Privacy Policy

About Medallion and its Privacy Commitments

FirstLayerAI, Inc. DBA Medallion (“we,” “our” or “us”) is committed to protecting your personal information through our compliance with this Privacy Policy.

This Privacy Policy describes the type of information we may collect from you or that you may provide when you visit our website at www.medallion.co, or any subdomain of www.medallion.co, including any content or functionality offered on or through the foregoing (the “Site”), or when you access or use the services we make available on the Site (collectively, the “Service”), whether as a guest, a registered user, or a client of a registered user. This Privacy Policy also describes how we may use and share that information as well as your rights and choices about such collection, use and sharing.

This Privacy Policy applies to information we collect on the Site, in email, text, or other electronic messages between you and the Site, and through your access to or use of the Service through the Site. It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party, nor to information collected by any other third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site or Service.

Please read this Privacy 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 the Site and Service. By accessing or using the Site or Service, you agree to this Privacy Policy.

This Privacy Policy may change from time to time (see Changes to this Privacy Policy). Your continued use of the Site or Service after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. If you have any questions about our privacy practices, please contact us as set forth in the Contact Us section below.

Information We Collect

When you access the Site or Service, we collect certain information about you. This may include information:

• that may personally identify you, such as your name, postal address, e-mail address, personal identifier, and/or telephone number, as well as more sensitive information that may identify you, such as your Social Security number, driver's license number, passport number, signature, education, employment, employment history, and fingerprints;
• that are characteristics of a protected classification under California or federal law, such as race, color, sex/gender, marital status, military or veteran status, national origin, ancestry, or age;
• that is about you but individually may not specifically identify you, such as your employer/affiliated organization name; and/or
• about your internet connection (e.g., IP address), the equipment you use to access the Site or Service (e.g., device and software IDs), and usage details (collectively, "personal information").

Ways We Collect Information

We collect this information from various sources, such as directly from you when you access or use the Site or Service, from other users acting on your behalf, or automatically as you navigate through the Site or Service.

1. Information You Provide to Us

We collect certain information you provide directly to us on or through our Site or Service, such as:

• Information that you provide by filling in forms on the Site or through the Service, which includes information provided at the time of registering to use the Site, subscribing to the Service, posting material, or requesting further services.
• Information we request/you provide when you enter a contest or promotion sponsored by us
• Information we request/you provide when you report a problem with the Site or Service.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

2. Information Collected Automatically

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

• usage details, IP addresses, and information collected through cookies and other tracking technologies;
• details of your visits to Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site; and
• information about the type of device or browser you use, your device's operating software, your internet service provider, your device's regional and language settings, and other similar information.

While some information we collect automatically may only be statistical data and may not include personal information, we may maintain it or associate it with personal information we collect in other ways or receive from third parties as it helps us to improve the Site and to deliver a better and more personalized Service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Identify bugs and fix errors.
• Store information about your preferences, allowing us to customize the Site and Service according to your individual interests.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include cookies, web beacons, tracking pixels and other tracking technologies, as outlined in further detail below. For instance, we may use analytics software to better understand how users interact with the Site or Service. For example, we use Google Analytics, which is an independent web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can learn about Google's privacy practices at https://www.google.com/intl/en/policies/privacy.

You may opt out of the aggregation and analysis of data collected about you on the Site by Google Analytics by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/. Please note that if you opt out, analytics companies other than Google Analytics may continue to aggregate and analyze data collected about you on the Site.

Use of Your Information

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

• To present the Site and Service 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 operate, maintain and improve the Site and its contents.
• 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 Site or Service.
• 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 our goods and services that may be of interest to you. If you do not want us to use your information in this way, please let us know at privacy@medallion.co.

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.

For information on your rights and choices regarding how we use your information, see Your Rights and Choices below.

Sharing of Your Information

We share information about you as follows:

• Services Providers. We may share your information with our agents, vendors and other service providers (collectively "Services Providers") in connection with their work on our behalf. Services Providers assist us with services such as payment processing, data analytics, marketing and promotional services, website hosting, and technical support. Services Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
• Affiliates. We may share your information with our related entities, including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing and technical operations.
• Third Parties. We may share your information with third parties for purposes of facilitating your requests and in connection with measuring and improving the Site or Service and enabling other enhancements.
• Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of Medallion, the Site or Service, or any third party.
• Consent. We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see Your Rights and Choices below.

