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Privacy Policy

We, mutually.com and our corporate affiliates (“mutually.com”, “we” or “us“), are committed to protecting and respecting your privacy. We believe in transparency, and we are committed to being upfront about our privacy practices. This Privacy Policy (“Policy“) explains which information we collect from you, when you (“you” or “your”, the user of our Services) access and use our websites (the “Site“), as well as our platforms, widgets, analytics tools, and other technical applications that we may provide either through our Sites or through third-party websites  or other products and services provided by us (which, together, are referred to as the “Services“), will be processed by us, and how we use such information and protect it. The Policy also wishes to make sure that you are aware of the options available to you when you access and use our Services.

This Policy is a part of our Terms of Use found on our website. By using the Services, you consent to our collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this policy. This includes any information you choose to provide that is deemed sensitive under applicable law. This Policy only applies to mutually.com’s Services. We are not responsible for the content or the privacy policies of any third-party websites or apps.

Contact Details  

If you have any questions or concerns about mutually.com’s Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at:

mutually.com

Email address: [email protected]

Export of Data

By using the Services, you authorize mutually.com to transfer and use your information in USA and any other country where mutually.com operates. Please be aware that the privacy laws and standards in certain countries may differ from those applying in the country in which you reside. We will take steps to ensure that your information continues to enjoy appropriate protections.

The information we collect from your use of the Services and how we obtain it

When you use or interact with our Services, we automatically collect certain information, such as: (a) anonymous encrypted code representing your Internet protocol (IP) address or your device identifier (if using a mobile device) and being used as a persistent identifier, your browser type and version, time zone setting, browser plug-in types and versions, operating system and version, device information; as well as (b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, the frequency and scope of your use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content you viewed (including advertisements you clicked on) and pages you visited, and cookie data.

As such, the information we collect cannot be used to specifically identify you. Our Services do not collect any personal information, i.e. information about a natural person such as name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual.

Tracking Methods. When you engage with advertisements that are displayed on the Services, mutually.com, third party advertisers and data service providers may use industry-wide tracking methods (e.g., cookies, web beacons, etc.) which store certain information (“Methods”) and which allow us or such third parties to collect certain data for the purpose of serving advertisements through the use of the mutually.com Services (including without limitation, serving advertisements that may be of interest to you). The Methods may store non-personal information as well as a persistent identifier. In such case, you will be subject to such third party advertisers’ privacy policy.

Information collected by Cookies and similar technologies – A cookie is a small text file that is stored on a user’s device for record keeping purposes. Cookies can only be read by the server that sent them, and they cannot read data from the hard drive. We or our service providers may use cookies, web beacons and similar technologies to collect and store certain information, such as your registration information, language preferences and other account settings. On our Services, we use cookies from the entities that adhere to the Self-Regulatory Principles for Online Advertising of the Digital Advertising Alliance and that are listed under http://optout.aboutads.info/?c=2#!/

We may also use these technologies to recognize your browser type as you navigate on the Internet and to collect aggregate and statistic information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site, all attributed to the persistent identifier in a manner that does not permit direct or indirect identification of you as a specific individual. This allows us to better serve you with more tailored information and facilitate your ongoing access to and use of the Services.

Any data that we store in such cookies are encrypted for security purposes. We may allow our authorized service providers to access the information collected by cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising.

To learn more about cookies, please visit http://www.allaboutcookies.org/. You may delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services properly.

Collaboration with Google and other Third-party Ad Networks.

We may collaborate with Google or other third party vendors or advertising networks as business partners. Google uses cookies to help serve the ads it displays on the websites of its partners, such as websites displaying Google ads or participating in Google certified ad networks. When users visit a Google partner’s website, a cookie may be dropped on that end user’s browser.

  • Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to our website or other websites.
  • Google’s use of advertising cookies enables it and its partners to serve ads to you based on you visit to our sites and/or other sites on the Internet.
  • You may opt out of personalized advertising by visiting Ads Settings. Alternatively, you can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting info.

