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    Privacy Policy

     
    PRIVACY NOTICE
     

    Last modified: March 31, 2022

     

    Introduction

    Castro Financials LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

    This policy describes the types of information we may collect from you or that you may provide when you visit the website welendllc.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

    This policy applies to information we collect:

    • On this Website.
    • In email, text, and other electronic messages between you and this Website.
    • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

    It does not apply to information collected by:

    • Us offline or through any other means, including on any other website operated by Company or any third party; or
    • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

    Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

    Information We Collect About You and How We Collect It

    We collect several types of information from and about users of our Website, including information:

    • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“personal information”);
    • That is about you but individually does not identify you; and/or
    • About your internet connection, the equipment you use to access our Website, and usage details.

    We collect this information:

    • Directly from you when you provide it to us.
    • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
    • From third parties, for example, our business partners.

    Information You Provide to Us.

    The information we collect on or through our Website may include:

    • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website.
    • Records and copies of your correspondence (including email addresses), if you contact us.
    • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
    • Your search queries on the Website.

    Information We Collect Through Automatic Data Collection Technologies.

    As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

    • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
    • Information about your computer and internet connection, including your IP address, operating system, and browser type.

    The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

    • Estimate our audience size and usage patterns.
    • Store information about your preferences, allowing us to customize our Website according to your individual interests.
    • Speed up your searches.
    • Recognize you when you return to our Website.

    The technologies we use for this automatic data collection may include:

    • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

    How We Use Your Information

    We use information that we collect about you or that you provide to us, including any personal information:

    • To present our Website and its contents to you.
    • To provide you with information, products, or services that you request from us.
    • To fulfill any other purpose for which you provide it.
    • To provide you with notices about your account, including expiration and renewal notices.
    • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
    • To notify you about changes to our Website or any products or services we offer or provide though it.
    • To allow you to participate in interactive features on our Website.
    • To respond to your inquiries and offer support to you.
    • To send administrative information to you.
    • To request feedback.
    • To protect our services.
    • To identify usage trends and effectiveness of marketing and promotional campaigns.
    • In any other way we may describe when you provide the information.
    • For any other purpose with your consent.

    We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

    Disclosure of Your Information

    We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

    • To our subsidiaries and affiliates.
    • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
    • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Castro Financials LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Castro Financials LLC about our Website users is among the assets transferred.
    • To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
    • To fulfill the purpose for which you provide it.
    • For any other purpose disclosed by us when you provide the information.
    • With your consent.

    We may also disclose your personal information:

    • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
    • and other agreements, including for billing and collection purposes.
    • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Castro Financials LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

    Choices About How We Use and Disclose Your Information

    We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

    • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
    • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to info@castrofinancials.com.
    • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to info@castrofinancials.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
    • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to info@castrofinancials.com.

    We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

    California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

    Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@castrofinancials.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

    Accessing and Correcting Your Information

    You can review and change your personal information by logging into the Website and visiting your account profile page.

    You may also send us an email at info@castrofinancials.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

    California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

    Your California Privacy Rights

    If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

    Information We Collect

    Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

    • Publicly available information from government records.
    • Deidentified or aggregated consumer information.

    In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:

    Category

    Examples

    Collected

    A. Identifiers.

    A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

    YES

    B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

    A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

    Some personal information included in this category may overlap with other categories.

    YES

    C. Protected classification characteristics under California or federal law.

    Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

     

    YES

    D. Commercial information.

    Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    YES

    E. Biometric information.

    Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    NO

    F. Internet or other similar network activity.

    Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

    YES

    G. Geolocation data.

    Physical location or movements.

    YES

    H. Sensory data.

    Audio, electronic, visual, thermal, olfactory, or similar information.

    YES

    I. Professional or employment-related information.

    Current or past job history or performance evaluations.

    YES

    J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

    Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

    YES

    K. Inferences drawn from other personal information.

    Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    YES

     

    Our Website obtains the categories of personal information listed above from the following categories of sources:

    • Directly from you. For example, from forms you complete or products and services you purchase.
    • Indirectly from you. For example, from observing your actions on our Website.

    Use of Personal Information

    We may use, or disclose the personal information we collect for one or more of the following purposes:

    • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
    • To provide, support, personalize, and develop our Website, products, and services.
    • To create, maintain, customize, and secure your account with us.
    • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
    • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
    • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
    • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
    • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
    • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

    We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

    Sharing Personal Information

    We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

    Your Rights and Choices

    The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

    Right to Know and Data Portability

    You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
    • The specific pieces of personal information we collected about you (also called a data portability request).

    Right to Delete

    You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

    Exercising Your Rights to Know or Delete

    To exercise your rights to know or delete described above, please submit a request by emailing us at info@castrofinancials.com

    Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

    You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include information which you have previously provided to us.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

    You do not need to create an account with us to submit a request to know or delete.

    We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

    Response Timing and Format

    We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at info@castrofinancials.com.

    We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

    If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

    Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    Non-Discrimination

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

    California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@castrofinancials.com or write us at: 8810 136th Street, Queens, New York 11418.

    Changes to Our Privacy Policy

    It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

    Contact Information

    To ask questions or comment about this privacy policy and our privacy practices, contact us at:

    8810 136th Street

    Queens, NY 11418

    info@castrofinancials.com