Your Rights and Choices

1. Review and Update of Account Information

You may access, update, or remove certain information that you have voluntarily submitted to us through the Site or Service by sending an email to us at privacy@medallion.co. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Additional information about privacy rights is set forth below.

2. Tracking Technology Choices

Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies, some parts of the Site or Service may not function correctly.

3. Communications

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at privacy@medallion.co with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of certain non-promotional emails, such as those about your account, transactions, servicing, or Medallion's ongoing business relations with you.

Your Privacy Rights

If you have visited our Site or used our Service, we may send you communications based on your consent or other legitimate interests. You may of course opt out of non-essential communications, but may continue to receive essential communications, such as communications related to the security or integrity of the Site or Services.

We will never share your information with a third party for third party's marketing purposes, unless you have specifically consented to us doing so.

You may contact us at privacy@medallion.co to exercise any of the rights outlined below. We may request specific information from you to confirm your identity, and in some circumstances, we may charge a reasonable fee for access to your information (if appropriate and permissible).

Your Privacy Rights

While not all U.S. states afford rights like those afforded by California or other states that have passed data privacy legislation, we honor requests from any users that wish to exercise the rights enumerated in this section and in the European Privacy Rights section below, and we will not discriminate against any user who exercises these rights.

Right to access/know your information. You may request from us a list of (i) the personal information that we have collected about you, and (ii) the categories of third parties to whom we have disclosed your personal information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete your information. You may request, at any time, that we delete your information and direct our service providers to delete your information from their records. We will honor such requests unless we are required by federal or state law to preserve the information.

You may contact us to exercise these rights at privacy@medallion.co. To ensure the privacy and protection of individuals, we are required to verify your identity (or that of your authorized agent) or otherwise authenticate your request(s), which we will do in accordance with the applicable privacy regulations. Please note that, under the CCPA in particular, we are not required to grant a request to access/know or a request to delete with respect to personal information obtained from you in your role as an employee, owner, director, officer or contractor of a company and within the context of Medallion providing its services to such company.

California Personal Data Classifications

For California residents, the California Consumer Privacy Act (“CCPA”) requires businesses to disclose, for the past 12 months, (i) the categories of personal information collected, (ii) the sources of the collected personal information, (iii) the purposes for which the collected personal information is used, (iv) the categories of personal information disclosed for a business purpose, and (v) the categories of any personal information sold. We provide these disclosures in the following table.

Do Not Sell

Note that Medallion does not sell any personal information, even under the broad CCPA definition of a “sale.”

European Privacy Rights

We do not expressly provide the Site or Services to users that reside in the European Economic Area, the UK, or Switzerland. If you are a resident of these jurisdictions, please do not use the Site or Services. That notwithstanding, this policy provides information about the rights afforded to users under regulations within the foregoing jurisdictions, such as under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) or similar regulations. Those rights include:

• The right of access to your information.
• The right to rectify your information if it is incorrect or incomplete.
• The right to have your information erased (“right to be forgotten”) if certain grounds are met.
• The right to withdraw your consent to our processing of your information at any time (if our processing is based on consent).
• The right to object to our processing of your information (if processing is based on legitimate interests).
• The right to object to our processing of your information for direct marketing purposes.
• The right to receive your information from us in a structured, commonly used and machine-readable format, and the right to transmit your information to another controller without hindrance from us (data portability).

If you believe that our processing of your information is inconsistent with your data protection rights, please contact us at privacy@medallion.co so we can address your concerns. In the case, we have not adequately addressed your concerns, under GDPR, you have the right to lodge a complaint with the data protection supervisory authority of your country.

Users of Our Services Outside the United States

Medallion is a U.S.-based company. If you are a non-U.S. resident and provide us with your personal information, you acknowledge and agree that your personal information may be transferred to and be processed in the United States, where the laws regarding processing of personal information may be less stringent than the laws in your country. By providing your information, you consent to such transfer and processing.

Children's Privacy

Our Site and Service is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Site or Service. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@medallion.co.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or Service.

Changes to this Privacy Policy

We reserve the right to revise this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy and updating the “last modified” date above. Your continued use of the Site or Service indicates your consent to the Privacy Policy then posted. If the changes are material, we will provide you additional notice to your email address. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site or Service and this Privacy Policy to check for any changes.

Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us as follows:

FirstLayerAI, Inc.

2261 Market Street #4084

San Francisco, CA 94114

hello@medallion.co