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PRIVACY POLICY

It is important that you understand our privacy practices at Moneties Trading Partners, LLC (“Moneties”) – d.b.a midcurrent.fliesforsale.com.  We have updated our Privacy Policy to clarify the information we collect, how we use and protect it, and the choices you have across various applications. 

If you have any questions or concerns, you can contact us at privacy@midcurrent.fliesforsale.com.

European Data Protection Law: We have added information about the rights of users in the European Economic Area under the GDPR and our legal bases for processing data from those users.

  1. Introduction
    2. About Moneties
    3.         Information We Collect
    4.         How We Use Information
    5.         Use of Cookies and Other Tracking Technologies
    6.         How We Share Information
    7.         Your Choices
    8.         Access
    9.         Children’s Privacy
    10.       Retention
    11.       Security Safeguards
    12.       Changes to This Policy
    13.       Third Party Services, Applications, and Websites
    14.       Cross-Border Transfers
    15.       Applicability of Law; Partner Agreements
    16.       Data Controller
    17.       Your Rights
    18.       Contact Us

  2. INTRODUCTION

At Moneties Trading Partners, LLC (“Moneties”), we respect the privacy expectations of our users and commit to complying with all applicable data protection and privacy laws. This Privacy Policy (“Policy”) describes who is responsible for the information we collect, the types of information we collect, how we use, share, retain, and protect this information, and the choices you, as one of our users (“Users”), have with respect to its access and use.

This Policy applies to Moneties mobile applications and Moneties websites (collectively “Services”), unless specified otherwise. In this Policy where we use the words “personal information” we use these words to describe information that is about you and which identifies you.  We encourage you to read this Policy in full to understand our privacy practices before using our Services.

  1. ABOUT MONETIES

For the purposes of our business, we are the data controller. In respect to processing that we undertake on behalf of our Trading Partners (“Partners”), we are the data processor and our Partners are the data controllers who determine the purpose and means of the processing of personal data which they provide us with. There may be instances where we are a joint data controller with our client.

Moneties provides a software platform that, where available, enables you to purchase fishing related products, both physical and/or digital through our applications or websites and applications or websites of affiliates or partners with whom we integrate.

We partner with businesses, non-profit organizations, and other public and private operators (our “Partners”), in order to streamline and improve their operations, and to better service the needs of their contacts and/or contacts. Our collection and use of your information is designed with these purposes in mind.

We offer our Partners a back-office system to manage and analyze their operations with respect to our Services.

  1. INFORMATION WE COLLECT

We collect your information in the following ways:

    1. from you through your use of our Services (such as in the course of your interactions with the Services);
    2. from our Partners, when you have subscribed to receive their communications

The types of information that we collect are:

      • Information about you and your account – Any information that you voluntarily provide such as name, email address, phone number, password, PIN, marketing preferences.
      • Device information – Operating system, browser type, IP address, device type, and device version. We collect this information automatically when you use our Services.
      • Geolocation information – If you have enabled location services on your device we may use such services to collect the geographic location of your device when you use the Services. Some services may not function as designed if location services are disabled.
      • Financial information – Credit card number, expiration date, billing zip code, name on credit card, and/or similar account information for alternative funding sources that you may associate with your account.
      • Marketing information – Marketing preferences (for example if you sign up to receive certain marketing communications), information about your interaction with, and responses to, our marketing communications, entries to contests, discounts, or rewards.

To learn about your information collection choices and to opt-out of data collection, see the “Your Choices” section below, and, for individuals located in the European Union/European Economic Area (“EU/EEA”), see also the “Your Rights” section below.

  1. How We Use Information

We use your personal information in connection with the provision of the Services to you.  In particular, your personal information may be used by us, our employees and our service providers for the purposes described below.  For Users in the EU/EEA, for each of these purposes, we have also set out the legal basis on which we use your personal information.

If you are located outside the EU/EEA, by providing Moneties and/or our Partners with your personal information, you consent to the collection, and use of that information by Moneties and/or the Partners in accordance with this Privacy Policy and as otherwise permitted by applicable law. If you do not agree with these terms, please do not provide any Personal Information to us.  You have the right to withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Moneties, but then you might not be able to receive the full benefit of Moneties’s services.

