Your Privacy Rights
Effective Date: August 19, 2020
This Privacy Policy describes the types of information gathered by Onyx Management Group, LLC in the process of providing https://gatewaynj.com (the “Site”), and the data, services, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use the information, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information, and our efforts to protect the information you provide to us through the Service.
By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.
This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date ” above to see when this Policy was last updated.
Territoriality
Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.
Who Collects Your Information On Our Service?
We do. We collect information that may identify you as a person, and thus may be referred to in this Privacy Policy as personally identified information ( “PII “) from you on the Service, and we are responsible for protection of your information. We collect two types of information about persons who use the Service: voluntarily provided personal information; and automatically collected information.
What Information Does Onyx Collect?
- Personal Information. We collect certain personal information about you, which may be supplied when you register for the Service, when you create or update an account, when you use the Service, when you request services, or otherwise when you submit such information. The types of personal information we collect and save include:
- Name, email address; phone number; and location information;
- Technical information collected in our logs. Such information may include standard web log entries that contain your IP address; browser history; third party cookies; web beacons; page URL and timestamp.
- Non-personal Information. Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to links and materials posted, the type of device you used and its operating system, browser information, the pages accessed most frequently, how pages are used, when and how you use the Service, applications downloaded, search terms entered, and similar non-personal data.
Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools. Through collecting your IP address, we may be able to approximate your geographic location; however, unless and until this is information is paired with your PII, it cannot be used to identify you. If non-personal information is paired to any of your PII, we will treat the non-personal information as if it were also PII.
Part of the purpose of the Service is to share materials you make available. Anything you publicly post will not be considered personal information.
- Aggregate Information. We may also collect anonymous, non-identifying and aggregate information, the date and time of any request you make, your language preference, the referring website, the website you go to immediately after visiting our Site, and the domain name of your Internet service provider.
You may provide us with information when you interact with us through email, submit a request through other use of the Service, or otherwise communicate with us. We may retain such information in order to provide you with services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.
- Personal Information. We collect certain personal information about you, which may be supplied when you register for the Service, when you create or update an account, when you use the Service, when you request services, or otherwise when you submit such information. The types of personal information we collect and save include:
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Why Is My Information Being Collected?
We accept and gather information in an effort to provide the Service to you. We need to collect your personal information so that we can respond to your requests for information or to be added to our email lists, enforce our Terms of Service, and otherwise provide the Service. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.
How Do We Use the Information We Collect?
- We use the personal information you provide for the purposes for which you have submitted it, including:
- Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, conduct usage experiments, develop and improve the Service and other offerings, and perform research and analytics.
- Communicating With You About Our Services. We may use your PII to send you information about new services and other items that may be of interest to you.
- Sending Marketing and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account information and your other PII; (b) confirm your registration; (c) send you general marketing messages if you subscribe to such messages; (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (e) provide you with information on our other services and products, or promotions related to the Service or our other services and products.
- Serve You Targeted Advertisements. We may use your PII to serve you advertisements with the Service that are targeted to your interests.
- We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services. We may use any anonymous, aggregate information, which may include or be based on your information, without restriction.
- We use the personal information you provide for the purposes for which you have submitted it, including:
Do We Share Your Personal Information?
We will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to carry out internal operations or business activities, for example, we may transfer your PII to a successor in interest after a merger with, or an asset sale to, another company. We may also share aggregate information with others, including affiliated and non-affiliated organizations.
How Can You Access And Control Your Information?
For instructions on how you can access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to legal@onyxequities.com. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections, or removing your information.
How Do We Store and Protect Your Information?
- After receiving your personal information, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.
- If you are visiting the Site from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
- We retain and store your PII until you request us to remove it from our servers. We store our logs and other technical records indefinitely.
How Do We Use Cookies And Other Network Technologies?
- To enhance your online experience with us, our web pages may presently or in the future use “cookies.” Cookies are text files that our web server may place on your computer or mobile device to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies.
- Google Analytics. Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 ( “Google “). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit https://optout.aboutads.info.
- Onyx or its service providers may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some of our Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ computers or mobile devices. Pixel Tags allow us and our service providers to count users who have visited certain pages of our Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
- As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data “, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site, App and Services.
- Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals.
Collection of Information by Others.
Our Terms of Service document identifies certain third party websites to which we may provide links, and that you may click on our Site or in our Service. This Privacy Policy is only applicable to our Service. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.
Children and Young People’s Information.
We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the Children’s Online Privacy Protection Act ( “COPPA “) and associated Federal Trade Commission ( “FTC “) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from our servers, please contact us at legal@onyxequities.com. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at legal@onyxequities.com.
California Privacy Rights
California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at legal@onyxequities.com with “Request for Privacy Information” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.
Contact Information
If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at legal@onyxequities.com.
Copyright © Onyx Management Group, LLC. All rights reserved. The Service is the property of Onyx, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.