Privacy Policy

Effective January 20, 2022, SBA Edge, LLC, including any subsidiaries and affiliates (collectively, “SBA,” “we,” or “us“), is committed to protecting your privacy and developing technology that provides you with the most powerful and secure online experience. This Privacy Policy (the “Privacy Policy“) explains how SBA collects and uses information about you. It applies to data collection through the SBA Site and any other website that links to this Privacy Policy (the “Site” or “Website“), as well as offline data collection. Please note that if you are visually impaired, you can access this notice through your browser’s audio reader.

APPLICABILITY

This Privacy Policy is a statement of how information about you is collected, used, and potentially shared by SBA. Specifically, this Privacy Policy will tell you:

• what personal information we collect;

• what your choices are regarding your personal information;

• how we use your personal information and with whom we share it;

• your consent regarding the collection, use, and disclosure of personal information;

• how you can access your personal information for review and updating;

• how we retain and dispose of your personal information; and

• how we protect your personal information.

Personal information is any information that directly or indirectly identifies an individual user or that can be reasonably linked to a specific person, computer, or device (“Personal Information”). This information includes, but is not limited to: (i) your name; (ii) mailing address; (iii) phone number; (iv) financial account information; (v) CPF; (vi) email address; and (vii) other similar information.

1. ALTERATIONS

SBA reserves the right to change this Privacy Policy at any time, at its sole discretion. If we do, we will update the “effective date” at the top of this Privacy Policy and notify you of any material changes by displaying a prominent notice at the top of the SBA website or by sending an email directly to you. Changes, revisions, or deletions with respect to this Privacy Policy will become effective immediately upon their inclusion or deletion from this Privacy Policy and their posting in this Privacy Policy on the Site. You are encouraged to revisit this Privacy Policy from time to time to review any changes that have been made. Your continued access and use of the Site after the posting of such changes shall indicate your acceptance of the same.

2. PURPOSES AND USES OF YOUR PERSONAL INFORMATION

We generally use your personal information for the following purposes:

• as required by law;

• as necessary for the performance of a contract with you and our business partners to operate our website;

• to handle contact and user support requests submitted through forms on our website or email;

• to improve our services and the Site;

• to conduct marketing campaigns;

• to ensure the security of our website; and

• with your explicit and informed consent.

We will only use your personal information for the purposes for which it was originally collected. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. Please note that, where permitted by law, we may process your personal information without your knowledge or consent if we believe it is reasonably necessary to comply with applicable laws.

3. TYPES OF PERSONAL INFORMATION COLLECTED AND PURPOSES OF COLLECTION

We will only collect personal information about you that is adequate, relevant, and limited to what is necessary. SBA Account Setup. When you sign up for an account with us, we request and collect personal information such as your name, valid email address, physical address, phone number, and online identifiers. We also collect payment details to facilitate the customer billing process. In some cases, and in some jurisdictions, we may also collect your government identification number (e.g., social security number, driver’s license number, passport number, or similar government identifier), utility service provider details, and information about leases or other real estate-related agreements or property of which you may be a part. We use this information to provide you with account-related functionalities. Accounts can be used to manage your SBA services. Providing this information is necessary to create an account and use our services. We may not be able to create your account or provide our services if you do not provide this information. Website Forms. If you express interest in receiving information about our services using any of the forms on our website, we collect the information you enter into the forms. We collect this information to respond to and communicate with you about your requests. Providing this information is voluntary. Support Request Information. We maintain your personal information associated with customer support requests and inquiries to track who handled your issue and whether and how it was resolved. Automated Information. We automatically receive and record information from your browser about the devices you use to access our website. This includes things like IP addresses, the type of browser and device you use, your language settings, the web page you visited before accessing our websites, and identifiers associated with your devices. We use “cookies” and various other tracking technologies (e.g., cookies and beacons) to collect and store information about your use of our website, your interactions with the content on our website, and your interactions with our online advertising efforts. We use these tools to ensure you receive a personalized experience and to keep your account secure. Please refer to the Cookies and Other Tracking Technologies section of this Privacy Policy for more information. Employment Information. If you apply for a job posting or become an employee, we collect the information necessary to process your application or retain you as an employee. Depending on the jurisdiction you are in and/or the position you are applying for, this may include your contact information, nationality, government identification number (such as your social security number or equivalent government identifier), demographic information, information about your education, medical, financial, criminal history, employment history, training records, and other information that may be necessary to facilitate our evaluation of your employment application. Providing this information is generally necessary to process your application. We use information about applicants and current employees to perform our employment contract or the anticipation of an employment contract with you. In some contexts, we are also required by law to collect information about our employees. We also use your information for purposes of efficient personnel and workforce operations. Business Contact Information. If you or your employer correspond with us regarding a business opportunity or enter into a business relationship with us, we collect the information necessary to facilitate that correspondence and/or relationship, such as your name, contact information, and job title. We may also collect payment information, corporate credit card or credit card number, billing address, billing information, and other payment details. We use this information to negotiate or execute service agreements or other contracts. In addition to the information that we collect directly from you, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use common tracking technologies, such as email tracking, log files, web beacons, and cookies to automatically collect information about you, which may contain personal information. This information is used to analyze how our website is used, to ensure the security of our website, and to improve our services. Log Files. Directly or through our hosting service provider, we may automatically receive and record information from your internet browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your Web browser, referring addresses, where the computer is routing from, and other generally accepted log information. We may also record page views (hit counts) and other general statistical and tracking information that will be aggregated with information about other users to understand how our website is being used and for security and monitoring purposes. Email Tracking. We may send emails that use a “click-through URL” linked to content on our website. When you click on one of these URLs, you pass through our web server before arriving at the landing page. We track this click-through information to help determine interest in specific topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click on text or graphic links in the email or notify us as set forth below (Changing or Removing Information; Opt-Out). Web Beacons. We may track your navigation on our websites via beacons as a means of tracking your web traffic patterns. We may also track such activity in connection with traffic monitoring and third-party services, which also may be used in connection with cookies to understand web activity and behaviors. Cookies. As mentioned above, SBA utilizes “cookies” to track and store information about Website Users. “Cookies” are alphanumeric identifiers in the form of text files that are placed and stored on your hard drive. Cookies track your personal preferences and activities. If you do not wish cookies to be placed on your hard drive, you can disable your hard drive’s ability to accept and receive cookies through your web browser. However, please be aware that if you disable your hard drive’s ability to accept and receive cookies, you may not be able to fully utilize all the conveniences and additional features of the Website. SBA uses cookies on its website for the following purposes: to better serve you by remembering your user preferences; to improve our website; to make our website work correctly; and to provide a secure Browse experience while using our website. We use the following types of cookies on our website:

