Notice to California Residents
This Notice to California Residents (“CA Notice”), provided by the Forge Group (“Forge,” “we,” “us,” or “our”) supplements our Privacy Policy and applies to natural persons who reside in the State of California (“consumers” or “you”) that visit our Sites, access or use our Services or that otherwise engage or interact with us. Any terms used herein but not defined shall have the meaning assigned in our Privacy Policy.
In the event of any conflict or inconsistency between this CA Notice and our Privacy Policy, this CA Notice shall control only with respect to the Personal Information of consumers, their households or devices. This CA Notice does not apply to our processing of Personal Information relating to our job applicants, employees, contractors and other Forge personnel or other individuals other than residents of California. If you are located outside of the State of California please refer to our Privacy Policy.
Information We Collect
For the purposes of the CA Notice, “Personal Information” does not include (i) publicly available information from government records; (ii) de-identified or aggregated Personal Information; or (iii) information excluded from the CPRA including information regulated by certain sector-specific data protection laws including the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act of 1999, and the California Financial Information Privacy Act.
We have collected the following categories of personal information from the categories of sources and for the purposes set forth below.
| Category of Personal Information | Collected |
|---|---|
| Identifiers, such as name, email address, billing address, shipping address, zip code, telephone number, email address, date of birth, account name and password, or other similar identifiers. |  |
| California Customer Records (Cal. Civ. Code § 1798.80(e)), such as driver’s license number, bank account information, credit or debit card information, or any other financial information. | |
| Protected Classification Characteristics, such as Social Security number and national origin. | |
| Commercial Information, such as your wagering activity, purchasing history and ordering behavior. | |
| Biometric Information, such as facial geometry used for identity verification purposes. |  |
| Internet/Network Information, such as IP address, device information, log and analytics data. | |
| Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address, but not your precise geolocation (e.g., latitude/longitude). | |
| Sensory Information, such as recordings of phone calls between you and us, where permitted by law. | |
| Professional/Employment Information, such as current occupation and income, job history and experience. | |
| Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), such as academic record. | |
| Other Personal Information, such as survey information, and information post on our applications or on social media pages, including pictures or videos of you, or other information you submit to us. We also collect information from the profile you create, such as your profile picture and loyalty program account number. | |
| Inferences, including information generated from your profile, as well as any of the information above and your use of our Services. | |
The following personal information elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):
- Your account log-in, password, or credentials allowing access to an account;
- Financial account information;
- Social security, driver’s license, government identification card, or passport number; and
- Information about your citizenship, residency or immigration status.
Forge only uses or discloses sensitive information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, to comply with our legal and regulatory obligations, for detecting security incidents, fraud and other illegal actions, to ensure the physical safety of natural persons, to perform services on behalf of the business, or for solely internal purposes, consistent with our Privacy Policy and any other expectations we’ve set with you. Forge only collects and processes sensitive information without the purpose of inferring characteristics about a consumer.
We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.
Sources of Personal Information
We collect personal information about you from one or more of the following sources:
- Directly from you (through the Services or via our service providers);
- Our business partners and other Forge affiliates;
- Third parties, such as third-party social networks, intermediate entities such as funds and “special purpose vehicles” that handle securities pools on behalf of Forge or on their own account, stock issuers, your employer or other third parties who purchase our Services for you or otherwise direct our Services to you;
- Industry sources, including trade show, conference and webinar providers;
- Your browser, device, through cookies or other data collection technologies on our Services
- Generated or derived from other Personal Information
Please note: In addition to the categories of sources identified above, we may collect information from publicly available sources and other third-party information providers in order to supplement the information we have otherwise collected.
Use and Disclosure of Personal Information
We may use or disclose the Personal Information for one or more of the commercial or business purposes and with the categories of third parties set forth in the Why we collect personal information and Onward transfer of personal information sections of our Privacy Policy, respectively.
The categories of third parties to whom we may sell or share Personal Information include:
- Affiliates; and
- Online Advertising Networks and Analytics Providers.
