Privacy Policy

Thank you for using the CopyForward service available via the Internet and/or mobile application(s) (collectively, the “Service” or “Services”) located at the URL www.copyforward.io, available via APIs as embedded in other sites or services, or downloaded to your device. The Services are owned and operated by CopyForward Inc. (“we,” “us,” “our”). The Services enable users to enter and manage assets in their own private portfolio, publish assets for sale via third party websites and applications, and record transers of assets that bear permanent royalties for all prior owners subject to the Terms and Conditions of Sale also found at www.copyforward.io/terms.

Privacy is our priority. This Privacy Policy details certain policies governing our use of personally identifiable information about users of the Services and users of our Services. In addition, this Privacy Policy incorporates and is subject to the Terms of Use found here: www.copyforward.io/terms.

Privacy Policy Updates

Due to the Internet’s rapidly evolving nature, we may need to update this Privacy Policy from time to time. If so, we will post its updated Privacy Policy on our Services along with a change notice. We may also choose to send registered users of our Service a notice that this Privacy Policy has been changed, but we are not obligated to do so. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of our Services and/or your continued provision of personally identifiable information to us after the posting of such notice will be subject to the terms of the then-current Privacy Policy.

Information Collection and Use

To use our Services, we require strict KYC (“Know Your Customer” or “KYC”) and identify verification which requires you to enter your personally identifiable information. We may invite you to contact us with questions or comments or request information, provide us with feedback, or complete a profile or registration form. Due to the nature of some of these activities, we will collect personally identifying information such as your name, address, zip code, government-issued photo id, email address, phone number, username, password, industry or employment information, credit card information, PayPal account information, and other contact information that you voluntarily transmit with your communication to us. We also may collect information about you and your use of our Services through your use of our Services and the data and information that you voluntarily elect to upload to our Services.

It is important to us that you know that the Assets you upload to your portfolio when using our Service are completely confidential and private to you. We do not make any information about you or any of your Assets known unless you direct us to publish Assets to a specific destination or record the transfer of any Assets to buyers.

We will use your personally identifying information to verify your identity (“Know Your Customer” or “KYC”), register you to use our Services, deliver our Services or information you have requested, verify your authority to use our Services, improve the content and general administration of our Services, provide you with notices regarding goods or services that you have purchased or may wish to purchase in the future, notify you as a buyer, seller, or prior owner, and for targeted advertising. You will be able to opt out of receiving any communications from us that are not essential to the functioning of the Services that you use.

Children’s Privacy

We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Our Services are not intended for children under the age of 13. We do not target our Services to children under 13. We do not knowingly collect personally identifiable information from children under the age of 13 and will take prompt steps to delete any such personally identifiable information if notified that any has been inadvertently collected.

Cookies

We may use small text files called cookies to improve your overall experience using our Services. A cookie is a piece of data stored on the your device containing information about the you. Cookies generally do not permit us to personally identify you.

We may use Google Analytics’ 3rd-party audience data, such as age, gender, and interests, to better understand the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. You may see certain ads on other websites because we contract with Google and other similar companies to target our ads based on information we or they have collected, including information that was collected through automated means (such as cookies and web beacons).

These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

You may edit or opt-out of the automated collection of information by third-party ad networks, for the purpose of delivering advertisements tailored to your interests, by visiting Google Display Network ads’ preferences at https://www.google.com/ads/preferences

Aggregate Information and Use of your Data

Our Services may track the total number of visitors, the number of visitors to each page or function, browser type, IP addresses, External Web Sites (defined below) linked to, and other aggregated data collected through our Services, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used, and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer our Services, track users’ movement, and gather broad demographic information for aggregate use.

We will use your data and information that you upload to the Services only as necessary to provide our Services to you and other users, as appropriate. Only you have access to your data and personally identifiable information, except that admin queries do access user’s data (but not their personally identifiable information), but only as aggregate “count” type queries with no identifying information.

Users of our Services have control over the disposition of their data and personally identifiable information, including the ability to delete, transfer, provide access to such data and/or personally identifiable information, and revoke access to such data and personally identifiable information.

Disclosure of Personally Identifiable Information

We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our Services to you. For example, we may provide your personally identifiable information to an email management company to provide you with notices about our Services. If you use our support, our support service provider will have access to any personally identifiable information that you upload or submit. We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation, or other government authority or to assist in any investigation, to protect our or our users’ rights or to enforce our Terms of Use. We will not sell your personally identifiable information to any company or organization, except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation, or other corporate reorganization in which we participate or to a purchaser of all or substantially all of the assets to which our Services relate.