• Strictly Necessary Cookies. These cookies are essential because they allow you to navigate our website and access its secure areas. Without these cookies, some website functionality will not work properly. These cookies do not collect information about you for marketing purposes. This category of cookies is essential for our website to function and cannot be disabled.

• Functional Cookies. We use functional cookies to remember your choices, so we can tailor our website to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our website. We do not use functional cookies to target you with online marketing. While these cookies may be disabled, this may result in less functionality when using our website.

• Performance or Analytical Cookies. These cookies collect anonymous passive information about how you use our website, including web pages you visit and links you click on. We use the information collected by these cookies to improve and optimize our website. We do not use these cookies to target you with online marketing. You can disable these cookies.

• Third-Party Cookies. We participate in behavior-based advertising, meaning that a third party uses cookies to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website or on other websites. Your Choices Your browser may provide the option to refuse some or all browser cookies. You may also remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by following the steps outlined below. First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies, other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org. Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies, go to http://www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, see http://www.aboutads.info/consumers. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to opt-out of their collection or use of your information in this manner. In addition, most web browsers provide help pages relating to setting cookie preferences. More information can be found for the following browsers here:

   
   

• Google Chrome

• Internet Explorer

• Mozilla Firefox

• Safari (desktop)

• Safari (Mobile)

• Android browser

• Opera

• Opera Mobile Do Not Track. Some Internet browsers, such as Chrome, Internet Explorer, Firefox and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

5. SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES

If we have collected your personal information, we will not disclose it to third parties without your consent, except in the following circumstances: Business Partners. We employ other companies to perform functions on our behalf, such as website maintenance, information collection, sending and responding to electronic mail, and other functions necessary to support SBA, the website, and the products and services that we offer. We will provide our business partners only the Personal Information necessary to perform their functions and will instruct them not to use your information for any purpose inconsistent with this Privacy Policy. We require that the companies with which we work contractually agree to comply with privacy laws and maintain safeguards for personal information consistent with this Privacy Policy. Harm Matters. We may disclose your Personal Information on a case-by-case basis to attorneys, private investigative organizations, or law enforcement agencies if we believe you are: (i) at risk of harm from a third party; (ii) harming or interfering (or intending to harm or interfere) with others; or (iii) violating (intentionally or unintentionally) our Terms of Use or other legal obligations. Within Our Corporate Organization. We may share your personal information with our subsidiaries and affiliates to provide you with the Site or services and take action based on your request, as well as for management and analysis purposes. For example, we may share your information with our subsidiaries and affiliated companies to administer our loyalty programs, process orders and requests, and expand and promote our Site and services. Legal. We will reveal Personal Information about you to the extent we reasonably believe we are required to do so by law. If we receive a legal process requesting the disclosure of your personal information, we may attempt to notify you through the contact information you provided (if any) within a reasonable time before we respond to the request, unless such notification is not permitted. Additionally, we may share your personal information with third parties as permitted by law to, for example, protect against fraud, the confidentiality or security of our business records, or to comply with applicable legal requirements. Transfer of Ownership. We will have the right to transfer Personal Information to a third party in connection with a sale or merger of a Site or business unit. If we transfer your Personal Information, we will do so in accordance with this Privacy Policy, provided that the acquiring third party has agreed to protect your Personal Information with safeguards that are, in all material respects, equal to or more protective than those set forth in this Privacy Policy. Consent. We may disclose your personal information for any purpose with your consent.

