This Privacy Policy describes the types of information we may collect when you access or use our Platform (as defined in the P2P Global Terms of Use (the “Terms”)) or visit our website, mobile versions of, or any other online service, platform or application we provide (collectively, the “Services”). We may supply different or additional notices of our information practices specific to certain subdomains of the Services, programs or activities. We may also provide different notices of our information practices with respect to certain subsidiaries or affiliates, in which case this Privacy Policy will not apply.

We take your privacy seriously. Our policy is clear: we collect no personally identifiable information about you when you use the Services unless you provide that information to us. Unless we have your authorization or are required to do so by law or other extraordinary circumstances, we will not share with any third party the personally identifiable information that we obtain from you.

This Privacy Policy addresses the nature, purpose, use, and sharing of any information collected via the Services. The information you provide through the Services will be used only as outlined in this Privacy Policy. Except as outlined in this document, the submission and collection of personally identifiable information (defined below) is strictly voluntary. By using or visiting the Services, you acknowledge your agreement with this Privacy Policy and the applicable terms and conditions related to that site or application. If you do not want to grant permission to use your information as outlined in this Privacy Policy, please do not provide it, and please do not visit or use the Services. However, not providing certain information may result in our inability to provide you with the information or services you desire.

Information Collected
Certain information about your use of the Services is anonymous information that cannot be used to identify you. We use this information to track navigation through the Services, which pages are viewed most often, what other websites are visited, and similar data. We also use the information to develop and deliver marketing strategy, to notify you of ads and promotions, and to offer products and services to you.

Personally identifiable information is sensitive information that can be used to identify you. Personally identifiable information includes, among other information, your full name, e-mail address, physical mailing address, and telephone number. Some of the features on the Services may require that you provide us information about yourself, such as when you register for the Services, use the Services, or choose to fill out a form on the Services. You can review and update any personally identifiable information you have voluntarily elected to provide to us prior to submitting the information.

We will never request your password, user name, or other personally identifiable information through e-mail. This practice, called “phishing,” is oftentimes a scam designed to steal your personal information. If you receive an e-mail message that looks like it is from us asking for your personal information, please do not respond.

Use of Personally Identifiable Information You Choose to Provide
If you choose to provide us with personally identifiable information, we will use that information to enhance your experience in the following ways, as applicable:

– Complete your request to sign up to receive information via e-mail.
– Complete your request to register as a Member or User.
– Complete your request to register to use any of our online tools you select.

Providing us with your personally identifiable information allows us to:

– Communicate information to you.
– Comply with valid legal procedures, requirements, regulations, and statutes.
– Share your personally identifiable information with third party vendors but only to the extent required to help us provide the Services.

Automatically Collected Information
We save information based on your interaction with the Services. This information includes, but is not limited to, your Internet Protocol address (the address automatically assigned to your computer every time you establish a connection to the Internet), the name of any referring websites, as well as your navigation and activity within the Services. By tracking this type of information, we may be able to modify our content to enhance your experience while using the Services.

This information is only used to help us make the Services more useful to you. Except for authorized law enforcement investigations, no attempts are made to identify unknown individual users or their usage habits. Raw data logs are retained temporarily as required for security and site management purposes only.

When you visit the Services or open e-mails from us, we (or an authorized third party) may send you a cookie.

What are cookies?
Cookies are small text files located in your browser directory that may be placed on your device. When a website is accessed, a cookie that is placed on a device will send information to the party that has placed the cookie. Cookies are extremely common and used on a number of websites. Each cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value (usually a unique number).

The Services may place first party cookies and allow third parties to place cookies on your device. The difference between a first party cookie and a third party cookie relates to the control of the party who serves the cookie. First party cookies are cookies that are specific to the website that created them. We use first party cookies to provide you with a good experience and allow us to improve the Services. Third party cookies, on the other hand, are placed on your device by a third party (i.e., not by us). While we may allow third parties access to the Services to place these cookies on users’ devices, we do not retain control over the information supplied by the cookies, nor do we retain access to that data. This information is controlled wholly by that third party in accordance with its privacy policy.

The Services may place session and persistent cookies on your device. The difference between a session and a persistent cookie relates to the length of time the cookie lasts. Session cookies are cookies that only exist temporarily. When you end your browser session, the cookie expires. (A browser session starts when a user opens the browser window and finishes when the user closes the browser window.) Persistent cookies will last after you close your browser. This allows for quicker and often more convenient access to the Services.

