Privacy policy

DECIMAL LLC (“Decimal”) cares deeply about the privacy of its visitors and users and would like to share the steps it takes to protect your personal information in compliance with applicable data privacy laws and best practices.  The below policy describes: (1) what information may be collected; (2) how such information may be used; and (3) your rights as a visitor of this site regarding such information. Information may be collected on our website (the “Site”). Decimal uses this information to deliver the services offered on the Site, to inform you of changes to the Site or your account, to enhance the Site, and to prevent illegal or potentially prohibited conduct.

When we offer services to individuals in the European Economic Area (“EEA”), we are subject to the EU General Data Protection Regulation (“EU GDPR”), which applies across the entire European Union. We are responsible as a "controller" of your personal information for the purposes of the GDPR.

Before you access or use any of our services we encourage you to read the entire Privacy Policy. A short summary is below:

• We collect information related to your use of the Site:
• Such information is used to provide you the services on the Site:
• You have the right to request the deletion of your personal information at any time and for any reason by contacting: [email protected]

We take your privacy very seriously and we work hard to earn and keep your trust. As such, we adhere to the following basic principles to protect your privacy:

• We do not rent or sell your personally identifiable information (“PII”) to third parties for marketing purposes.
• Any personally identifiable information that you provide will be secured with industry standard protocols and technology.
• We will collect the bare minimum information and store for only so long as we need it to provide you with the services on the Site.

This Privacy Policy governs Decimal’s information management policies including how Decimal gathers, stores or shares your information, if at all. Notwithstanding anything to the contrary, this Privacy Policy does not apply to information that is gathered or collected offline. By using the Site and by submitting information to Decimal, you agree to the practices described in this Privacy Policy and to any other applicable terms. This Privacy Policy is intended to provide you with a clear explanation of how, when, and why we collect and use your personal information, as well as an explanation of your legal rights. Nothing in this policy is intended to override the terms of any contract you have with us or any rights you have under applicable data privacy laws.

Please read the entire policy and make sure you fully understand our practices before using our services. If you do not agree with our practices you must immediately leave the Site. If you have any questions after fully reading the policy, please contact us at: [email protected]

From time to time, we may develop new or offer additional services.  If the introduction of services results in any material changes in the way we collect or process your information we will provide you with more information and update this policy.

We host live zoom conversations with our friends periodically. These zooms are recorded. If you do not want your information recorded and posted on our site in the zoom recording please turn off your video and do not use your full name.

We collect two types of information from visitors and users. The first, unidentified and non-identifiable information (“Anonymous Information”) does not enable Decimal to identify the visitor or user from whom it was collected. The Anonymous Information collected by Decimal may consist of the date, time, length and non-precise location of your visit. Decimal will not aggregate, use or share Anonymous Information with third parties for marketing or advertising purposes but please review the privacy policy of Google Analytics to see how they may use Anonymous Information they gather from the Site.

The second type of information we collect is individually identifiable information, meaning information that can identify an individual or may, with reasonable efforts, lead to the identification of an individual (“PII”).  PII collected by Decimal is described in the chart below.

Categories of Personal Information

1. Identifiers (e.g., 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)
2. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.
3. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)
4. Geolocation data
5. Audio, electronic, visual, thermal, olfactory, or similar information

Specific Types of Personal Information Collected

1. We may collect your full name, alias, IP address, email address, phone number, and physical address.
2. We may collect your name, physical characteristics, address, or telephone number.
3. We may collect your browsing history, search history, and information regarding your interaction with our Site.
4. We may collection your location through Google Analytics.
5. We may collect a recording of you if you leave your video on in a Friends of Decimal zoom.

If any Anonymous Information is linked to PII, it is treated as PII as long as the connection exists. You may request to review, amend, or delete any and all information associated with your personal information by sending an e-mail to: [email protected]

Decimal collects information about you only if we have a reason for such collection, such as to provide the services, to communicate with you, or to improve our Site. Information is collected in three ways:

(a) Information collected automatically through accessing the Site. When you visit the Site (or any website), your actions while you browse the Site or access any links, either directly through the Site or with the help of third-party services such as cookies, and analytics plugins are tracked. Learn more about how we use cookies and third-party services in Section 7 below.