Please be advised that the cookies of other third-party vendors or ad networks may also be used to serve ads on our website, and therefore, please be informed as follows:

  • You may visit the foregoing websites to opt out of the use of cookies for interest-based advertising (if the vendor or ad network offers this capability). Alternatively, you can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting info.

Information collected by third parties. We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our website does not provide personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. [Some of these third party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers end users a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

How we use the information we collect and store

We respect your privacy. As explained above, mutually.com does not collect any personal data or information that can identify you. We generally use the information that we collect and process to provide and improve our services and products, for targeted online and offline marketing, and for general research and aggregate reporting.

We use information in the following ways:

Information we collect.

    • We use the information to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.
    • The information helps us measure and research the effectiveness of the Services’ features and offerings, advertisements, and e-mail communications, and to improve them when necessary.
    • We may also use it to make suggestions and recommendations to you and other users of our site about services that may interest you or them.
  1. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
  2. Storage of Information. In addition, please be aware that we may host or store your data and information (including personally identifiable information) in the United States and other countries through certain third parties that we use to operate and manage the Site and Services, including, inter alia, Amazon Web Services (“AWS”). By using the Site, you acknowledge and expressly consent to the transfer and processing of your personally identifiable information in this way. We may store your information also after your membership has been terminated. Such information may be used for any internal purpose, such as quality control efforts or customer analysis.
  3. Respond and handle your questions and requests. – no storage of any contact information.

DISCLOSURE OF YOUR INFORMATION

We only share information with third parties in the following instances:

  1. When we received your consent. This includes sharing information with other service providers.
  2. With our affiliates. This relates to companies that are legally part of the same group of companies that we are part of, or that become part of that group.
  3. Third-Party Service Providers. We may make use of third party service providers in the course of collecting, storing and/or processing information. We use commercially reasonable efforts to engage with third-party service providers that post a privacy policy governing their collection, processing and use of non-personal and personal information. Please note, however, that we do not control such third party service providers.
  4. Non-Personally Identifiable Information. We may also share non-personally identifiable information that we collect under any of the above circumstances with our business partners, affiliates or other third parties to develop and deliver targeted advertising on our websites and on websites of third parties. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customize content and advertising.

We may disclose information to third parties:

  1. If mutually.com or substantially all of its assets are acquired by a third party.
  2. We may disclose information (i) as a response to a legal request (such as a court order, search warrant, or subpoena) if we believe that we are required to do so by applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud, intellectual property infringement, piracy, or other illegal activities; enforce this Policy or our Terms of Use, including in order to investigate potential breaches; protect our rights, property or safety, or those of our users or from members of the public from harm, as required or permitted by law; and prevent death or imminent bodily harm. In such events, mutually.com may disclose a name, address, country, phone number, email address and company name.
  3. mutually.com is affiliated with a variety of businesses and works closely with them. These businesses may offer promotions (including e-mail promotions) or sell items or services to you through our Services. When an affiliated business is associated with your transaction, we may share information related to the transaction with that affiliated business to facilitate your transaction.

DATA RETENTION

We retain aggregated or anonymous data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary.

What are my California privacy rights?

California’s “Shine the Light” law permits residents of California to request certain details about what personal information (as that term is defined in California Civil Code § 1798.83) a company shares with third parties for the third parties’ direct marketing purposes. Upon receipt of this notification, we will discontinue sharing your information for third party direct marketing purposes as soon as practicable.

The California Consumer Privacy Act, effective January 1, 2020, provides California “Consumers” with certain rights, as explained in our California Consumer Privacy Act Notice (“CCPA Notice”) below. Please review our CCPA Notice below for more information.

This CCPA Notice applies to “Personal Information” (also referred to herein as PI) of “Consumers” as defined by the California Consumer Privacy Act (“CCPA”).

We collect and share the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below.