What cookies do we use?
We use “essential cookies” to enable you to navigate the Services and to use its features.

We use “preference cookies” to collect information about your choices and preferences and to allow us to customize the Services accordingly.

We use “social media cookies” (such as Facebook’s third party cookies) to enable you to share pages and content you find interesting on the Services through third-party social networking and other websites. These cookies may also be used for advertising purposes.

We use “analytics cookies” (such as Google’s and Facebook’s first party cookies) to collect information about your use of the Services and to enable us to improve the way the Services works. Analytics cookies allow us to see the overall patterns of usage on the Services, rather than the usage of a single person.

We use “advertising cookies” (such as DoubleClick’s third party cookies) to display targeted promotions or advertisements based upon your interests on the Services or to manage our advertising.

How can you manage cookies?
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. (These settings are usually found in the “options” or “preferences” menu of your internet browser, and you should use the “Help” option in your internet browser for more details.) However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, the Services will issue cookies as soon as you visit them.

Like many websites, the Services do not currently respond to “do not track” settings or other mechanisms that consumers may utilize on their web browsing device to limit the collection of certain information about a consumer’s activities over time and across various websites or online services.

For information about how you can opt-out of Google Analytics Advertising Features, visit

If you have a Facebook account, visit to control how Facebook uses data to show you ads.

Similar Technologies
There are other technologies that perform a similar function to cookies. These include web beacons (a small .gif image) and clear gifs. We use web beacons and clear gifs in conjunction with cookies to help us understand our customers better. When we send you e-mails we use these technologies as follows so that we can track e-mail open and click rates. We also use web beacons to determine a user’s ability to receive HTML e-mail. Web beacons do not collect any personal data. Users that do not want to receive e-mail messages with web beacons can choose to receive their e-mails in text (non-HTML) format.

Sharing Information
We may share your personally identifiable information with other Members of the Services and their Users. This is necessary to provide you with the ability to utilize the Services.

We may share aggregated general information collected by the Services with our subsidiaries, affiliates, sister and parent corporations, and our third party service providers. Aggregated data does not contain any personally identifiable information that could be used to contact or identify you. We only share personally identifiable information in one or more of the following limited circumstances:

– We have your consent.
– We may provide such information to respected third party service providers to the extent necessary for them to assist and support us as we attempt to better provide enhanced products and services to you and to complete your requests to receive information from us via e-mail, use our online tools or register as a member on the Services.
– When required by law or where we have a good faith belief that such action is necessary to comply with a current judicial proceeding, a criminal investigation, a court order, or legal process served on us in direct relation to you. We may also share your personally identifiable information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the terms and conditions of the Services and services, or as otherwise required by law.
– If you have established an account with us, we may share the information submitted under your account among any or all of our subsidiaries, affiliates, sister or parent corporations, or our trusted third party service providers working on our behalf in order to provide you with a seamless experience and to improve the quality of our services.

We will not disclose your account information to other people or non-affiliated companies, except in limited circumstances described in this Privacy Policy or with your consent.

In the event that another company acquires all or substantially all of the assets related to our business, we reserve the right to include any or all stored personally identifiable information among the assets transferred to the acquiring company.

We may store and process personally identifiable information collected through the Services in the United States or any other country in which we maintain facilities. By using the Services, you consent to the transfer of your information among these facilities, including those located outside your country.

We currently do not share your personally identifiable information with any other companies or organizations that would present you with offers or promotions that are not directly related to us or our subsidiary, affiliate, sister, or parent companies.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of the data you provide to us. Our servers are protected by firewalls and are physically located in secure data facilities to further increase security. While no computer or facility is 100% safe from outside attacks, we believe that the steps we have taken to protect your personally identifiable information dramatically reduce the likelihood of security problems to a level appropriate for the type of data involved.

You may receive e-mail messages from us. If you no longer wish to receive these communications, let us know by following the opt-out directions on any of the e-mail messages you have received from us.