We use collected information to:

    • Communicate with you about your account and use of the Services. These communications are for our legitimate interests (i.e., the provision of the Services), and depending on the circumstances, to perform a contract between you and us.

      This communication includes:
      • Providing information to help you use and navigate the Services.
      • Supporting and responding to your inquiries when using the Services.
      • Sending updates and notifications about the Services.
      • Providing you with your transaction history.
    • Communicate with others about your account use of the Services. These communications are for our legitimate interests (i.e., the provision of the Services).

      This communication includes:
      • Developing reports and providing information as required by our Partners and other service providers, such as payment processing entities.
      • At your request and on your behalf
      • Responding to all lawful access requests from law enforcement or other government authorities.

    • Provide our Services. This activity is for our legitimate interests (i.e., the provision of the Services), and depending on the circumstances, to perform a contract between you and us.

      This activity includes:
      • Operating the Services.
      • Managing your account on your behalf, including correcting any errors, updating or terminating your account, and ensuring that your data is retained as required for audit and compliance purposes or as required by law.

    • To audit and monitor the use of the Services. This activity is for our legitimate interests (i.e., the provision of the Services, as well as to monitor, maintain and improve the security of the Services).  We may request your consent in circumstances (e.g., in relation to our use of certain cookies). 

      This activity includes:
      • Analyzing and monitoring usage.
      • Maintaining security, preventing fraud, and enforcing our policies.
      • Complying with applicable laws.
      • Examining and remediating any Services outages or malfunctions.

    • To notify you about changes to the Services. This activity is for our legitimate interests (i.e., the provision of the Services).

    • To improve our Services. This activity is for our legitimate interests (i.e., the provision and improvement of the Services).

      This activity includes:
      • Improving and personalizing the User experience.
      • Creating aggregated and anonymized data to identify trends, errors, and opportunities for enhancements.
      • Conducting and using data analyses to improve the Services or to develop new features or products

    • Process your transactions, to help you manage your transactions and process payments on your behalf. This activity is for our legitimate interests (i.e., the provision of the Services), and depending on the circumstances, to perform a contract between you and us. This includes, in some cases, serving as the merchant of record or payment gateway provider.

    • Market and advertise to you, in accordance with your marketing preferences and, where relied upon, your consent. This activity is for our legitimate interests (i.e., the provision and promotion of the Services).  We may request consent in circumstances where a legal justification over and above legitimate interest is required by applicable law. 

      This activity includes:
      • Contacting you about services we offer, including details of any services which we believe may be of interest to you.
      • From time to time, using your contact information to administer and conduct surveys or notify you about promotional activities such as contests, discounts, or rewards for ourselves or third parties. You may opt out from receiving these kinds of communications.

    • To enforce any of our rights and to enforce or apply the agreements concerning you, such as in connection with a dispute or an attempt to collect unpaid amounts, for all other legal purposes, including to comply with any legal or regulatory obligations. This activity is for our legitimate interests and for compliance with legal obligations to which we are subject.

Where we rely on our legitimate business interests or those legitimate interests of a third party to justify the purposes for using your personal information, this will include:

  • pursuit of our commercial activities and objectives, or those of a third party;
  • compliance with applicable legal and regulatory obligations and any codes of conduct;
  • improvement and development of our business operations and service offering, or those of a third party; or
  • protection of our business, shareholders, employees and customers, or those of a third party.
  1. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We use common information-gathering tools to collect data when you are using our Services, such as cookies and other tracking technologies, to remember settings, track activities within the Services, and analyze trends. We may obtain reports based on the use of these technologies on an individual and aggregated basis.