Category of Personal Information Sources of Personal Information Purposes for Collection Categories of Third Parties with whom Personal Information is shared Purposes of Third Parties Receiving PI
1. Identifiers and Personal Records (e.g., email address, name, address, IP address, credit card number) Directly from you; your devices; Vendors Performing Services; Processing and managing interactions and transactions; Quality Assurance; security; debugging; marketing Vendors which assist us in providing services and running our internal business operations (“Vendors”); Data Analytics Partners Performing Services on our behalf; Processing and managing interactions and transactions; performing services; Quality Assurance; security; debugging
2. Customer Account Details / Commercial Information (e.g., details of your use of our service) Directly from you; your devices Performing Services; Research and development; quality assurance; security; debugging; and marketing Data Analytics Partners; Vendors Performing Services on our behalf; research and development; quality assurance; security; and debugging
3. Internet Usage Information (e.g., information regarding your interaction with our services) You; your devices; Data Analytics Partners; Vendors Research and development; quality assurance; security; and debugging Data Analytics Partners; Vendors Performing Services on our behalf; Research and development; quality assurance; security; and debugging
4. Geolocation Data Your devices; Vendors Performing Services; Processing and managing interactions and transactions; Quality Assurance; security; debugging; marketing Vendors Performing Services on our behalf; Processing and managing interactions and transactions; performing services; Quality Assurance; security; debugging
5. Inferences (e.g., your preferences, likelihood of interest in certain of our services) Data Analytics Partners; Vendors; Advertising Networks Research and development; quality assurance; and marketing Data Analytics Partners; Vendors; Advertising Networks Performing Services on our behalf; research and development; quality assurance; marketing

In addition, we may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your PI as defined by the CCPA. You can exercise control over browser-based cookies by adjusting the settings on your browser. We do not represent that these third-party tools, programs or statements are complete or accurate.

Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.

California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

To make a request according to your rights to know or to request deletion of your PI set forth below, please email us at [email protected]. For your specific pieces of information, if required by the CCPA, we will apply heightened verification standards, which may include a request to provide further information.

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting or selling your PI.
  • The categories of third parties to whom we have shared your PI.
  • The specific pieces of PI we have collected about you.
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
    • The categories of your PI we have sold.
    • The categories of third parties to which we sold PI, by categories of PI sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.

You may alternatively exercise more limited control of your PI by instead exercising one of the following more limited opt-outs, including unsubscribing from email newsletters by sending an email to [email protected].

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

Disclosure for Law Enforcement

Under certain circumstances, mutually.com may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

mutually.com may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of mutually.com
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. mutually.com aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where mutually.com relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

HOW DO WE SECURE YOUR INFORMATION?

We consider data security a top priority and we do our best to keep your information secure. For that purpose, we:

  1. Encrypt many of our services using SSL.
  2. Employ firewalls and intrusion detection systems.
  3. Practice administrative, technical, and physical security procedures to help protect the information you provide us.

Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your information, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to their standard terms and conditions that are generally non-negotiable; and accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

PROTECTION OF CHILDREN’S PRIVACY

Our Services are not directed to children under 18.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. Your continued use of our Services following the posting of changes to this Policy or providing notice to you, whichever occurs first, means that you accept those changes.

GENERAL

We reserve the right to discontinue or modify any aspect of the Services at any time. This Policy, together with our Terms of Use and any other legal notices published by us on the Site and in the Platform, shall constitute the entire agreement between us concerning the Services. If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

GOVERNING LAW AND JURISDICTION

This Policy shall be governed by the laws of Panama, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the federal and state courts located in Panama, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.

Our Services are controlled and operated from Panama, and we make no representations that they are appropriate or available for use in other locations.

NOTE TO INTERNATIONAL USERS

We are a private company incorporated under the laws of Israel. If you are located elsewhere, the information you provide to us or that we collect will be transferred to the USA and governed by applicable laws and regulations and this Privacy Policy. Some of this information may be transferred to, processed and stored by our service providers in other countries.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.