This page presents the Cinco Privacy Policy and describes how Lavenant LLC, d/b/a Cinco (“we” or “us”) use and protect personal information you provide to us when you use our Platform (the Cinco mobile app and the Cinco website, www.thecincoapp.com). This Privacy Policy does not apply to personal information you may provide to other users of the Platform or to third parties.

 

1. HOW WE PROTECT YOUR PRIVACY

We use a combination of physical, electronic and procedural safeguards to help prevent unauthorized access to personal information that is under our control and to protect it from loss, misuse, alteration or destruction. For example, we limit access to your personal information to our employees and other authorized parties who we believe reasonably need to come into contact with that information to provide the Platform and its products or services to you or in order to do their jobs.

The information you provide to us online is protected by encryption technology to prevent unauthorized parties from viewing any confidential information transmitted to or from the Platform during your session. This technology scrambles your information as it moves between your device and the Platform and helps protect the safety and confidentiality of your personal information when you use the Platform. We also use other technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to your data.

 

2. CHOICES

You have the choice to allow, prohibit or modify certain information that we may collect. You may do this by editing your account settings on your device if using the mobile app or on your computer if using the website, by disabling cookies (described below) or by opting out or unsubscribing to specific Platform offerings. However, the Platform or its features may no longer function properly if you do so.

 

3. WHAT INFORMATION WE COLLECT

In the course of using the Platform, we collect information about you, such as:

• Information you provide to us, such as your name, gender, date of birth, location, addresses, phone numbers, email addresses, payment information, passwords, user groups, user contacts, user events, user photographs, and other information we need to perform the Platform services and products for which you have registered
• Information or photographs that may be posted by other users, such as from your user groups
• Information we receive from third parties, such as banking partners that may provide the status of payments you made to use the Platform and its services and products
• Geolocation information, usage data, and anonymous data our servers/web browsers automatically collect such as your device ID, IP address, your browser type, your device type, operating system, and the timing and order in which our pages are accessed.

 

4. HOW WE USE INFORMATION

Information collected may be used for a number of purposes, such as:

• Operating, maintaining and improving the Platform
• Displaying information about you, such as your profile, and personalizing the Platform to your possible interests
• Communicating with you
• Advertising and keeping you informed about products and services that may be of interest to you
• Performing other business and legal activities as needed
• Compiling anonymous statistical data and analysis for use internally or with third parties.

 

5. WHY WE MAY DISCLOSE INFORMATION AND TO WHOM

We may share information we have collected about you to others, such as:

• Other users, such as in your selected user groups, and those third parties with whom you have requested us to share information
• Our third-party service providers who help us operate, maintain, improve and track the Platform and its services and products
• Companies involved in completing your transactions, such as payment processors and financial institutions
• Fraud or identity screening services such as credit bureaus or other service providers to protect you and us against fraud
• Analytics and advertising partners, subject to applicable law
• Governmental agencies or authorities as required by law
• Third parties as required by law (in response to subpoenas or other legal processes)
• And we may disclose non-personally identifiable use data to companies that use and analyze anonymous statistical data.

 

6. HOW WE USE TRACKING TECHNOLOGY

We may place cookies, pixel tags and similar files on your hard drive or mobile device for security purposes, to facilitate Platform navigation, to facilitate your use of the Platform, and to personalize your experience on the Platform. A cookie is a small text file assigned by a Web server to the browser on your device that keeps track of your preferences and recognizes returning visitors. Cookies cannot be used to run programs or deliver viruses to your device. We uses cookies to store your preferences and other information on your device in order to save you time by eliminating the need to repeatedly enter the same information. When you sign in using your user name and password, the Platform’s Web server stores your unique identification, and the time you signed in, in an encrypted cookie on your hard disk or device. This cookie allows you to move from page to page on the Platform without having to sign in again on each page. When you sign out, these cookies are deleted from your computer or device. As a matter of security, we do not embed your account number(s) or passwords in our cookies.

 

7. PLATFORM ANALYTICS / ADVERTISING PARTNERS

We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Platform through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Platform and its services and products, determine the popularity of certain content and better understand online activity, and serve advertisements. By accessing the Platform, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative or Digital Advertising Alliance Opt-Out Tool.

We do not provide any personal information to an advertiser when you interact with or view a customized advertisement.
However, when you view or interact with an advertisement, the possibility exists that the advertiser will make the assumption that you are interested in the subject matter of the advertisements.

You should be aware that getting a new device, computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

 

8. OTHER USERS AND THIRD-PARTY WEBSITES

This Privacy Policy does not apply to information you provide to other users or user groups on the Platform. This Privacy Policy also does not apply to third party websites. The Platform may contain links to third-party websites and applications of interest, including advertisements and external services, which are not affiliated with us. Once you have used these links, any information you provide to the third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for how other users or user groups use any information you provide to them, and we are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Platform.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can
activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.
No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to btracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

 

10. HOW WE PROTECT INFORMATION OF FORMER USERS

All personal information of a user will be deleted if a user deletes their account.

 

11. CALIFORNIA USERS

If you are a California resident, under the California Consumer Privacy Act (“CCPA”), as may be amended from time to time, you may request up to two times in any twelve month period (1) that we disclose how we collect and use Personal Information as it relates to you, the categories of Personal Information we collect, the categories of sources we collect it from, and the categories of any third parties to whom we sell or disclose the Personal Information, (2) the specific pieces of Personal Information we collected about you during the prior 12 months, (3) to have such Personal Information corrected or deleted (with some exceptions), and (4) that your Personal Information not be sold or disclosed to third parties (although not disclosing it through the Platform to our third-party providers means you may not be able to use portions of the Platform). We agree that we will not discriminate against you if you exercise any of these rights. Your request must be identified as a “Personal Information Request” and be directed to hello@thecincoapp.com or call the phone number listed on the Platform. We will need to collect information from you in order to verify your identity, and then we will respond within 45 days of receiving your Personal Information Request. However, we cannot respond to your request or provide you with Personal Information if we cannot verify your identity and authority to make the request, and confirm that the Personal Information relates to you. Under the CCPA, as amended, Personal Information includes the personally identifying information identified in “What Information We Collect” above, as well as the following categories of information, some of which the law may deem to be “Sensitive Personal Information”, to the extent any is collected, (i) identifiers (such as cookie information), (ii) information protected against security breaches (such as name, driver’s license, social security number, user name and password); (iii) protected classification information (like race, gender, ethnicity), (iv) commercial information, (v) Internet/electronic activity, (vi) geolocation, (vii) audio/video data, (viii) professional or employment related information, (ix) education information, (x) biometrics, and (xi) inferences from the foregoing. We understand that California privacy regulations are amended from time to time, so we commit to comply with the most current privacy regulations that are applicable at the time you make a request pursuant to this paragraph.

 

12. CHANGES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy to reflect changes to the Platform and its services and products. If we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this statement. If there are material changes to this statement or in how we will use your information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this statement to be informed of how we are protecting your information.

 

13. QUESTIONS

We welcome your comments. If you have any questions regarding this Privacy Policy or believe that we have not adhered to it, please contact us at hello@thecincoapp.com.

(Updated March 2023)