6. YOUR CHOICES AND RIGHTS REGARDING PERSONAL INFORMATION

We give our users appropriate control over their personal information. You may contact us to change or update discretionary information you have previously submitted. Please refer to the Contact Us section below for our contact information. If we send you newsletters, updates, surveys, or other communications related to marketing materials, we will provide you with the ability to decline – or “opt-out” of – receiving such communications. Instructions for opting out will be provided if and when we elect to send you such communication. Please understand that you will not be permitted to “opt-out” of formal notices regarding the operation of this website and legal and other notices related to your relationship with the website. Additional Rights for Individuals Located in Certain Jurisdictions In some circumstances and jurisdictions, we may be subject to data protection laws that grant you additional data protection rights, depending on where you are located. To the extent required by these applicable laws, we will grant you the rights listed below, provided we can adequately verify your identity:

• Access to Your Personal Information. You may request confirmation and access to the personal information we hold. If permitted and required by law, we will confirm whether we hold or process your personal information and grant you reasonable access to the data we hold about you.

• Retention and Deletion of Your Personal Information. We typically retain your personal information for the period necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of data or request that we delete your personal information by contacting us at the address described below. If we are permitted to do so and to the extent required by law, we will grant a request to delete personal information, but you should note that in many situations, we must retain your personal information to comply with our legal obligations, in pursuit of a legal action, to detect or monitor fraud, resolve disputes, or enforce our agreements with you. Additionally, please understand that if you request the deletion of your information, you will not be able to utilize the associated features of the website and any associated services. You cannot remove unidentified, anonymous, or aggregated data from our databases.

• Objection to Certain Processing. You may have the right to object to the use of your personal information. You may have the right to object to direct marketing and, in some circumstances, the right to object to certain automated processing operations.

• Right to Restrict Processing. You may have the right to object to the processing of your information in certain circumstances, for example, when: (i) you dispute the accuracy of your information; (ii) your personal information is being or has been processed unlawfully; (iii) we no longer need to process your information, but you need your information in connection with a legal claim, or (iv) you object to processing pending verification of whether there is a legitimate reason for such processing.

• Right to Rectification. You may have the right to request the rectification or correction of inaccurate or incomplete personal data concerning you.

• Right to Data Portability. You may have the right to request to receive your information in a structured, commonly used, and machine-readable format in certain circumstances.

• Withdrawal of Consent. You may withdraw any prior consent to the processing of your personal information if we process your data based on consent. If you withdraw your consent, we may no longer be able to process your personal information or provide the portion of the service that relies on such consent. In some cases, we may limit or deny your request to withdraw consent if the law permits or requires us to do so.

For more information about your privacy rights, please see Information for Specific Jurisdictions below. To exercise any of the above rights that may apply to you, please submit your request to us using the information in the Contact Us section below. If you are not satisfied with our response, you may have the right to file a complaint with your local supervisory authority or government privacy regulator.

7. INTERNATIONAL TRANSFERS

Your personal information may be stored and processed in any country where we have offices or servers or in which we engage service providers. Your personal information may be transferred to countries outside of your country of residence, including the United States, which may have data protection and processing laws that are different from those of your country. Any such transfer shall only occur in accordance with and as permitted by the law of your jurisdiction, but be aware that laws and practices regarding the protection of personal information are likely to be different and, in some cases, may be weaker than those within your home jurisdiction. Regardless, in all cases, we will apply the provisions of this Privacy Policy to your Personal Information wherever it is located. If you have questions about international transfers, please contact us using the information in the Contact Us section below.

8. SECURITY OF YOUR PERSONAL INFORMATION

SBA utilizes commercially reasonable physical, administrative, and technical safeguards to protect the security of any Personal Information submitted by you through our Site. One such safeguard is the HTTPS protocol we use to ensure your personal information is kept confidential. Our security systems are structured to prevent unauthorized access to the personal information that you provide us. Please understand, however, that information processing activities can never be 100% secure. Due to the nature of communications over the Internet and evolving technologies, we cannot and do not provide and disclaim assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

9. RETENTION

We will process and retain your personal information as long as your account is active or as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Once retention periods expire, we delete your personal information or prevent any future use of it.

10. LINKS TO THIRD-PARTY WEBSITES

The SBA website may contain links to other websites. This Privacy Policy applies exclusively to our Site, and SBA makes no representations or warranties about, nor is it responsible for the privacy practices of other websites. When you enter a linked website, SBA encourages you to read that linked website’s privacy policy as its privacy policy may differ substantially from that of the website.

11. CHILDREN’S PERSONAL INFORMATION

We do not knowingly or intentionally collect personal information from minors. If you are under 18, you may use our website only with the consent of your parent or guardian. Please contact us if you believe we have collected personal information about a child without consent, so we can take appropriate action and delete it.

12. CONTACT US

We encourage you to provide us with feedback regarding this Privacy Policy. If you have questions, comments, or concerns about this Privacy Policy, please email us at dpo@sbaedge.com. If you are located in any of the jurisdictions listed in the section below, you may also contact us using the contact information found on the specific jurisdiction’s page.

13. INFORMATION FOR SPECIFIC JURISDICTIONS

If you are located in any of the countries or jurisdictions listed below, please click on the links for more information about your privacy rights and how to contact us: