Last updated September 12, 2026
This privacy notice for Hi Cavalry, Inc. (doing business as 100) ("we","us", "our", or “100”), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services, our websites and applications, including https://www.get100.com/ or any website of ours that links to this privacy notice (the “Platform”), our business operations and when you engage with us in other related ways, including any sales, marketing, or events. “You” or “your” includes users of our Platform, including property management companies, property owners, and their authorized staff members who access the Platform pursuant to a commercial agreement with us (collectively, “Operators”), individuals (including prospective tenants) whose identity is verified or whose personal information is otherwise processed through the Platform in connection with a rental application or screening event (collectively, “Renters”), authorized users and other persons about whom we collect or process personal information. If you are an individual, this privacy notice also provides you with important information about your personal information rights with respect to personal information that we control and how to exercise them. The Platform may also include artificial intelligence and machine learning technologies (collectively, “AI Technologies”). AI Technologies on the Platform include an AI-powered customer support agent that may interact with you directly through automated chat conversations. When you engage with our customer support features, you may be communicating with an AI agent rather than a human representative.
This privacy notice does not apply to personal information that we collect from employees of or job applicants to 100 in connection with their employment or potential employment with us.
BY ACCESSING OR USING OUR PLATFORM, OR BY PROVIDING PERSONAL INFORMATION TO US, YOU ACKNOWLEDGE THAT YOU ACCEPT OUR PRIVACY PRACTICES AND POLICIES OUTLINED BELOW, AND YOU CONSENT THAT WE MAY COLLECT, PROCESS, STORE AND SHARE PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE.
BY ENABLING OR USING ANY BIOMETRIC FEATURE OF THE PLATFORM, YOU EXPRESSLY CONSENT IN WRITING TO THE COLLECTION, PROCESSING, STORAGE, AND RETENTION OF YOUR BIOMETRIC DATA AS DESCRIBED IN OUR PRIVACY NOTICE.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Platform. If you still have any questions or concerns, please contact us at info@get100.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Platform, we may process personal information depending on how you interact with us and the Platform, the choices you make, and the products and features you use. Learn more about personal information you disclose to us in Section 1.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process in Section 1.
Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources in Section 1.
How do we process your information? We process your information to provide, improve, and administer our Platform, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. Learn more about how we process your information in Section 3.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information in Section 4.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be ableto defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe in Section 8.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights in Section 10.
How do you exercise your rights? The easiest way to exercise your rights is by visiting info@get100.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. OUR BUSINESS PURPOSE FOR COLLECTING
3. HOW DO WE PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. DO WE SEND TEXT MESSAGES AND HOW DO YOU OPT IN OR OUT
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. AUTOMATED DECISION-MAKING AND AI-POWERED INTERACTIONS
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect information that identifies, relates to or could reasonably be linked, directly or indirectly, with a particular individual or household (collectively, “personal information”) that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our products and Platform, when you participate in activities on the Platform, or otherwise when you contact us. Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified, or aggregated data (even if it originally comes from personal information).
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make, and the products and features you use. The personal information we collect may include the following:
Not all categories below are collected from every individual. The categories collected depend on your relationship with us: Operators typically provide contact information, professional information, account access information, and internet and device data. Renters may provide or have collected from them: contact information, government-issued identity information, biometric information, financial and income information, and verification status data. Biometric information, government identification information, and financial information are collected only from or about Renters, not from Operators. See the “Operator Data and Renter Data” section below for a full description of each population’s data
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
• biometric data, such as biometric identifiers derived from identity documents submitted through our identity verification process, including through our partnership with CLEAR. Biometric identifiers processed through CLEAR’s Verified Renter Network™ may also be subject to CLEAR’s privacy policy; please see CLEAR’s privacy policy at https://www.clearme.com/privacy-policy for information about CLEAR’s independent data practices with respect to biometric information
• social security numbers or other government identifiers
• financial data
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Generally, you are not under a statutory orcontractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to provide access to the Platform, verify your identity, or process transactions, we may be unable to offer access to the Platform, or otherwise conduct business with you.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Platform.
We automatically collect certain information when you visit, use, or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Platform, and other technical information. This information is primarily needed to maintain the security and operation of our Platform, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Platform and which we recordin log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Platform (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such asinformation about your computer, phone, tablet, or other device you use toaccess the Platform. Depending on the device used, this device data may includeinformation such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Platform. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Platform.
Google API
Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Information Collected From Other Sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.
If you interact with us on a social media platform using your social media account (e.g.,Facebook or X), we receive personal information about you from such platforms such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings. Please note that their own use of your information is not governed by this privacy notice.
We Do Not Sell or Share Your Personal Information for Targeted Advertising
We do not sell personal information, including sensitive information such as biometric data, biometric identifiers or biometric information. We do not disclose biometric information to third parties other than: (i) CLEAR, in connection with the verification infrastructure described above; (ii) vendors who processbiometric information on our behalf; and (iii) as required by applicable law or a valid legal process. For purposes of this privacy notice, “sell” means the disclosure of personal information to a third party in exchange for money or other valuable consideration.
We do not share personal information with third parties for cross-contextual behavioral advertising or targeted advertising.
We do not share personal information with third parties for such third parties’ direct marketing purposes.
Operator Data and Renter Data — How We Differentiate Our Data Practices
100’s Platform serves two distinct categories of individuals, and our data practices differ meaningfully between them. This section describes those differences.
A. Operator Data
“Operators” are property management companies, property owners, and their authorized staff members who access the Platform pursuant to a commercial agreement with us. When we refer to “Operator Data,” we mean personal information that Operators provide to us directly in connection with their use of the Platform as a business customer, including:
· Contact and account information of Operator staff (name, email, phone, title);
· Property and portfolio information uploaded to the Platform; and
· Usage and activity data generated through the Platform in connection with Operator’s account.
Operator Data does not include biometric information. Operators are our direct contractual counterparties, which impose obligations on Operators with respect to the personal information of Renters and other individuals whose data is submitted to the Platform. We process Operator Data to provide the Platform, support our commercial relationship with Operators, and for our other business purposes described above.
B. Renter Data
Renters may or may not have a direct account with us; in some cases, a Renter’s information is submitted to or processed by thePlatform at an Operator’s direction. “Renter Data” means all personal information relating to a Renter, including:
· Identity information (name, date of birth, government-issued identification);
· Biometric identifiers collected during the identity verification process;
· Financial and income information used to assess rental qualification; and
· Verification status and screening outcome data shared with the applicable Operator.
Where Renter Data includes biometric information, it is subject to the additional protections and disclosures set forth in the “Biometric Information” section of this privacy notice. Renters who have not directly created a Platform account may nevertheless exercise the privacy rights described in section 10 of this privacy notice by contacting us at the email address provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?". We will verify the identity of the requesting individual before responding to any such request. Where a Renter’s data has been submitted to the Platform at an Operator’s direction, we may coordinate with the relevant Operator to fulfill the request.
Biometric Information — Disclosures
In the event of any conflict between this section and the rest of this privacy notice, the terms of this section govern with respect to biometric information.
What Biometric Information We Collect and Why
In connection with our identity verification services, we, in Partnership with CLEAR, collect or receive the following biometric identifiers and biometric information from or about Renters: (a) Facial geometry scans and templates derived from photographs or images on government-issued identity documents submitted during verification; and (b) other biometric identifiers derived from identity documents through ourverification infrastructure.
Biometric information is collected solely for the following purposes: (i) to verify the identity of Renters in connection with rental application screening; (ii) to establish and maintain Renter participation in the Verified Renter Network™; and (iii) to prevent identity fraud and protect the security of the rental application process. Biometric information is not collected for any other purpose without separate, express written consent.
CLEAR Partnership and Biometric Data Flows
Our identity verification infrastructure is powered in part through our partnership with CLEAR (Alclear, LLC), a secure identity company. When a Renter enrolls in the Verified Renter Network™ through CLEAR’s network, CLEAR processes biometric identifiers pursuant to CLEAR’s own privacy notice and terms of service. To the extent that we receive biometric information from CLEAR in connection with a verification event, we process such information solely for the purposes described in this section. We are not responsible for CLEAR’s independent data practices. Please review CLEAR’s privacy policy at https://www.clearme.com/privacy-policy for information about how CLEAR handles your biometric information.
Consent for Biometric Collection
Prior to or at the time of collecting biometric information from a Renter, we (or CLEAR on our behalf) obtain the Renter’s informed written consent to the collection, processing, storage, and use of their biometric information as described in this privacy notice.
No Sale or Profit from Biometric Information
We do not, and will not, sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. We do not disclose biometric information to third parties other than: (i) CLEAR, in connection with the verification infrastructure described above; (ii) vendors who process biometric information on our behalf subject to written data processing agreements that prohibit use for any other purpose; and (iii) as required by applicable law or valid legal process.
Biometric Retention and Destruction Schedule
We retain biometric identifiers and biometric information only for so long as necessary to fulfill the purpose for which they were collected, and in no event longer than permitted by applicable law. In no event will we retain biometric identifiers or biometric information beyond three (3) years from the date of collection, or beyond the period required to fulfill the original purpose of collection, whichever is earlier, unless a longer period is required by a valid legal hold or applicable law.
2. Our Business Purposes for Collecting and Sharing Personal Information
We process all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests, and the legitimate interests of third parties to:
Under the laws of some jurisdictions, we must be able to describe the legal bases on which we rely to process personalinformation. We primarily rely on the legitimate interests, described above, to process personal information when not overridden by an individual’s data protection interests or fundamental rights and freedoms. Other legal bases for our processing of personal information include when the processing is necessaryto perform a contract with you, we have a legal obligation to process the personal information or we have your consent to process the personal information.
3. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Platform, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Platform, including:
• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. Customer support may be provided in whole or in part through the use of AI Technologies, including an AI-powered agent. The AI agent processes the content of your inquiries in real time to generate responses. If you prefer to interact with a human representative, you may request to do so through the support interface.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
The categories of third parties we may share personal information with are as follows:
• User Account Registration & Authentication Services
• Payment Processors
• Website Hosting Service Providers
• Cloud Computing Services
• Communication & Collaboration Tools
• AI-Powered Customer Support Providers (e.g., providers of AI chatbot and automated support agent technology that process user inquiries on our behalf)
We also may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition of all or a portion of our business to another company or other transaction in which athird party invests in, finances or acquires control of the portion of our business or assets (in whole or in part), or any similar corporate event to any of the foregoing.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Marketing Purposes. We may share the following categories of personal information with third parties for our direct marketing purposes: contact information, professional or employment-related information (for example, job title and employer), and preference information
• Legal Purposes, including governmental authorities, law enforcement, courts, or other third parties
You may not disclose the personal information of someone other than yourself to us unless you have the other individual’s prior written consent or are otherwise authorized under applicable law to share their information with us. To the extent that you provide another individual’s personal information to us or we collect another individual’s personal information on your behalf, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information, including:
· providing all applicable notices
· receiving the proper authority or consent to allow us to collect, store, process and share such personal information responding to data subject requests
· respondingto data subject requests
· ensuring that any communications you submit through the Platform, including text messages, SMS messages, or other message content involving third parties, are shared only with the prior written consent of all individuals whose communications are included, and assuming sole responsibility and liability for any such submission. 100 is not responsible for, and expressly disclaims any liability arising from, user-submitted communications involving third-party content
International Transfer, Storage and Processing
We operate from the United States and the personal information we collect or receive is processed in the United States and may be processed in other countries around the world. If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of personal information to the United States or any other country in which we, our affiliates or vendors maintain facilities and tothe use and sharing of information about you as described in this privacy notice.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Platform. Some online tracking technologies help us maintain the security of our Platform and your account, prevent crashes, fix bugs, save your preferences, and assist with basic sitefunctions.
