By accessing this web site, you are agreeing to be bound by this website’s Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trade mark law.
1. Use License
- Permission is granted to temporarily download one copy of the materials (information or software) on Cody Shirk’s web site for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:
- modify or copy the materials;
- use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
- attempt to decompile or reverse engineer any software contained on Cody Shirk’s web site;
- remove any copyright or other proprietary notations from the materials; or
- transfer the materials to another person or “mirror” the materials on any other server.
- This license shall automatically terminate if you violate any of these restrictions and may be terminated by Cody Shirk at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.
- The materials on Cody Shirk’s web site are provided “as is”. Cody Shirk makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Cody Shirk does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet web site or otherwise relating to such materials or on any sites linked to this site.
In no event shall Cody Shirk or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption,) arising out of the use or inability to use the materials on Cody Shirk’s Internet site, even if Cody Shirk or a Cody Shirk authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.
4. Revisions and Errata
The materials appearing on Cody Shirk’s web site could include technical, typographical, or photographic errors. Cody Shirk does not warrant that any of the materials on its web site are accurate, complete, or current. Cody Shirk may make changes to the materials contained on its web site at any time without notice. Cody Shirk does not, however, make any commitment to update the materials.
Cody Shirk has not reviewed all of the sites linked to its Internet web site and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Cody Shirk of the site. Use of any such linked web site is at the user’s own risk.
7. Governing Law
Any claim relating to Cody Shirk’s web site shall be governed by the laws of the State of California without regard to its conflict of law provisions.
General Terms and Conditions applicable to Use of a Web Site.
- Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
- We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
- We will only retain personal information as long as necessary for the fulfillment of those purposes.
- We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
- Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
- We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
- We will make readily available to customers information about our policies and practices relating to the management of personal information.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
How to Contact Us
How to contact us. If you have any questions about our practices or this Privacy & Cookies Policy, please contact us at email@example.com.
Our EU Representative. As we do not have an establishment in the European Union (“EU”), you may address any issues or queries you may have relating to our processing of your Personal Data and/or this Privacy & Cookies Policy more generally by emailing at the following address: firstname.lastname@example.org.
Your Rights Relating To Your Personal Data
You have the right under this Privacy and Cookies Policy, and by law if you are within the EU, to:
- Request access to your Personal Data. If you are within the EU, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right if you are within the EU to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. If you are within the EU, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights. If you want to exercise any of the rights described above, please contact us using the contact details in Who We Are and How to Contact Us.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that if you are in the EU the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing Communications Preferences
You can ask us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:
- by following the opt-out links on any marketing message sent to you; or
- through your account settings at https://codyshirk.com/;
- by contacting us at any time using the contact details in Who We Are and How to Contact Us.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to existing or pending hires, purchases or investments using the Services or consent to direct marketing communications.
What Personal Data we collect
Cody Shirk uses Personal Data we collect to provide the Services, personalize content, remember information to help you efficiently access your account, analyze how the Services are used, diagnose service or technical problems, maintain security, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track user content and users as necessary to comply with the Digital Millennium Copyright Act and other applicable laws.
Information You Directly Provide to Us. There are many occasions when you provide information that may enable us to identify you personally (“Personal Data”) while using the Services. The Personal Data we may collect from you is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, picture, social security number and/or tax identification number, password, copies of ID cards or other forms of identification.|
|Contact Data||Your home address, work address, billing address, email address and telephone numbers.|
|Content Data||Any content you post to the Services not already included in another category, including without limitation, your profiles, questions, preference settings, answers, messages, comments, and other contributions on the Services, and metadata about them (such as when you posted them) ( “Content”).|
|Behavioral Data||Inferred or assumed information relating to your behavior and interests, based on your online activity. This is most often collated and grouped into “segments.”|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
No Special Categories of Personal Data. We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How We Use Your Personal Data and Why
We generally use Personal Data for the following: to deliver and improve our Services; to manage your account and provide you with customer support; to perform research and analysis about your use of the Services; to develop, display, and track Content; to diagnose or fix technology problems; to automatically update the Services on your device; to verify your identify and prevent fraud or other unauthorized or illegal activity; to enforce or exercise any rights in our Terms of Service;
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a legal basis for that use if you are within the EU. The legal bases depend on the Services you use and how you use them. This means we collect and use your Personal Data only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; or
- We need to process your data to comply with a legal or regulatory obligation.
