Terms of Use

Last Updated: December 20, 2019

Introduction

Royalty Exchange and its affiliates and subsidiaries (“Royalty Exchange,” “Company,” “we,” “us,” or “our”) respect your concerns about privacy. This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used. We also detail below our security policy, which describes how your personal information is protected.

In general, and as described in detail below, we collect several types of information from you:

Information we collect from you and about you

We collect personal and financial information from you while you use the site, and most of this collection occurs during registration. Additional information may be gathered during your subsequent use of the site, whenever you choose to provide it.

Certain personal information must be supplied during the registration processes, as indicated below, in order to (a) enable registered users to login to the site, (b) determine users’ eligibility to participate in the marketplace, (c) verify your identity, and (d) guard against potential fraud. This basic personal information includes:

We may request or you may choose to provide additional information such as credentials, access or links to your accounts with various third parties (i.e. financial institutions, royalty distributors, etc.).

We will use your required and optional information to facilitate activities and transactions, such as:

In addition, we gather names and email addresses of people who contact us through our web site with questions about our company or operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people, such as in the case of job applicants who submit resumes, etc.

We (and/or our service providers) collect information about your computer and your visits to our web site, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our web site to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our web site based on the needs of our users.

Finally, we may receive information about you from our trusted business partners and service providers.

We will retain your information for as long as your account is active, as needed to provide you services or as otherwise needed for our business purposes. We will retain and use your information as necessary to comply with our legal obligations, complete transactions, resolve disputes, improve our products and services, and enforce our agreements.

Communications from our Site

When you register on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses, and confirmation of marketplace participation. You will also receive progress updates on the status of auctions and transactions that you participate in. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

How and when your information is shared with other parties

We may share personal information we collect with our trusted business partners that perform vital functions as part of our operations, including electronic payment service providers and transaction processors. We also will share information with service providers that perform services on our behalf. These partners and service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We may share our research or analysis of aggregated customer data or information we receive, but only in a way that would not allow you or any other person to be identified.

We may also disclose information about you: (i) if we are required to do so by law or legal process (such as in SEC filings), (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iv) if necessary to protect the vital interests of another individual (such as to prevent death, bodily harm, or serious damage to property). We reserve the right to transfer information about our users in the event we sell or transfer all or substantially all our business or assets.

Web-related information collection

We use web beacons or pixel tags, which are tiny graphics, in conjunction with cookies on our web site, including session ID cookies, non-persistent cookies and persistent cookies. A cookie is a text file sent by a web server to a web browser and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser and load the pages according to a user’s preferences for that particular site, including the personalization of content. Cookies are also used to gather statistical data, such as which pages are visited, what is downloaded, the ISP’s domain name and country of origin, and the addresses of sites visited before and after coming to our site, as well as your “click stream” activity (meaning, the paths taken by visitors to our site as they navigate from page to page) and transactional attributes in accordance with information you voluntarily submit in the course of using our site. This data is aggregated for analysis to ensure proper functioning of our site, in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing efforts. At no time do any of our cookies capture any personal information. More importantly, using cookies also helps us protect the security of your account. Session ID cookies follow your activities on our site so that we can ensure that no one is making changes to your profile, applying for loans or making loans on your behalf. This information is encrypted and no personal data about you is stored on our servers.

We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our web site, to improve its usability and for evaluating our marketing effectiveness as described above. We may also use that information to recognize your computer when you visit our web site (if you select the “remember me on this computer” option, and to personalize our web site for you. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookie by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector). Blocking cookies, however, can also have a negative impact on the usability of many web sites.

Cookies may have long-term expiration dates, or none, and thus can stay in your hard drive for months at a time. While you can remove them as instructed by the help content in your chosen browser, disabling cookies will prevent you from using our site. As with many transactional web sites, cookies must be enabled in order to use our site.

We use third-party tracking services (e.g. Hotjar, Google Analytics, Heap) that use cookies to track non-personal information about visitors to our site in the aggregate (such as web page views and referral page information to track the success of our marketing efforts to bring people to our site as well as overall site performance). We use respective web beacons to gather information that lets us tune and improve our users’ browsing experience, as well as track user responsiveness to various advertising campaigns and user activities. As with cookies, the information these beacons collect is aggregated, anonymous “click stream” and transactional data, and is not associated with any users as individuals. No personal or sensitive information is transmitted to advertising partners (but some partners may use incoming IP addresses to avoid double-counting the number of new members who joined as a result of the advertising campaign).

If you would like more information about the use of third-party cookies and tags, or the process of opting out of such cookies or tags, please visit https://www.hotjar.com/legal/compliance/opt-out and http://www.google.com/privacy.html and https://heap.io/privacy.

We use Hubspot to gain insight into visitor flows, traffic sources and page views on our website, and to initiate and track email interactions. Entering information on our website and interacting with our emails will cause you to be personally identified. This means we can see, for example, whether you open our email and whether you click through to our website, and what your website activities are. If you wish to avoid this tracking, you can unsubscribe from our mailings and/or customize the settings of your browser so that it refuses cookies. For more information, please refer to Hubspot’s Privacy Policy here: https://legal.hubspot.com/privacy-policy.

We may allow third-party companies, including ad networks, to serve advertisements, providing other advertising services and/or collect certain information when you visit our website.  Third-party companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visit to this website in order to provide advertisements about goods and services likely to be of interest to you.   To learn more about Interest-Based Advertising or to opt-out of this type of advertising, you can visit AboutAds.info/choices or www.networkadvertising.org/choices/.

Compliance with state and federal laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Where required under applicable law, we will only collect and process personal information about you if we can rely on a valid legal ground for that processing, such as consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Service you have requested)), legal obligations (e.g. for compliance with securities laws) and “legitimate interests” (e.g. for product development and analytics purposes).

If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us as described below.

California Users: Subject to certain limitations, the California Consumer Privacy Act provides California consumers the right to request more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@royaltyexchange.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

European Users: If you are located in the European Economic Area or Switzerland, you may have the right to:

Request access to and receive information about the personal information we maintain about you, to update and correct inaccuracies in your personal information, to restrict or to object to the processing of your personal information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your personal information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

Withdraw any consent you previously provided to us regarding the processing of your personal information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Those rights may be limited in some circumstances by local law requirements. You may exercise your rights by contacting us as specified below.

Links to other sites

We may offer links to partners’ sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled or to facilitate our customers’ more effective use of our platform, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy and may have different privacy policies or approaches to the handling of information. Further, we have no control over the content of these sites. Please consult the privacy policies on these sites before you provide them with any of your personal information.

Access, correction, and deletion

We will provide you with the ability to access, correct, or delete certain information we have about you, such as your contact information. Your right to access, correct, or delete personal information may be limited in some circumstances. Please submit your request by sending an email to the address specified in the “How to Contact Us” section below. Please include your name, email address, and postal address in your request, and describe specifically the information that you would like to access, correct, or delete so that we may respond appropriately and promptly.

How we protect personal information

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases your information is accessible when you log into a feature we offer, and in those cases you need to keep your log in information, such as your password, confidential and secure so that your information is protected.

We may make changes to this policy

As technologies, laws and user needs change, our site and its features will also change. This policy may be updated from time to time as such needs dictate, and we will indicate at the bottom of this page the date the policy was last updated.

How to contacts us

If you have any questions or comments about this policy, or if you would like us to update, amend, or request deletion of the information we have about you or your preferences, please contact us as follows:

Address:

Royalty Exchange Inc.

1550 Larimer St. #769

Denver, CO 80202

Attn: Privacy Department

Email: privacy@royaltyexchange.com