(b) Information you provide Decimal. When you contact us directly, we collect the PII you provide us.  If you participate in a Friends of Decimal presentation during the live zoom you may be recorded. We may also store all communications you have directly with us (c) Information obtained from outside sources. This may include internet service providers, Google Analytics, and cookies on our website.

We use the information we collect (both Anonymous Information and PII) to operate and improve the Site as well as to stay in touch with you, to comply with regulatory obligations, and in other instances where you have given consent. 

Except for the public posting of Friends of Decimal zoom recordings, we do not share your PII with outside parties except to the extent necessary to operate our Site. Google Analytics is used to run the Site any may have access to your PII. Email addresses may be stored in Klaviyo. Please review their privacy policies to learn more about how they use information and how you may opt out of collection.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

1. To provide products and/or services to you.
2. To prevent and detect fraud against you or us.
3. Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business.
4. Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures
5. Marketing our services to:
   • Existing and former customers
   • Third parties who have previously expressed an interest in our services
   • Third parties with whom we have had no previous dealings

Our reasoning

1. For the performance of our contract with you or to take steps at your request before entering into a contract.
2. For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.
3. This is only done if required by law or regulation.
4. For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price.
5. For our legitimate interests, i.e., to promote our business to existing and former customers.

In the future, we may sell to, buy, merge with, or partner with other businesses. In such transactions, Anonymous Information and PII may be among the transferred assets.

Decimal will not sell, license, rent, or otherwise disclose your PII except as stated herein, unless under the following circumstances: (1) you have affirmatively given your consent; (2) we previously notified you of the disclosure in this Privacy Policy or when you provided your information on the Site; (3) we are compelled by law, legal process, or court order to disclose; (4) disclosure is required to identify, contact, or bring legal action against someone who may cause harm to, or interference with, Decimal’s rights or property, our users, or anyone else; or (5) to respond to an inquiry, request or complaint that you have made. Decimal may cooperate with Internet service providers to identify users whenever required to comply with law, to enforce compliance with this Privacy Policy or our Terms, or to protect the Site, our customers and others.

We may use your PII to send you updates (by email) about our services including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above "Why Is Information Collected?"). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at: [email protected]

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share personal information with:

• third parties we use to help us run our business, such as website hosts, klaviyo, and google analytics.
• the public if you turn your video on or your use your full name in a Friends of Decimal zoom session.

We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

In the preceding 12 months, we have shared the following categories of personal information:

• Identifiers (e.g., a real name, alias, postal address Internet Protocol address, email address, or other similar identifiers).
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, physical characteristics or description, address, and telephone number.
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement).
• We may have collected a recording of you if you leave your video on in a Friends of Decimal zoom.

Decimal uses industry standard technologies to safeguard your data (both Anonymous Data and PII) from unauthorized use and disclosure and to prohibit possible security breaches of the Site. Unfortunately, no website, application, computer system or online communication is completely secure. Decimal cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Site is at your own risk.

Data will be maintained, processed and stored by Decimal in the United States of America (outside of the EEA) or other jurisdictions, as necessary, for proper delivery of the services or as required by law. PII is kept only as long as necessary to provide you with access to the Site and for legitimate and essential business purposes, such as making data-driven business decisions about new features and offerings.

EEA Data Subjects: non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses please email us at [email protected]

If you would like further information, please email us at [email protected]

We will keep your PII while we are providing services or information to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf
• To show that we treated you fairly 
• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Right to Be Informed:
The right to know or be notified about the collection and use of your personal information.

Right to Access:
The right to be provided with a copy of your personal information (the right of access).

Right to Rectification:
The right to require us to correct any mistakes in your personal information.

