PLEASE NOTE OUR PRIVACY POLICY RELATED TO CHILDREN UNDER THE AGE OF 13 CAN BE FOUND IN SECTION 8 ON THIS DOCUMENT.
Sootchy Inc., Sootchy Securities, LLC and both entities’ officers, directors, employees, agents, members, managers, successors, assigns, predecessors, group companies, affiliates and subsidiaries from time-to-time (collectively referred to herein as “we”, “us”, “our”, or “Sootchy,”) are committed to protecting your privacy. This online privacy policy (“Privacy Policy” or “Policy”) describes how we gather and use your personal information.
This Privacy Policy applies to our mobile application, web application (together, the “App”) and website as well the investment advisory services provided by Sootchy Securities (collectively, our “Service(s)”), and describes our practices relating to the collection, recording, use and disclosure of personal information collected from or about our current and past clients, website visitors, mobile application users and other individuals. By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Use. In this Privacy Policy, personal information means “personally identifiable information.” This Privacy Policy will be reviewed periodically and will be updated to reflect any changes.
The services of Sootchy are listed on www.sootchy.com. You acknowledge and agree that your personal data collected may be used in accordance with this Policy by and for one or more Sootchy companies, which will be regarded, individually or jointly, as data controllers in respect of such data.
This Policy applies to personal data collected in connection with services offered by Sootchy or from other interactions with us where a link or other appropriate reference of incorporation to this Policy is made, for example, in connection with our website, applications and other types of services offered by Sootchy typically in electronic form, as well as other services, such as customer care, customer events, or promotions and campaigns.
Sootchy uses personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. We collect and receive information about you from various sources including the following:
1.1 Information you provide. Sootchy may collect public and non-public personal information about you from you or your representative.
1.2 Information collected through your use of the Sootchy Website. When you download and use our Service, we automatically collect information on the type of device you use, operating system version, and the device identifier. We collect information about how you use the Service, including information about your transactions and account activity with us and with any college savings programs and service providers who help us provide the Service.
1.3 Information from third parties. We may obtain information about you from third parties including the custodian holding your college savings accounts, companies we work with to develop or enhance the Service, companies we use to verify your identity (including your wireless provider), our affiliates, public sources and others. This information could include, among other things, information about your account transactions and balance and personally identifiable information. We may also obtain publicly available demographic data, and any information needed to comply with regulatory requirements, ensure the accuracy of data, better understand your likely interests, and/or prevent fraud.
1.4 Information from third-party social networking or authentication services. We may also receive personal information about you from third-parties when you log in through a third-party social networking or a single sign-on service. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, e-mail address, address book and contacts or other information. We use this information in the same way we use other personal information we collect from you as described in this Policy.
1.5 Information received via Cookies and other tracking technology. We, and our third-party service providers, automatically collect certain types of usage information when you visit our websites, use our Service, read our emails or otherwise engage with us via “tracking technologies”.
From these various tracking technologies, we may collect information about your device and its software, including but not limited to your IP address, browser type, Internet service provider, network domain, platform type, device type, operating system, date and time stamp. We may also collect information about the way you use our Service, how frequently you access the Service, access times, whether you open emails or click the links contained in emails, what content you view, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data including information regarding the location of your mobile device (subject to your prior consent when prompted). We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the websites and to understand more about the demographics of our users.
We do not collect personal information about your online activities over time and across different web sites or online services. Therefore, our websites do not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect personal information about your online activities over time and across different web sites or online services.
When you use our Services or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by the telecommunications operator as a standard part of that communication. Please also see the “Cookie Policy” section below.
Examples of Tracking Technologies include:
1.6 Data concerning minors. We do not seek to collect any information from or engage in any transactions with persons under the legal age in their respective country. Our databases may nevertheless contain personal data of children due to the fact that it is not always possible to determine precisely the age of the user. If we learn that a minor has provided personal information through our services, we will use reasonable efforts to remove such information from our files. We reserve the right to block the service from any person who is or whom we reasonably suspect of being a minor. Sootchy’s policy is to request that minors do not engage in other legal acts on relating to our services without the consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have your legal guardian’s consent, you must be able to prove that such consent exists upon request.
