Privacy Policy

Effective Date: July 26, 2018

We respect your right to privacy and will only process your personal information in accordance with applicable data protection and privacy laws. In this Privacy Policy, "we," "us," "its" and "our" refer to Progressive Labs, Inc. ("Progressive Labs"), organized under the laws of Delaware, USA. Please read carefully this Privacy Policy ("Policy") relating to your use of Progressive Labs’ applications, services and websites.

A. Introduction

This Policy explains how Progressive Labs collects, stores, uses and discloses information from you when you use Progressive Labs products, services, mobile applications and websites (collectively, the “Services”). This Policy applies to users of the Services, defined as the services, APIs, and functionality we make available either through www.investleft.com, any other domains owned and operated by Progressive Labs, and related site pages (the "Website"), via separate sites, repositories or servers under our control, or through third party sites that utilize our services and functionality, as well as through our application software ("Software"). This includes entities using the Service to receive donations. This Policy does not apply to websites, applications, or services that do not display or link to this Policy or that display or link to different privacy statements; nor does this Policy apply to practices of companies that we do not control or to people we do not employ or manage.

By accepting the Policy during account registration, you expressly consent to our collection, storage, use and disclosure of your personal information and non-personal information as described in this Policy and to all other terms herein.

It may be possible for you to browse certain parts of the Website without telling us who you are or revealing any information that enables us to directly identify you as an individual. However, you may lose anonymity once you give us personal information about you, and by doing so, you agree to the collection, transfer and storage of that information to our servers and to the terms of this Privacy Policy.

B. Information Collected

We collect information about you in various ways when you use our Service and as set forth in the Terms of Use. Some of this information may be Personal Data about you. As used in this Policy, "Personal Data" means any information (either alone or in combination with other information we hold) that specifically identifies you as an individual, such as your name, address and physical location, account numbers, email addresses, or telephone numbers.

As well as Personal Data, we also collect some information that is not personally identifying, including aggregate information, which is data we collect about use of the Service or about a group or category of users from which it is not possible to identify you (“Nonpersonal Data”; together with Personal Data, collectively "Information").

Personal Data

When you register for an account, and in the course of your use of the Service, we collect the following Personal Data: your log-in information (username and password), email address, mobile phone number, any profile or biographical information you elect to provide, company details, any personally identifying information to the extent revealed in your Content (as that term is defined in the Terms of Use and, if applicable, financial information, including credit card and/or bank account numbers, that you provide to us in exchange for your commercial use of the Service as agreed in writing separately between us.

Cookie Policy

We may automatically collect Information using "cookies," which are small files placed on your hard drive or device storage that may uniquely identify your browser and collect certain Information about you. Among other things, cookies help us analyze our web page flow, customize our Service, measure promotional effectiveness, and promote trust and safety. Certain features are only available through the use of cookies, and generally we need to use cookies to help identify you and maintain your signed-in status. You are always free to decline Website cookies via your browser settings, although doing so may interfere with your use of the Website. You may encounter cookies from third parties that we do not control on certain pages of the Website.

We may additionally collect Information using pixel tags, web beacons or other web site usage tracking technologies. Web beacons (also known as "tracking pixels") are electronic images that may be used in the Service or in emails that we send to you. Amongst other things, we use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon. Such devices are used to collect Nonpersonal Data, such as the identity of the applicable internet service provider, the IP address of the user’s personal computer, the type of browser software and operating system in use, the date and time of site access, the website address, if any, from which the user linked to the Website and other similar traffic-related information. We also may aggregate such information with similar data collected from other users.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this could affect certain features of our Service. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.

Do Not Track Disclosure

We do not knowingly engage in the collection of Personal Data from users across third party sites or applications. We may use third party applications (such as Google Analytics) that collect your Personal Data about your online activities over time and across different Web sites or services when you use the Service.

Services Via Third Party Applications

We may provide Services functionality via or to third party applications. In such context, we collect only Nonpersonal Data as described in this Policy (such as device IP address, device model, brand, operating system, version, language/country and timezone, network and connection information). Any Personal Data that may be collected by such third parties is subject to such third parties' policies and practices, over which we exercise no control. We will not be liable for the acts and omissions of such third parties or for any loss of privacy, use or control of data caused by such third parties. You must contact such third parties for any requests, questions or concerns you may have regarding your Personal Data and data collected via such third party applications.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

C. Our Use of Information

We may use and provide data and information to our partners and customers for commercial purposes. When possible, we will remove your name and any other personally identifying information from it, or combine it with other people's data in a way that it is no longer associated with you. We use Information collected through our Service for the purposes and as described in this Policy, as disclosed to you on our Software, as needed to carry out the Service, and as set forth in the Terms of Use. We may also use your Information to:

(i) operate, maintain, customize, measure and improve our Service, and to fulfill the purposes disclosed when you provided your information to us;

(ii) respond to your comments and questions and provide the Service and customer support you request;

(iii) resolve disputes, collect fees, enforce our terms and policies, and troubleshoot problems;

(iv) understand you and your preferences to enhance your experience and enjoyment using our Service;

(v) communicate with you about new events, offers and other news about our products and services offered by us and our selected partners;

(vi) send you Services-related information, including confirmations, invoices, reminders, technical notices, updates, security alerts and support and administrative messages;

(vii) ensure contributions, payments, or activity of any kind is reported, processed, or handled in accordance with local, state, federal, international, or subjective laws that govern our operation, or that we choose to acknowledge; and

(viii) to prevent fraud, abuse or potential illegal activity or to otherwise ensure compliance with applicable law, rule and regulations.

