Privacy Policy - Catchlight AI

Last updated: April 5, 2023

This Privacy Policy explains how we collect, use and disclose personal information and other information about you in connection with your use of https://catchlight.ai (this “Website”) and Catchlight^SM and any other applications, products and services (collectively, “Services”) that may be available to you on this Website. This Website and the Services are intended for use only for business purposes by persons located in the United States. They are not intended to be used by persons that are not located in the United States or for personal, family or household purposes.

This Privacy Policy applies only to this Website and the Services. If you use other websites and/or other products or services offered by us or any of our affiliated entities, please review the applicable privacy policy (or policies) associated with those websites, products and service.

This Website contains links to third party websites, such as a link to the website of a third party that you or your firm may use to remit payments to us for you or your firm’s use of the Service. Please note that these third-party websites are not subject to this privacy policy. We are not affiliated with, nor do we control, any of these third parties. Your use of any such third-party website, and such website’s collection, processing or use of your personal information, is subject to the privacy policy and other terms and conditions associated with such website. Please review the privacy policy and other terms and conditions associated with such website for information about the third party’s privacy practices. We are not responsible for any aspect of any such other website, including, without limitation, its privacy practices, your account on such service or the content of such website.

Who we are

This Website and the Services are made available to you by Catchlight Insights LLC (referred to in this Privacy Policy as “Catchlight”, “we” and “us”), a wholly owned subsidiary of FMR LLC, the parent company of Fidelity Investments. In this Privacy Policy, FMR LLC and all other subsidiaries and affiliates of FMR LLC are referred to as “Affiliated Companies”.

How and why we obtain information

We and our service providers may collect personal information and other information about you when you use this Website or any of the Services, and when you interact with us or our service providers regarding this Website or any of the Services. Personal Information means personally identifiable information such as your name, postal and email addresses, and telephone, fax and mobile numbers. Please note that information by which an individual cannot be identiﬁed (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.

We or our service providers may collect certain information from any of the following sources, and the information we or they receive from a particular source may be linked or combined with information from other sources:

You, on applications or forms or in your user profile associated with this Website or any of the Services (for example, name and business contact information)
You, from your interactions (whether via online or other means) with us or our service providers (for example, communications with customer service staff, or information you enter into this Website or when using any of the Services)
You, regarding your preferences (for example, managing your communication preferences or for any customizable features of this Website or any of the Services)
Through the software (e.g. web browsers) and devices that you use to access this Website or any of the Services or other electronic communications from us (for example, device type, browser type, internet protocol address, pages visited on this Website, and time spent on this Website or using the Services)
Affiliated Companies
Third parties that perform services for us or on our behalf
Publicly available sources
Other sources with your consent

We may use the information we or our service providers collect:

to allow you to use this Website and the Services, and to facilitate and personalize your interactions and experiences with us
to service, maintain, and protect your user account associated with this Website or any of the Services, including verifying your identity
to respond to inquiries from you and fulfill requests from you
to market and communicate to you and your firm
to provide and improve this Website and the Services, and develop, offer and deliver other products and services
for our and other Affiliated Companies’ respective business purposes, such as reporting, planning and analytical purposes, and training and quality control purposes
to detect and prevent fraudulent, malicious or illegal activity, for risk control and mitigation purposes, and to fulfill legal, judicial, contractual and regulatory requirements
in connection with corporate business transactions, such as a merger, joint venture, corporate reorganization or sale of a business
to enable integrations with third party products and platforms that you elect to use

How we protect information about you

We employ physical, electronic and procedural controls to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology. We use firewall barriers, encryption techniques and authentication procedures, among other controls, to maintain the security of your online session with this Website, protect our systems and guard against unauthorized access to your account associated with this Website.

How we share information about you with our affiliates

We may share information about you, including personal information, with various Affiliated Companies that are providing services to us, such as administrative, business and data processing services. In addition, we may share information about you with Affiliated Companies for use in their businesses, including developing, marketing, offering and delivering their products and services.

How we share information about you with third parties

We do not share information we collect about you with unaffiliated third parties for their use in marketing their products and services. We may share certain information with the following entities:

Unaffiliated service providers and other third parties with which we or our Affiliated Companies have a business relationship;
Government agencies, other regulatory bodies and law enforcement officials;
Other organizations conducting research or performing academic or similar activities;
Other third parties, as directed by you;
Other organizations as permitted or required by law (for example, for fraud prevention or to respond to a subpoena); and
The investment firm(s) you are affiliated with.

Our unaffiliated service providers are obligated to keep the personal information we share with them confidential and use it only to provide the services specified by us.

Our Website and Services may have links to third party sites. If you choose to use or indicate your interest in using a product, service or investment offering that is offered by a third party and made available through Catchlight, we may share personal information with that third party in connection with your use or interest of that product, service or investment offering.

Cookies and similar technologies

Catchlight and our third-party service providers may use cookies and similar technologies (“cookies”) to support the operation of and maintain our digital oﬀerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital oﬀerings, including date and time of visits, pages viewed, amount of time spent using our digital oﬀerings, or general information about the device used to access our digital oﬀerings. Catchlight cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Both Catchlight and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices oﬀer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.

We may also use cookies in our emails. Depending upon the email client/service that you use, you may have the option to prevent the automatic downloading of images which would suppress these cookies until images are downloaded.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google's privacy policy. You can also view Google’s currently available opt-out options.

Advertising on Non-Catchlight Digital Offerings

Catchlight also advertises our products and services on digital oﬀerings not aﬃliated with us and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Catchlight and these third-party online advertising companies may use the data collected, along with other information we have about you and your Catchlight relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Catchlight and non-Catchlight websites. These advertisements are known as "interest-based advertisements".

You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by Catchlight, by clicking on the AdChoices icon and following the opt-out instructions.

If you generally want to “opt out” of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in a self-regulatory programs like the Digital Advertising Alliance DAA program or the Network Advertising Initiative (NAI), please follow the instructions at WebChoices: Digital Advertising Alliance's Consumer Choice Tool for Web US (aboutads.info) and NAI Consumer Opt Out (networkadvertising.org) to place an “opt-out” cookie on your device indicating that you do not want to receive interest-based advertisements. If you want to “opt out” of receiving online interest-based advertisements on mobile devices, please follow the instructions at YourAdChoices.com | AppChoices and Mobile Opt Out - NAI: Network Advertising Initiative (thenai.org).

Connecting with Catchlight on social media platforms

Catchlight provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Children's privacy

Catchlight’s Websites and Services are not directed to individuals under the age of thirteen (13). We do not intentionally collect information on our websites and services from those we know are under 13, and we request that these individuals do not provide personal information through our digital offerings. If we do provide a Website or Service that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.

Updates

We may change this Privacy Policy at any time, and without notice to you, by posting an updated Privacy Policy on this Website or otherwise providing you with a copy of the updated Privacy Policy. When we make changes to this Privacy Policy, we will change the “Last Updated” date specified at the beginning of this Privacy Policy. All changes shall be effective from the date the updated Privacy Policy is published, unless otherwise specifically stated in the updated Privacy Policy. We encourage you to review this Privacy Policy on a regular basis so that you will be aware of any changes to it.

Additional information

If you have questions or concerns about this Privacy Policy, please contact us at hello@catchlight.ai.

1054778.1.0