Right to be Forgotten:
The right to require us to delete your personal information—in certain situations.

Right to Restriction of Processing:
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.

Right to Data Portability:
The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.

Right to Object:
The right to object:
• At any time to your personal information being processed for direct marketing (including profiling).
• In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making:
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

Decimal strives to provide these rights to all visitors and users. Please email us at [email protected] with any requests, questions, or concerns.

If you would like to exercise any of your rights as described in this Privacy Policy, you can email us at [email protected]

• If you choose to contact us directly by email, you will need to provide us with:Enough information to identify you (e.g., your full name);
  o Enough information to identify you (e.g., your full name);
  o Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) ; and
  o A description of what right you want to exercise and the information to which your request relates.
• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
• Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We hope we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. You  can find a list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)

What are cookies?

Cookies are small data files sent from a server to your web browser. They are stored in your browser’s cache and allow a website or a third party to recognize your browser.

Our sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them). We specifically use two types of cookies:

(1) first party cookies, provided directly by us to your computer or mobile device, which we use to recognize you when you revisit our Sites; and

(2) third party cookies, which are served by service providers or other third parties and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising, and social media features.

We Use the Following Categories of Cookies.

Essential cookies: These cookies are strictly necessary to provide you with services available through our Sites and to use some of its features. Refusal of these cookies may impact Site functionality.

Performance and functionality cookies. These cookies are used to enhance the performance and functionality of our Sites but are not required for site use. However, without these cookies, you may lose functionality, and we will not be able to conduct analytics to optimize site functionality and performance.

Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Sites are being used generally, or how effective our marketing campaigns are, or to help us customize our Sites specifically for you. Without these cookies, we will not be able to analyze your site usage to provide custom content.

Other technologies

In addition to cookies, our Sites may use other technologies such as pixel tags to collect information automatically.

UTM codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a web page) when a user moves from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

Local Storage Objects: These are sets of data that can be stored on your browser by a site or app. They can be used to maintain preferences, a history of usage, or even the state or settings of a site or an app.

Your choices

There are a number of ways that you can opt-out or manage cookies. Your options for controlling what information cookies and similar technologies collect about you include:

Your Cookie Settings. When you visit our Sites, depending on where you are located, we may show you a notice which tells you how and why we use certain cookies and provide you the ability to opt out of cookie use (other than Essential cookies necessary to provide our Sites).

Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.

Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

This Site is NOT directed towards children under the age of 13. Decimal recognizes the importance of maintaining the privacy of children, especially those under the age of 13. Decimal is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. § 6501, et seq.

Decimal does not and will not knowingly request, collect, store, maintain, or share any personally identifiable information of children under the age of 13, without first obtaining the consent of a legal guardian. In those limited instances, Decimal will only collect reasonably necessary information, and Decimal will not share with third parties any personally identifiable information of a child under the age of 13 without the explicit consent of a legal guardian, or as permitted by COPPA or other applicable law.

You may revoke your consent and request the removal of your child’s information at any time. If you are the legal guardian of a child under the age of 13 and discover that your child has submitted their personally identifiable information without securing your consent, Decimal will use commercially reasonable efforts to remove this information. If at any point you wish to review, amend, or request the removal of your child’s information, please send an e-mail to [email protected] and provide appropriate details.

Decimal may at any time and in its sole discretion, add, modify, or remove any feature, function or portion of the Site, the Terms, and/or the Privacy Policy, in whole or in part, with or without notice to you, prior or otherwise. Any changes to the Privacy Policy will be effective as of the posting date. Decimal will provide prominent notice on the Site of any major changes to the Privacy Policy. Your continued use of the Site after Decimal posts any modifications to the Privacy Policy shall be deemed your explicit acceptance of those modifications and shall constitute your agreement to comply with the Privacy Policy, as modified.

If there are any questions regarding this Privacy Policy you may contact us using the information below.

Decimal LLC.
Attn: Legal Department
[email protected]