We also may combine your Information with information we collect from other sources to improve our products and services. Further, we may use Personal Data to respond to legal requirements, in connection with a merger, sale of assets, or other similar corporate transactions, to respond to claims that content violates the rights of others, or to protect the rights, property, or safety or any person.

D. Sharing Information

We do not disclose, sell or rent your Personal Data to third parties for their marketing purposes without your prior consent. If you do consent but later change your mind, you may contact us and we will cease any such activity. We only share your Personal Data as follows:

(i) at your direction and control via your normal and intended operation of the Service, or with your consent, for example, when you agree to our sharing your Personal Data with other selected third parties for their own marketing purposes subject to their separate privacy policies;

(ii) with service providers, consultants or similar contractors, or third parties who provide services or content in connection with our Service in order to support or enhance our products and services or our business operations, or to make available and consummate initiated transactions;

(iii) to comply with laws or respond to lawful requests and legal process or to enforce or apply our terms of use/service, license terms, or other agreements between us, and to protect the rights, safety and property of Progressive Labs, our agents, employees, customers, members, and others; and

(iv) under written obligations of confidentiality, in connection with or during negotiation of any a merger, financing, acquisition, or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.

We may also share and disclose Nonpersonal Data, e.g., by publishing a report on trends in the usage of its Service.

E. No Guarantee of Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.  We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy.

However, no one can create a completely secure website, app or service and third parties may unlawfully intercept, steal or access transmissions or private communications. No method of transmission over the internet, or method of electronic storage is 100% secure or error free.  Therefore, we cannot guarantee that your Information or private communications that you transfer over the internet to us will always be secure or remain confidential. This includes financial transactions (i.e. donations) processed through our software. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

F. Password

Your password deserves careful thought and protection. Use unique numbers, letters, and special characters and do not disclose your password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. If your password has been compromised for any reason, you should immediately access your profile to change your password and notify us immediately at support@investleft.com. Certain Progressive Labs applications, products, services, or offerings may use password services like Auth0. Progressive Labs makes no guarantee of the quality of these services.

G. International Transfers

We may process Information on servers located in a number of countries. Accordingly, we may share Information with our affiliated companies for such companies to carry out any of the activities specified in this Policy. We may also subcontract processing to or share Information with third parties located in countries other than your home country. Information collected within the European Economic Area and Switzerland may, for example, be transferred to, and processed by our affiliates or other third parties identified above that are located in a country outside of the EEA and Switzerland, where you may have fewer legal rights in relation to your information. However, we will only process your information as described in this Policy in every country.

H. Children

The Services are not directed at or intended for children under thirteen (13) years of age, and we do not knowingly collect Personal Data from such children. If you believe that we might have any Personal Data from a child under 13 years of age, please contact us at support@investleft.com.

I. Policy Changes

We may amend this Policy from time to time. If we make any changes to this Policy, we will post the amended terms, change the "Last Updated" date above, and where appropriate, notify you by email. By continuing to use the Services, you acknowledge you have read the current Policy and agree to it. If you do not and wish to terminate your account, please contact us at support@investleft.com and cease usage of your account immediately.

J. Your Information and Choices

You have the right to ask us not to process your Personal Data for marketing or promotional purposes via email sent to support@investleft.com. You may also opt out of receiving promotional emails from us by following the instructions in the emails themselves or via email sent to support@investleft.com. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

You can see, review and change your Personal Data by logging into the Service or by contacting us at support@investleft.com. You should promptly update your Personal Data if it changes or is inaccurate. You also may send requests about your contact preferences, to request a review of the Personal Data we have about you, and to request that we update or correct any out-of-date or incorrect Personal Data we have about you (to the extent of Personal Data we have not already made available to you for your own review, modification, or deletion). Upon receipt and process of a reasonable opt-out request, we will, within a commercially reasonable period of time, comply with such request to the extent reasonable. Note that requests to terminate disclosure to third parties may frustrate or render impossible our ability to provide the Service or conduct transactions initiated by you.

We may retain your Personal Data as part of providing ongoing services for our clients and maintaining updated records as part of our Services. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

We retain Personal Data from closed accounts, if and to the fullest extent permitted by applicable law, including in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements and policies, and take other actions otherwise permitted by law or as specified elsewhere in this Policy.

K. Questions

If you have any questions about this Policy, please contact us at support@investleft.com.