We have sold or shared the following categories of Personal Information to non-affiliated third parties for the purposes of target advertising, subject to your settings and preferences, and your right to opt-out:
- Identifiers; and
- Internet / Network Information.
Please see our Privacy Policy to learn more about how third-party advertising networks, social media companies and other third party businesses collect and disclose your Personal Information directly from your browser or device through Cookies when you visit or interact with our websites, use our apps or otherwise engage with us.
Data Retention
We will usually store the Personal Information we collect about you for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and legal requirements. However, if necessary, we may retain Personal Information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Your Rights and Choices
Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
| The Right to Know |
The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including:
|
| The Right to Access & Portability |
The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. |
| The Right to Correction |
The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. |
| The Right to Control Over Sensitive Information |
The right to exercise control over our collection and processing of certain sensitive information. |
| The Right to Deletion |
The right to have us delete the personal information we maintain about you. |
| The Right to Opt-Out of Sales or Sharing of Personal information |
The right to direct us not to “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. |
| The Right to Control Over Automated Decision-Making / Profiling |
The right to direct us not to use automated decision-making or profiling for certain purposes. |
Non-Discrimination / Non-Retaliation. You also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
Exercising Your Right to Know, Access, Portability, Correction or Deletion. To exercise these rights, please submit a verifiable consumer request to us by either: (a) submitting your request via this web form, or (b) submitting your request by email to [email protected].
You may only make a verifiable consumer request under the right to know or access twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you. Making a verifiable consumer request does not require you to create an account with us.
Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising
Sale. Under California law, the definition of “sale” is broad and covers many common business activities, even when the Personal Information used is not exchanged for money, or when it has been partially de-identified. Forge shares personal identifiers and internet and network information for data analytics including fraud detection, marketing and advertising purposes, for example, to better understand engagement with our Services, to match your interests with similar products you may also be interested in, to offer advertising for our products across other devices that you use, and to identify other consumers with interests similar to yours who may also be interested in our products. These broad business uses may be considered “sales” under California law, subject to your right to opt out.
Share. When we use the term “share” or “sharing” we mean sharing, renting, releasing disclosing, disseminating making available, transferring or otherwise communicating orally, in writing, or by electronic or other means, your personal information by us to a third-party for cross-context behavioral advertising.
We do not “sell” or “share” sensitive information.
To opt out of the “sales” or “sharing” of your Personal Information for the purposes of cross-contextual behavioral advertising, or any potential future “sales” or “sharing” of your Personal Information, please complete the following steps.
- Sites. To opt out of advertising cookies on the website, navigate to your browser’s settings and clear your cache and delete all cookies stored on your browser. Then, please click on Do Not Sell or Share My Personal Information, where you can opt out of the collection of your Personal Information through advertising cookies on the Site. Please note that this opt-out is device- and browser-specific and will not be effective on your visits to the Services from other devices or browsers. Please note that deleting and opting out of some Cookies may result in an inability to take full advantage of the services.
- Other Potential Future “Sales” and “Sharing”. If you are a registered user, you may request to opt out of other potential future “sales” and “sharing” and to be added to our suppression list by submitting your request by email to [email protected] with the subject line “Consumer Opt-Out Request” and sufficient information in the content of the message to identify you in our records.
However, you may change your mind and opt back in to Personal Information sales at any time by contacting us at [email protected].
Right to Designate an Authorized Agent. In certain circumstances, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf, or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney.
For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the data subject on whose behalf the request was made.
If you wish to submit a request to access, modify or delete information on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., that you are the child’s legal guardian or authorized representative).
Minors
We do not sell the Personal Information and do not have actual knowledge that we sell the Personal Information of minors under 18 years of age.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected Personal Information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).
Changes to Our CA Notice
This CA Notice is effective as of the date of the Effective Data stated at the top of this CA Notice. We may change this CA Notice from time to time with or without notice to you. By visiting or accessing the Website or the Services, purchasing products or services from us, or otherwise engaging or interacting with us after we make any such changes to this CA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CA Notice in current effect. Please refer back to this CA Notice on a regular basis.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
E-mail: [email protected]