Consistent with applicable law and the choices available to you, we use the information we collect for the purposes below. Please note that one or more purposes may apply simultaneously:
Sootchy does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information in the instances described below. For further information on your choices regarding your information, see the Your Choices section below.
Sootchy, Inc. partners with financial services software company Sila Inc. (Sila) and banking services provider Evolve Bank & Trust (Evolve), member FDIC, to offer you electronic fund transfers and provide you with an Account. By registering for our platform, linking your external bank account, and authorizing any electronic payment, you authorize us to share your identity and banking information with Sila and Evolve to support your Account. You also agree to the terms and conditions of Sila’s privacy policy, https://www.silamoney.com/legal/sila-privacy-policy, and Evolve’s privacy policy, https://www.silamoney.com/legal/evolve-privacy-policy (the “Partner Privacy Terms”). It is your responsibility to ensure the data you provide to us is accurate and complete, which is necessary for our partners to process electronic fund transfers on your behalf and provide you with continued access to the Account. The Partner Privacy Terms may be modified from time to time, and the governing versions are incorporated by reference as part of this Privacy Policy. IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER PRIVACY TERMS BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR ACCOUNT WITH US, INCLUDING BUT NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.
5.1 Accessing Your Data. You may access, and update information stored in your account profile by visiting the Sootchy website or mobile application. Please keep your contact, account, and preference information up-to-date. Doing so enables you to receive maximum possible benefit from the Service.
5.2 Modifying or Deleting Your Data.If you have any questions about modifying or deleting your information, you may contact us at help@sootchy.com. We may not be able to modify or delete your information in all circumstances. We will retain your information for as long as you are a Sootchy client and/or we reasonably deem it necessary to provide you services, comply with our legal or other obligations, resolve potential disputes, audit our records and/or enforce our rights and obligations under our agreements. If you no longer want us to use your information to provide you services, you may terminate your Sootchy Client Agreement and request that your information be deleted. We may not be able to delete your information in all instances, such as if we are required to retain certain data for record-keeping purposes or to comply with laws.
5.3 Unsubscribe. If you do not wish to receive marketing messages from Sootchy, you may indicate your preferences by clicking the “Unsubscribe” link in the email. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service or technical and security notices).
We care about the security of your information and use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Service. At Sootchy, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you. If personally identifiable information is accessed through our Service, it is encrypted before it is transmitted over the internet. To protect your personally identifiable information, we use technical and physical safeguards and train our employees. Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction of your personal data. Where the Sootchy website supports online transactions, we will use an industry standard security measure, such as the one available through “Secure Sockets Layer” (“SSL”), to protect the confidentiality and security of online transactions.However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised in accordance with any applicable laws and regulations.
If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically,
To submit a request to exercise any of the rights described above, you may contact Sootchy, Inc. either by email to help@sootchy.com or contact us via postal mail, proper postage prepaid, at:
Sootchy, Inc.
Attn: Your California Privacy Rights
1234 Wilshire Boulevard, #104-A7
Los Angeles, CA 90017
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
In accordance with Children’s Online Privacy Protection Act (COPPA) we maintain additional privacy controls for children under the age of 13. Before allowing registration on our mobile application and before we collect personal information we will request a user’s date of birth. Based on this date of birth, if the user is under 13 we will ask for the child’s parent or guardian’s email address and/or phone number for the limited purpose of obtaining parental/guardian consent. We will not use the parent/guardian email for any purpose other than obtain consent without express consent of the parent/guardian. If we do not receive parent/guardian consent in a reasonable period of time we will delete the email.
The information we obtain from children under 13 will be limited to that which is deemed necessary. We will not share child information unless required by law, essential to protect Sootchy, necessary to enable our service providers to perform services, or to help protect a child’s safety.
At any time a parent/guardian can request that we terminate child access and delete any child information. Please note, that doing so may prevent the child from using our Services. To request terminating child access please email us at help@sootchy.com along with the child’s name and your email address and telephone number. You may also request we terminate access and data by sending a written request to Sootchy at 1234 Wilshire Boulevard, Suite 104-A7, Los Angeles, CA 90017.
This Service may contain links to and from third party websites of college savings programs, service providers, advertisers, and social media companies. It is important to remember that if you link to another website from any of our Sootchy websites, that party's privacy policy and its terms and conditions of use apply to you. We encourage you to learn about each third party's privacy policy before giving your information to them.