Privacy Policy Changes
As we continue to improve the services, products, and features we provide, this Privacy Policy is subject to change. This Privacy Policy is subject to change without direct notice to you. We may change our Privacy Policy at any time by posting a new version of it on the Services. Therefore you should review this Privacy Policy each time you visit any portion of the Services. The dates provided below will inform you as to when the most recent material updates to this Privacy Policy occurred and the date on which the updated Privacy Policy became effective.

Date of Last Update: June 10, 2019

Date Updated Policy Became Effective: June 10, 2019

California Privacy Rights
We do not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Any California residents under the age of eighteen (18) who have registered to use the Services and posted content or information on the Services can request that such information be removed from the Services by sending an e-mail to us at Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

Concerns About Privacy
If you have any questions or comments about this privacy policy, please contact us at

Data Processing Addendum

1. Definitions
(a) “Data Protection Legislation” means European Directives 95/46/EC and 2002/58/EC, and any legislation and/or regulation implementing or made pursuant to them, or which amends or replaces any of them (including the General Data Protection Regulation, Regulation (EU) 2016/679);

(b) “Data Processor”, “Data Subject”, “Processor”, “Processing”, “Subprocessor”, and “Supervisory Authority” shall have the meanings to them provided in the applicable Data Protection Legislation;

(c) “Personal Data” as used in this Addendum means information relating to an identifiable or identified Data Subject who accesses or uses the Platform, which we Process as a Data Processor in the course of providing you with the Platform; and

(d) All other capitalized terms in this Addendum shall have the same definition as in the P2P Global Terms of Use.

2. Data Protection
2.1. When we Process Personal Data in the course of providing the Platform, we will:

2.1.1. Process the Personal Data as a Data Processor, only for the purpose of providing the Platform in accordance with your use of the Platform, commensurate with the functionalities of the Platform. If we are required by law to Process the Personal Data for any other purpose, we will provide you with prior notice of this requirement, unless we are prohibited by law from providing such notice;

2.1.2. notify you promptly, to the extent permitted by law, upon receiving an inquiry or complaint from a Data Subject or Supervisory Authority relating to our Processing of the Personal Data;

2.1.3. implement and maintain appropriate technical and organizational measures to protect the Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration or disclosure. These measures shall be appropriate to the harm which might result from any unauthorized or unlawful processing, accidental loss, destruction, damage or theft of Personal Data and appropriate to the nature of the Personal Data which is to be protected;

2.1.4. provide you, upon request, with up-to-date attestations, reports or extracts thereof, where available, from a source charged with auditing our data protection practices (e.g. external auditors, internal audit, data protection auditors), or suitable certifications, to enable you to assess compliance with the terms of this Addendum;

2.1.5. notify you promptly upon becoming aware of and confirming any accidental, unauthorized, or unlawful processing of, disclosure of, or access to the Personal Data;

2.1.6. ensure that our personnel who access the Personal Data are subject to confidentiality obligations that restrict their ability to disclose the Personal Data; and

2.1.7 upon termination or expiration of the Terms, we will promptly initiate our purge process to delete or anonymize the Personal Data. If you request a copy of such Personal Data prior to termination or expiration, we will provide you with a copy of such Personal Data.

2.2 In the course of providing the Platform, you acknowledge and agree that we may use Subprocessors to Process the Personal Data. Our use of any specific Subprocessor to process the Personal Data will be in compliance with Data Protection Legislation and will be governed by a contract between us and Subprocessor.

3. Miscellaneous
3.1 In the event of any conflict or inconsistency between the provisions of the Terms and this Addendum, the provisions of this Addendum shall prevail. For avoidance of doubt and to the extent allowed by applicable law, any and all liability under this Addendum, including limitations thereof, will be governed by the relevant provisions of the Terms. You acknowledge and agree that we may amend this Addendum from time to time by posting the relevant amended and restated Addendum on our website, available at and such amendments to the Addendum are effective as of the date of posting. Your continued use of the Platform after the amended Addendum is posted to our website constitutes your agreement to, and acceptance of, the amended Addendum. If you do not agree to any changes to the Addendum, do not continue to access or use the Platform.

3.2 Except as specifically modified and amended in this Addendum, all of the terms, provisions and requirements contained in the Agreement shall remain in full force and effect and govern this Addendum. If any provision of the Addendum is held illegal or unenforceable in a judicial proceeding, such provision shall be severed and shall be inoperative, and the remainder of this Addendum shall remain operative and binding on the parties.