We will provide your personally identifiable information to third parties per your instructions if you are a user of our Services and through the Services you request us to send certain information that may include personally identifiable information to third parties (such as a regulatory agency). Within our Services, you may give access to your records and Assets to other users, and those users with such access will be able to view your records and Assets (and any personally identifiable information included in such records). Except as otherwise stated in this Privacy Policy, we will not disclose your records to third parties.

Links to Third Party Sites

Our Services may provide links to other websites or resources over which we do not have control (“External Web Sites”). Such links do not constitute our endorsement of those External Web Sites. You acknowledge that we are providing these links to you only as a convenience, and further agree that we are not responsible for the content of any such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked-to External Web Sites.

Security

We may employ procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration, or destruction. We may use firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information. However, no security system is perfect, and we cannot guarantee that personal information you provide to us over the Internet will remain private. We also cannot guarantee that information you transmit to us over the Internet will not be intercepted. When you register for our Services, we encourage you to choose a strong password (typically long, contain capital and lowercase letters as well as numbers and symbols, and do not consist of dictionary words or any of your biographical information).

Retention of Personal Information

We keep your personal information only as long as necessary for the purposes for which it was given to us. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Generally, this means we retain your personal information to comply with any retention or statutory limitations or for purposes of performing a contract with you. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit its active use.

Access

If you are a registered user of our Services, you may correct, amend, or delete your personally identifiable information that we store, except where the burden or expense to us of providing access would be disproportionate to the risks to your privacy or where the legitimate rights of persons other than you would be violated. Please access your account to correct, amend or delete your personally identifiable information. Additionally, if you wish for all of your personal information to be removed from our systems, you may submit a request for your account to be deleted. Upon deletion, all of your personal information will be permanently expunged from our primary production servers and further access to your account will not be possible. However, portions of your information, consisting of aggregate data derived from your personal information and data, may remain on our servers indefinitely.

Information for California Residents

In addition to the other information and rights described in this Privacy Policy, California residents are also entitled to certain additional information and have certain additional rights under the California Consumer Privacy Act (“CCPA”) with respect to their personal information. If you are a resident of California (a “Consumer” as defined by the CCPA), this section of the Privacy Policy applies to you.  If you are not a Consumer, this section does not apply to you and you should not rely on it.

A. Information We Collect and How We Use It

Below is a summary of our collection and use of “personal information” (as defined by the CCPA) about Consumers in connection with our Services.  For additional details, please consult the other sections of this Privacy Policy.

Categories of Personal Information we may collect and use for our commercial and business purposes:

  • Contact and account registration information.When you register for an account or contact us, you may provide your name, email address, physical address, phone number, government-issued photo identity, account username and password, electronic signature, and other related information.
  • Financial or payment information. We collect information about payment methods that you provide, billing information, Royalties due and paid, Purchase Price, and information about the products or services you buy or sell.
  • Transaction information.When you use the Services to conduct a transaction, we will collect names, phone numbers and email addresses of parties to a transaction, description of assets, royalty percentages, other options (such as buyout/no buyout) and personal information about those individuals or their devices, such as name, email address, IP address, and authentication methods.
  • Customer service information. We collect information about your support and customer service communications with us, including, for example, questions and other messages you address to us directly through online forms, by email, over the phone, or by post.
  • Information about your web browser, mobile device, or internet connection. When you access our Services online, we may automatically collect IP address, device identifiers and device attributes, including cookie IDs, mobile advertising IDs, and other similar unique identifiers, data about how you interact with the Services online (usage data), location information (e.g., city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation) and, with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile device.

Commercial and Business purposes for which we use the personal information we collect:

  • Provide you with and collect payments and Royalties for Assets which you transfer and Services you request.
  • Create your account and manage your relationship with us (e.g., communicating with you, providing you with requested information).
  • Send you records of our relationship, including for purchases or other events.
  • Market features, products, or special events using email or phone or send you marketing communications about third party products and services we think may be of interest to you.
  • Record details about transactions involving Assets.  
  • Run promotions, contests, and refer-a-friend programs.
  • Choose and deliver content and tailored advertising and support the marketing and advertising of our Services.
  • Create and review data about our users and how they use our Services.
  • Test changes in our Services and develop new features and products.
  • Fix problems you may have with our Services, including answering support questions and resolving disputes.
  • Manage the Services platform including support systems and security.
  • Prevent, investigate, and respond to fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior.
  • Comply with legal obligations.
  • Meet legal retention periods.
  • Establish, exercise, or defend our rights in legal claims.