We may update this privacy policy to reflect changes to our practices from time-to-time. If we materially change this privacy policy or our information handling practices as described in this policy, we will notify you by email and/or through a notice on the applicable website prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.
Do not hesitate to contact Sootchy at help@sootchy.com with any questions or concerns you may have with our Privacy Policy. We want you to feel completely safe using our services, so we encourage ongoing communication with our clients
This Web Privacy Policy is effective as of March 6, 2023, and replaces any prior Sootchy Privacy Policy.
Sootchy.com collects some Personal Data from its Users.
This document can be printed for reference by using the print command in the settings of any browser.
Sootchy, Inc.
1234 Wilshire Boulevard, Suite 104-A7, Los Angeles, CA 90017
Owner contact email: support@sootchy.com
Among the types of Personal Data that Sootchy.com collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; phone number; email address; date of birth; address; country; Data communicated while using the service; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; app information; device information; device logs; username; website.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Sootchy.com.
Unless specified otherwise, all Data requested by Sootchy.com is mandatory and failure to provide this Data may make it impossible for Sootchy.com to provide its Services. In cases where Sootchy.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Sootchy.com or by the owners of third-party services used by Sootchy.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Sootchy.com and confirm that they have the third party's consent to provide the Data to the Owner.
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Sootchy.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data.
Certain Sootchy Services may allow you to manage your profile and the information in such profile. We encourage you to access your personal data via your profile from time to time to ensure that it is correct and up-to-date. Please remember that for such electronic services where you may manage your profile, it is your responsibility to provided us with correct details as well as to update the personal data you have provided us with in case of any changes.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, User database management, Managing contacts and sending messages, Traffic optimization and distribution, SPAM protection, Hosting and backend infrastructure, Interaction with external social networks and platforms, Tag Management, RSS feed management, Remarketing and behavioral targeting, Managing support and contact requests, Interaction with support and feedback platforms, Interaction with live chat platforms, Infrastructure monitoring, Heat mapping and session recording, Displaying content from external platforms, Content commenting and Backup saving and management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior
Backup saving and management
This type of service allows the Owner to save and manage backups of Sootchy.com on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Sootchy.com.
Contacting the User
Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Sootchy.com.Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Sootchy.com and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.Some of these services may record sessions and make them available for later visual playback
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Sootchy.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Sootchy.com.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Infrastructure monitoring
This type of service allows Sootchy.com to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Sootchy.com.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Sootchy.com. The interaction and information obtained through Sootchy.com are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on Sootchy.com isn’t being connected back to the User’s profile.
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of Sootchy.com, for contacting and being contacted by Sootchy.com support service.If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of Sootchy.com.If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Managing support and contact requests
This type of service allows Sootchy.com to manage support and contact requests received via email or by other means, such as the contact form.The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Remarketing and behavioral targeting
This type of service allows Sootchy.com and its partners to inform, optimize and serve advertising based on past use of Sootchy.com by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
RSS feed management
This type of service allows Sootchy.com to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.
SPAM protection
This type of service analyzes the traffic of Sootchy.com, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Sootchy.com in a centralized fashion.This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Traffic optimization and distribution
This type of service allows Sootchy.com to distribute their content using servers located across different countries and to optimize their performance.Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Sootchy.com and the User's browser.Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Sootchy.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Sootchy.com. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Sootchy.com.
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
Right to know/access
California residents have the right, (upon a verifiable request) to request the following:
You may request this information up to two (2) times each year, and we will respond within forty-five (45) days without charging you.
Additionally, you may request and obtain from us one (1) time per year, free of charge, information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes.
Please note that Sootchy may need to identify you and to ask for additional information in order to fulfill your request. You can make your request through the online webform listed below. You may be required to provide your email address on file with us among other information. We will acknowledge your request within ten (10) days. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.
Right to request deletion of personal information
Subject to certain expectations, California residents have the right to request deletion of their personal information collected or maintained by Sootchy.
Please note that Sootchy may need to identify you and to ask for additional information in order to be able to fulfill your request. You can make your request at the toll-free number or through the online webform listed below. In both instances, you may be required to provide your email address on file with us among other information. We will acknowledge your request within ten (10) days. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.