  • Cookies –We use session-based and persistent cookies. Session cookies exist only during one session whereas persistent cookies remain on your device after you close your browser or turn off your device. You can control the use of cookies at the browser level. If you reject or delete cookies, some Services may no longer function as designed. Each browser provides different mechanisms for managing cookies; your browser’s help menu can assist you in determining the best way to modify your browser’s cookie storage. For more information about how to control or delete cookies, visit www.aboutcookies.org.
  • Analytics –We use Google Analytics and Google Analytics for Firebase to measure how you interact with our websites and Apps to improve your experience. To learn more about Google Analytics’ privacy practices and opt-out mechanisms, click here (support.google.com/analytics/answer/6004245?hl=en), and click here (firebase.google.com/policies/analytics) to learn more about Firebase Analytics’ privacy practices and opt-out mechanisms.

We also use analytics to measure how you interact with our website to improve your experience. Finally, we may store certain information in server logs, including IP address and device information, and collect and store information on your device using local storage objects; other tracking technologies we use include scripts, tags, MAC address, IMEI device number and pixels.

  • “Do-Not-Track” Technologies –We do not respond to web browser “Do-Not-Track” signals.
  • Third Party Tracking – Third parties, other than our service providers (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting the Services. That said, we cannot control third party tracking and there may be some third party tracking that occurs without our knowledge or consent.

  1. HOW WE SHARE INFORMATION

We share information about you with third parties in the following manner:

      • With external companies with whom we utilize to provide our Services, who provide payment processing, website hosting, data analytics, information technology, marketing, customer service, email delivery, audit, debt collection and similar services.
      • If you participate in promotional activities such as surveys and promotions, we may share your information with our service providers and other third parties relating to such activities.
      • We share certain information with our Partners in accordance with this Policy and any applicable provisions of our Partner agreements, so that they may appropriately provide services and support to you, or so that they may market and advertise to you as required by our agreements.
      • As part of merger, acquisition, or sale of substantially all of our assets.
      • With our professional advisers, such as accountants and lawyers that assist us in carrying out our business activities.
      • With government authorities and third parties involved in court action, including external agencies and organizations (including the police and the relevant local authority) for the purpose of complying with applicable legal and regulatory obligations.
      • When we believe that disclosure is (1) reasonably necessary to comply with any applicable law, regulation, subpoena, legal process or enforceable governmental request; (2) necessary to enforce the provisions of the Policy; (3) required to enforce our terms, including investigation of potential violations; or (4) necessary to investigate or protect against actual or threatened harm to the rights, property, or safety of Moneties, our Users, or the public as required or permitted by law.

You acknowledge and agree that we cannot be held liable for actions or omissions of any party with whom we share your information, and such information will be governed by such parties’ policies, procedures, and practices.

  1. YOUR CHOICES

You can change your preferences by contacting us directly or by changing your settings in our Apps directly where available. For ancillary services provided by Moneties that are not necessary for the proper operation of our Apps, you may also limit the use and disclosure of your data or revoke your consent, where relied upon, by contacting us directly or changing your settings in our Apps directly where available.  For ancillary services provided by third parties or Partners, such as marketing emails, you may limit the use and disclosure of your data or revoke your consent by contacting such Partners directly.

  • Marketing emails –You can choose to stop receiving marketing emails from Moneties by following the unsubscribe instructions included in these emails. Moneties is not responsible for marketing emails sent by our Partners.
  • Third-party communications –You may opt in to receive emails or other communications from our Partners, vendors, or affiliates. If you opt in, you may be subject to such parties’ separate privacy policies.
  • Account –You can stop Moneties from collecting information through your Moneties account by ceasing to use our Services. You can also contact us to delete or modify certain account information at the email address listed in the Contact Us section below.
  1. ACCESS AND CORRECTION

It is important that the information about you contained in our records is accurate and complete.  If your personal information happens to change during the course of our relationship, please keep us informed of such changes.  You can access, review, update, and object to the processing of your information, as well as cancel your user account, by contacting our customer support team at the email address listed in the Contact Us section below. We will respond to your request at our earliest opportunity and within any response periods required under applicable law.

  1. CHILDREN’S PRIVACY

Our Services are not directed to children under the age of 13, or under the applicable legal age in jurisdictions outside of the United States, and we do not knowingly collect information from them.