B. The Right to Opt Out of Sales of Personal Information

Consumers have the right to opt out of “sales” of their personal information under the CCPA. According to the CCPA, and subject to certain exceptions, a business “sells” personal information when it sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or by electronic or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration.

As explained further in this Privacy Notice, we share personal information with other companies. 

Consumers may submit requests to opt out of such sharing using the following methods:

  • Adjust your cookie settings and select the option to opt out of respective cookie activities.  
  • Click the link to “unsubscribe” at the bottom of any of our marketing communication.

C. The Right to Access

Consumers have the right to request certain details about the personal information we have collected about them (generally, within the past 12 months). This includes the right to request:

  • The specific pieces of personal information and the categories of personal information that we have collected about them.
  • What categories of personal information we sold or disclosed for business purposes and the categories of third parties to whom we sold or disclosed that information for a business purpose.
  • The categories of sources from which we collected personal information.

D. The Right to Deletion

Consumers have the right to request that we delete the personal information we have collected from them. In certain circumstances, however, the CCPA allows us to retain information for particular purposes (for example, if we need to retain the information to meet our legal obligations, and for certain other limited reasons set forth by the CCPA).

E. How to Exercise Access and Deletion Rights

Consumers may submit requests for access to or deletion of their personal information using any of the following methods:

For security purposes, we will attempt to verify your identity prior to fulfilling your request. If you have an account with us, we may verify your identity through your login to your account. If you do not have an account with us, we may need to respond to your request or otherwise contact you to request additional information from you to verify your identity (including, but not limited to your name, email address, or telephone number).

If we are able to verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you or we may deny your request. If we are unable to fulfill your request(s) in their entirety, we will provide further information to you about the reasons that we could not comply with your request. 

Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services.

F. The Right to Nondiscrimination

Consumers have the right not to be discriminated against for exercising their CCPA rights. We will not deny, charge different prices or Royalties for, or provide a different level of quality of goods or Services with respect to Consumers who choose to exercise their CCPA rights.

G. Authorized Agents

Consumers may designate an agent to make CCPA requests on their behalf. For Consumers who do so, we will take steps to verify both the identity of the Consumer seeking to exercise their rights as described above, and to verify that the Consumer’s agent has been authorized by them to make a request on their behalf by requesting a signed written authorization or a copy of a power of attorney.

H. “Shine the Light”

California residents may ask for a list of third parties that have received their personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. If you are a California resident and would like to request this information, please contact us at support@copyforward.io.

Your Privacy Rights

You may have certain rights related to your personal information, subject to local data protection laws. To exercise any of these rights, please contact us at support@copyforward.io.

  • You can access and review personal information associated with your account at any time by clicking here: https://support.copyforward.io.
  • You also can request the following information: how we collect and use your personal information and why; the categories of personal information involved; the categories of recipients of your personal information; how we received your personal information and its source; our business purpose for using your personal information; and how long we use or store your personal information or the manner in which we determine relevant retention periods. 
  • You have a right to correct inaccurate personal information about you, and you should notify us immediately if you believe the personal information we hold about you is inaccurate, incomplete, or out-of-date.
  • In certain situations, you can ask that we erase or stop using your personal information, object to or restrict the use of your personal information or export your personal information to another controller. 
  • Where we rely on your consent to process your personal information, you have the right to decline consent and/or, if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your personal information for direct marketing purposes.
  • If you are unsatisfied with our response to your complaint, you have a right to raise questions or complaints with your local data protection authority at any time.

If you make a request to exercise the rights referenced above, we will require you to provide certain information for identity verification purposes. If you have an account with us, we may verify you through your login of your account. If you do not have an account with us, we may require you to provide additional information from which we can confirm your identity. You may authorize an agent to make a request to us on your behalf and we will verify the identity of your agent or authorized legal representative by either seeking confirmation from you or documents that establish the agent’s authorization to act on your behalf.

Certain personal information may be exempt from such requests under applicable law.

If you wish to exercise these rights, please contact us at www.copyforward.io.

Notice to European Users

Our Services are targeted for users in the United States of America. Any information you enter using the Services or otherwise provide to us may be transferred outside of the European Union to the United States of America, which does not offer an equivalent level of protection to that required in the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union’s Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of personal information, regardless of the third country’s level of protection. By agreeing to the Terms of Use and this Privacy Policy, you consent to the transfer of all such information to the United States of America, which may not offer an equivalent level of protection to that required in the European Union, and to the processing of that information on our servers located in the United States of America as described in this Privacy Policy.

Questions

If you have any questions regarding this Privacy Policy, please contact us via email at support@copyforward.io.

This Privacy Policy was last updated: August 14, 2021CopyForward Inc.