gives you the ability to opt out of the Service for any reason. You can opt out by texting “STOP” or “QUIT” when asked to.

We reserve the right to send you certain communications relating to the Service, such as announcements and administrative messages, without offering you the opportunity to opt-out of receiving them.

Children

The Service is not intended for children under 13, and Colva Capital does not knowingly collect information from children under the age of 13.

Children aged 13 or older should not submit any Personal Information without the permission of their parents or guardians. By using the Service, you are representing that you are at least 18, or that you are at least 13 years old and have your parents’ permission to use the service.


Intended audience

Colva Capital requires that users of this service be limited to US residents only.

Questions or concerns?

If you have any additional questions regarding this Policy, please feel free to contact us any time by emailing [email protected]

SMS Terms of Service

Use of the Colva Capital text message-based services (the “Service”) is subject to the following Terms of Service. These terms constitute a legal agreement (the “Agreement”). Please read them carefully.

  1. Colva Capital will allow several different opportunities, such as a entering a phone number online, to opt-in to SMS services.
  2. You can cancel the Service at any time. Just text "STOP". After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time, and we will start sending SMS messages to you again.
  3. If at any time you forget what keywords are supported, just text "HELP". After you send the SMS message "HELP" to us, we will respond with instructions on how to use our Service as well as how to unsubscribe.
  4. We are able to deliver messages to the following mobile phone carriers. Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless). ***Carriers are not liable for delayed or undelivered messages***
  5. As always, message and data rates may apply for any messages sent to you from us and to us from you, and Colva Capital is not liable for the cost of any such messages. You will receive recurring messages. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. For all questions about the Service provided by this short code, you can send an email to [email protected]
  6. You understand that anyone with access to your mobile phone may be able to view the messages you receive when using the Service, and you agree that Colva Capital will not be liable to you if this occurs.
  7. You understand that you are not required to consent to the Service to receive any other services from Colva Capital.
  8. By agreeing to these Terms of Service and providing us with your mobile phone number when you opt in to the Service, you authorize Colva Capital to contact you by text message at your mobile phone number using an automatic telephone dialing system or device, or any other computer assisted technology as applicable.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected] or (858) 263-1703.