  1. RETENTION

We retain your information for as long as necessary to comply with our legal obligations, resolve disputes, enforce our rights, or as reasonably necessary for business purposes. Where appropriate or legally required, we retain your information on our servers even after deletion or termination of your user account to comply with our legal obligations, resolve disputes, or enforce our rights.

  1. SECURITY SAFEGUARDS

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our Services, please contact us using the email address listed in Contact Us section below.

  1. CHANGES TO THIS POLICY

We periodically update this Policy to account for changed legal and operational circumstances and to describe new features, products, or services, and how those changes affect our use of your information. Any changes we make to this Policy in the future will be posted on this page, and, if we make material changes to this Policy, we may provide notification through our Services or directly to you; in any case, you may choose to discontinue using our Services if you do not wish to accept the changes. The updated Policy will take effect as soon as it has been updated or otherwise communicated to you.  We encourage you to review this Policy for updates each time you use our Services.

  1. THIRD PARTY SERVICES, APPLICATIONS, AND WEBSITES

Certain third-party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our Partners or service providers. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.

  1. CROSS-BORDER TRANSFERS

Our Services are global and data (including personal information of Users) may be transferred, stored and processed in any country where we have operations or where we engage service providers. We may transfer data to countries outside of your country of residence, which may have data protection rules that are different from those of your country, subject to any applicable laws. Data hosted within and outside of your country of residence may be accessed by Moneties personnel located in the U.S. We take appropriate measures to ensure that any such transfers comply with applicable data protection laws and that your data remains protected to the standards described in this Policy.

For Users located in the EU/EEA, if we transfer your personal information outside of the EU/EEA, we will establish the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of standard clauses issued by the European Commission).  For Users located in the EU and in Switzerland, with respect to the transfer of personal information to the United States.  Moneties complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce, and Users can learn more about our Privacy Shield certification in our Notice.

  1. APPLICABILITY OF LAW; PARTNER AGREEMENTS

As discussed earlier, Moneties may have an agreement with a Partner when operating the Services.  Our Partners and our Users are located in different jurisdictions in which we operate, and therefore we may have varying privacy obligations depending on the applicable jurisdiction and on our privacy obligations under the applicable Partner agreement.   It is our policy to comply with the applicable privacy law and with the applicable Partner agreement.

If any of the foregoing provisions of this Policy conflict with how Moneties may collect, use, share, retain, or transfer your information under any applicable international, state, federal, provincial, or other territorial laws, Moneties will comply with such law or laws accordingly.

  1. DATA CONTROLLER

We, Moneties Trading Partners, LLC, are the data controller for the purpose of data protection law, in respect of your personal information collected and used through your use of the Services.  This is because we dictate the purposes for which your personal information is used and how we use your personal information.

Our Partners may act as data controllers for the purpose of data protection law when they offer you the services, or any part thereof.  Please refer to the privacy policies of our Partners for more information.

  1. YOUR RIGHTS

If you are a User located in the EU/EEA, then you have certain additional rights with respect to your personal information under the General Data Protection Regulation.  The rights may only apply in certain circumstances and are subject to certain exemptions.  Please see the table below for a summary of your rights.  You can exercise these rights using the contact details under the “Contact Us” section at the very end of this Policy.

Summary of your rights:

  • Right of access to your personal information
    1. You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.
  • Right to rectify your personal information
    1. You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
  • Right to erasure of your personal information
    1. You have the right to ask that your personal information be deleted in certain circumstances.  For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.
  • Right to restrict the use of your personal information
    1. You have the right to suspend our use of your personal information in certain circumstances.  For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
  • Right to data portability
    1. You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organization, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.
  • Right to object to the use of your personal information
    1. You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.
  • Right to withdraw consent
    1. You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
  • Right to complain to the relevant data protection authority
    1. You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law.
    2. CONTACT US

If you have questions about this Policy or our information handling practices, please contact us at privacy@midcurrent.fliesforsale.com or write to us at:

Moneties Trading Partners, LLC
Attention: Privacy Officer
12 Netherwood Rd
Windham, NH 03087