We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we do rely on your consent to a use of your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place). We have set out below, in a table format, more detailed examples of relevant purposes for which we may use your Personal Data.
|Purpose||Why do we do this|
|Providing, updating, and maintaining our Services, Site and business||To deliver the Services you have requested, including, for example, registering you as a user, managing your account and profile, and authenticating you when you log in.For our investment related services, this also includes, for example, establishing your eligibility to invest on the Site under applicable laws, third-party contractual obligations and internal policies, surfacing suitable investment products for you on the Site, and providing tax and other investment related reporting for investors.|
|Research and development||To enable us to improve the Services and better understand our users and the markets in which we operate. For example, we may conduct or facilitate research and use learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, areas for additional features and improvement of the Services and other insights. We also test and analyze certain new features with some users before introducing the feature to all users.|
|Communicating with users about the Services||To send communications via email or third party messaging applications and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages. We may also provide tailored communications based on your activity and interactions with us. For example, we may provide you with updates regarding hiring and recruiting related matters, notify you of investment opportunities, and providing information regarding your investments through the Site. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.|
|Providing customer support||To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.|
|Enhancing security||To keep our website, our Services and associated systems operational and secure, including, for example, verifying accounts and activity, monitoring and investigating suspicious or fraudulent activity and to identify violations of our terms and policies.|
|To comply with applicable law, legal process and regulations and protect legitimate business interests||As we believe is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with with the acquisition, merger or sale of securities or a business (e.g. due diligence).|
What happens when you do not provide necessary Personal Data? Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Services). In this case, we may have to stop you using our Services.
What are cookies? When you visit the Services, we may send one or more “cookies” – small data files – to your computer to uniquely identify your browser and let Cody Shirk help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.
What cookies do we use? Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use a number of different tools including Google Analytics, Segment, Amplitude, Intercom, and Fullstory for this purpose.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site to help track conversions from ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—users who have already taken certain action on the Site.|
How can I disable cookies? You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Services.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Log Files: Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
Clear GIFs Information (Web Beacons): When you use the Services, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your Cody Shirk account is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make Cody Shirk better for our users.
Third Party Services: Cody Shirk may use third-party services such as Google Analytics, Segment, Fullstory or Amplitude to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You can also prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
CalOPPA Disclosures: We do not currently respond to web browsers’ “do not track” signals that provide a method to opt out of the collection information about users’ activities on the Services and on other websites. If we do so in the future, we will provide relevant information in this Privacy & Cookies Policy.
Who We Share Your Personal Data With
We may share your Personal with third parties in the ways that are described in the table below. We consider this information to be a vital part of our relationship with you.
|Recipients||Why we share it|
|Our Affiliates||Our affiliates may access your Personal Data to help us develop, maintain and provide our Services and help manage our customer relationships (including providing customer support, customer liaison, fund advisory services, etc).|
|Service Providers||Our service providers provide us support for our Services, including, for example, website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use Personal Data about you.|
|Professional Advisers||Our lawyers, accountants, bankers, auditors and insurers may need to review your personal data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services.|
|Researchers||To enhance the public understanding of patterns and trends in the markets served by or Services, we may provide Personal Data to third parties under confidentiality obligations such as, for example, academics or contractors for research purposes.|
As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.
We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.
If you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).
How long we store your Personal Data
We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your Personal Data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
Where We Store Your Personal Data
The Services are maintained in the United States of America. Personal Data that you provide us may be stored, processed and accessed by us, our staff, sub-contractors and third parties with whom we share Personal Data in the United States of America or elsewhere inside or outside of the EU for the purposes described in this policy. We may also store Personal Data in locations outside the direct control of Cody Shirk (for instance, on servers or databases co-located with hosting providers). Although we welcome users from all over the world, by accessing the Services and providing us with your Personal Data, you consent to and authorize the export of Personal Data to the United States and its storage and use as specified in this Privacy & Cookies Policy. Note the laws of the United States might not be as comprehensive or protective as laws in the country where you live.
How We Protect Your Personal Data
Cody Shirk uses industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to Cody Shirk or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, Cody Shirk will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy & Cookies Policy, or as otherwise required by applicable law.
Cody Shirk cannot ensure that your Personally Data will be protected, controlled or otherwise managed pursuant to this Privacy & Cookies Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.
Our Policy on Children’s Privacy
Protecting the privacy of young children is especially important. The Services are not intended for children below 16 and Cody Shirk does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register with the Services. If you are under the age of 16, please do not submit any personal information through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy & Cookies Policy by instructing their children never to provide personal information on this Site. If we become aware that we have collected personal information from a child under age 16, we will take steps to remove that information.
Links to Other Websites
This Privacy & Cookies Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Cody Shirk. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy & Cookies Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our Site, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.
Changes to Our Privacy & Cookies Policy
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy & Cookies Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy & Cookies Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy & Cookies Policy means you consent to such changes.