Mighty

Privacy Policy

Last Updated: December 27, 2020

Please contact Mighty Invest LLC’s compliance department for information regarding our privacy policy.

Michael Fruzzetti
Chief Compliance Officer
(720) 295-3760
1436 W 33rd Ave
Denver, CO 80211

Privacy Policy Notification
Mighty Invest, LLC (“Mighty”) believes that clients deserve outstanding service – including feeling confident about our protecting the personal nonpublic information they share with us. We respect the right to privacy and understand the importance you place on the privacy and security of information that personally identifies you or your account information.

The Securities and Exchange Commission has implemented Regulation S-P, which relates to the privacy of consumer financial information, and has established rules in response to Section 504 of the Gramm- Leach-Bliley Act. Regulation S-P and the Gramm-Leach-Bliley Act limit investment companies, broker- dealers, and registered investment advisers in their disclosure of consumers’ and customers’ nonpublic personal information. Regulation S-P also requires that financial institutions provide privacy notices in various instances and to adopt policies and procedures to protect the personal information of its customers. This statement describes our firm’s privacy policy and how we handle your personal information. This policy applies to former, current, and prospective customers.

This notice is intended to tell you where we obtain information about you, how we use that information and who has access to the information.

Why and How We Collect Personal Information
We are required by the regulations of our industry to obtain personal information about you while providing investment solutions to you. We use this information to manage your account, direct transactions, and provide you with information. We may collect this information from you through online forms, online questionnaires, or other online transmissions. The information includes your name, address, telephone number, social security number, transactional and financial information, as well as other personal nonpublic information we may need to service your account. In addition, we may access or generate information to service your account, such as account statements and portfolio holdings.

Finally, we may receive information from third parties with respect to your account, such as accounts you may have with other financial institutions.

How We Protect the Confidentiality of Your Personal Information
Mighty does not provide, for sale or otherwise, personal information about you to outside firms, organizations, or individuals except as required by law or as requested by you. In the course of regular business, Mighty may share relevant information with regulators, financial institutions and other service providers that support our service of your account. These companies may use this information only for the services for which we hire them and are not permitted to use or share this information for any other purpose. There are times when we may distribute information about your account to regulators, financial institutions, and service providers electronically which may include transmitting information via email or by other means over unsecure networks.

We use your personal information in ways that are compatible with the purposes for which we originally requested it. For example, we will use the information you give us to process your requests for transactions, to meet regulatory requirements, to provide you with additional information about products and services, or to share information with you about your account. We may also be required to share information by law due to a subpoena, court order, or regulatory requirements. At all times, we will limit the collection and use of personal information to that which is necessary to administer our business and to deliver the best possible service to you.

Mighty restricts access to nonpublic personal information about our customers to employees who need to know such information to provide products or services to you. We maintain strict safeguards – physical, electronic, and procedural – designed to protect your personal information and comply with federal standards. If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices as described in this notice.

We are Committed to Protecting Your Privacy
We value the confidence and trust you have placed in us and strive to protect that trust. If you have questions regarding our customer privacy policy, please contact us at (720) 295-3760.

Additional Disclosures

Mighty Invest, LLC (“us”, “we”, or “our”) operates http://www.investmighty.com and Mighty mobile application (hereinafter referred to as “Service”).
Our Privacy Policy governs your visit to http://www.investmighty.com and Mighty mobile application, and explains how we collect, safeguard and disclose information that results from your use of our Service. 
We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

  • Definitions

SERVICE means the http://www.investmighty.com website and Mighty mobile application operated by Mighty Invest, LLC.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

  • Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

  • Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  1. Email address
  2. First name and last name
  3. Phone number
  4. Address, State, Province, ZIP/Postal code, City
  5. Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  1. Session Cookies: We use Session Cookies to operate our Service.
  2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
  3. Security Cookies: We use Security Cookies for security purposes.
  4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
  • Use of Data
    Mighty Invest, LLC uses the collected data for various purposes:
  1. to provide and maintain our Service;
  2. to notify you about changes to our Service;
  3. to allow you to participate in interactive features of our Service when you choose to do so;
  4. to provide customer support;
  5. to gather analysis or valuable information so that we can improve our Service;
  6. to monitor the usage of our Service;
  7. to detect, prevent and address technical issues;
  8. to fulfill any other purpose for which you provide it;
  9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  12. in any other way we may describe when you provide the information;
  13. for any other purpose with your consent. 
  • Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

  • Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Mighty Invest, LLC will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

  • Disclosure of Data

We may disclose personal information that we collect, or you provide:

  • Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

  • Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

  • Other cases. We may disclose your information also:
  1. to our subsidiaries and affiliates;
  2. to fulfill the purpose for which you provide it;
  3. for any other purpose disclosed by us when you provide the information;
  4. with your consent in any other cases;
  5. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
  • Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

  • Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/ 

According to CalOPPA we agree to the following:

  1. users can visit our site anonymously;
  2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
  3. users will be notified of any privacy policy changes on our Privacy Policy Page;
  4. users are able to change their personal information by emailing us at support@investmighty.com. 

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. 
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

  • Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

  • Analytics

    We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Firebase

Firebase is an analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Flurry Analytics

Flurry Analytics service is provided by Yahoo! Inc.
You can opt-out from Flurry Analytics service to prevent Flurry Analytics from using and sharing your information by visiting the Flurry's Opt-out page: https://dev.flurry.com/secure/optOut.do
For more information on the privacy practices and policies of Yahoo!, please visit their Privacy Policy page: https://policies.yahoo.com/us/en/yahoo/privacy/policy/index.htm

  • Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click 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.

  • Children's Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”). 
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

  • Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

  • Contact Us 

If you have any questions about this Privacy Policy, please contact us:
By email: support@investmighty.com.

 

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