To submit a deletion request please email help@sootchy.com or submit a request through our online form – Please select Type of Request “Personal Data Management” and Data Request Type “Right to Deletion” prior to filling following fields when making your request. Please also indicate in the “Comments” field “Right to Deletion”.
Please note, to ensure that your personal information is permanently deleted, you should delete your cookies from your browser (refer to our link to Sootchy cookie policy) and decline giving your consent via our cookies preference center (link Sootchy website form).
California minors only
See DATA CONCERNING MINORS section above. A business shall not sell the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers at least 13 years of age and less than 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information. This is the right to opt-in. If you are between 13 and 16 years of age, you may opt-in simply by consenting to cookies via our cookies preference center (here). If you are under 13 years of age, we do not seek to engage with you in any transaction, tracking by cookies or otherwise.
Authorized agent
You have the right to designate an authorized agent to make any CCPA request on your behalf. Sootchy reserves the right to ask for proof that such agent is in fact authorized by you. Please direct your agent reach out by email at help@sootchy.com, or at (323) 677-4482. Authorized agents must submit proof of the consumer’s signed authorization to make a request. We may require you to verify your identity directly with us prior to fulfilling your authorized agent’s request.
CCPA Disclosures
Pursuant to the CCPA, and in addition to the disclosures elsewhere in this Privacy Policy, this section describes the types of personal information that we collected, disclosed for business purposes, or sold to third parties in the last twelve (12) months.
Right to Non-Discrimination for the Exercise of Your California Rights
You have the right not be discriminated against because you exercised any of your rights under California law.
EEA and UK residents’ rights
If you live in the European Economic Area (“EEA”) or United Kingdom (“UK”) and wish to access, amend, delete, or transfer any personal data we hold about you, you may contact us at help@sootchy.com. In some cases, you may also update your registration information or preferences by accessing your account settings page on our websites.
At any time, you may object to the processing of your personal data in our legitimate interests, except if otherwise permitted by applicable law. If you believe there has been a violation of your privacy rights, please contact us athelp@sootchy.com. You also have a right to lodge a complaint with your local data protection authorities.
You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of the products and services.
We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for analytics purposes, in which case we may use this information indefinitely without further notice to you.
Please be advised that the following below terms shall apply to EEA and UK residents to the extent they vary from the terms listed above.
EEA and UK MINORS only: See DATA CONCERNING MINORS above. A business shall not sell the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer’s parent or guardian has affirmatively authorized the sale of the consumer’s personal information. This is the right to opt-in. If you are under 13 years of age, we do not seek to engage with you in any transaction, tracking by cookies or otherwise.
To the extent Sootchy is required to respond to questions about data it collects, stores and sells, Sootchy shall endeavor to respond within thirty (30) days of the request being made.
To the extent Sootchy has any of your personal data, it shall promptly respond to requests regarding:
You have the right to lodge a complaint with the EU Commission if you are displeased with any of Sootchy’s responses. Sootchy shall endeavor to provide requested information electronically.
If you believe that any personal data that Sootchy has regarding you is inaccurate, please contact us at help@sootchy.com and inform us as to what you believe is inaccurate.
If you want to have any of your personal data that Sootchy has regarding you deleted, please contact us as at help@sootchy.com and Sootchy with endeavor to delete the information unless Sootchy is legally required to retain such information.
If you want to have any of your personal data that Sootchy has regarding you kept, but not used by Sootchy, please contact us at help@sootchy.com and Sootchy with endeavor to cease using such information.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Sootchy.com uses Trackers. To learn more, the User may consult the Cookie Policy.
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Sootchy.com or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Sootchy.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Sootchy.com and any third-party services may collect files that record interaction with Sootchy.com (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Sootchy.com does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this Privacy Policy
The Owner reserves the right to make changes to this Privacy Policy at any time by notifying its Users on this page and possibly within Sootchy.com and/or, as far as technically and legally feasible, sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Sootchy.com (or third-party services employed in Sootchy.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use Sootchy.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Sootchy.com who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Sootchy.com. The Data Controller, unless otherwise specified, is the Owner of Sootchy.com.
Sootchy.com (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Sootchy.com as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to Sootchy.com, if not stated otherwise within this document.
Latest update: February 2023
iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.