We also permit third parties and service providers to use online tracking technologies on our Platform for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and Platform tailored to your interests which may appear either on our Platform or on other websites.
To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can optout of these online tracking technologies by submitting a request as describedbelow under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"
Google Analytics
We may share your information with Google Analytics, and may use others, to track and analyze the use of the Platform. If you do not wish for Google Analytics to gather information about how you interact with our website, please install the Google Analytics Opt-out Browser Add-on to opt out of being tracked by GoogleAnalytics across the Platform here: https://tools.google.com/dlpage/gaoptout and employ it at the start of each session. A cookie will be set on your browser that instructs this technology not to start for that session. Please note that the next time you access our website the analytics will be reactivated, so you will have to disable the technology each time.
o See Google’s policies at https://policies.google.com/privacy and https://policies.google.com/technologies/ads. Manage Google’s personalized ads at https://myadcenter.google.com/?ref=privacy-policy. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
o You have the option to manage Google's personalized ads by visiting the Google advertising center at https://myadcenter.google.com/?ref=privacy-policy.
Disable or Delete Cookies from Your Browser or Device
You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature. You can also delete all cookies that are already on your device. If you delete or block all cookies, however, you may have to manually adjust some preferences every time you visit our Platform and some of the Platform functionalities may not work.
To make choices about targeted advertisements from participating third parties, including to opt-out, please visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance at www.aboutads.info/choices. To find out more information about cookies, please visit http://www.allaboutcookies.org.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Platform using a social media account, we may have access to certain information about you.
Our Platform may offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Platform. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes setout in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we willeither delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
With respect to retention of biometric information, please reference “Biometric Information - Disclosures” in section 1.
With respect to data collected through our AI-powered customer support agent, we retain conversation transcripts and associated personal information for as long as reasonably necessary to provide and improve customer support services, resolve disputes, and comply with our legal obligations, and in no event longer than twenty-four (24) months from the date of the interaction unless a longer period is required by applicable law, a valid legal hold or for reasons described in this privacy notice.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the Platform within a secure environment. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. We urge you to take adequate precautions to protect personal information as well, including never sharing your account username or password.
This privacy notice covers how we treat personal information that we collect from you, or in connection with our Platform provided to you, or in connection with our other business or interactions with you. This privacy notice does not cover, and we are not responsible for, the policies or practices of you or third parties that you may access or be connected with through us.
Third-Party Links
This privacy notice does not cover, and we are not responsible for, the privacy policies or practices of any third parties, which have their own rules for how they collect and use personal information. Please make any privacy requests directly to third parties with respect to personal information in their control.
Our Platform may include links to third-party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share personal information. We do not endorse or controlthese third-party websites, plug-ins, and applications and are not responsiblefor their privacy practices or any information on their websites. When you leave our Platform, we encourage you to read the privacy notice of every website you visit.
User-Submitted Communications
This privacy notice does not cover, and 100 is not responsible for, any text messages, SMS messages, or other communications that you submit to or through the Platform involving third parties. If you submit or share any such communications through the Platform, including conversations, message threads, or content involving other individuals, you represent and warrant that you have obtained all required consents from those individuals to share their communications and personal information. Your submission of such communications to the Platform is at your sole risk and responsibility.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Platform. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@get100.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing groundsother than consent.
Account Information:
If you would at any time like to review or change the information in your account or terminate your account, you can:
• Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Platform.
If you have questions or comments about your privacy rights, you may email us at info@get100.com.
11. DO WE SEND TEXT MESSAGES AND HOW DO YOU OPT IN OR OUT?
In Short: By providing your phone number for phone-based sign-up or login, we will send you a one-time passcode (OTP) via text messages (SMS) to authenticate your device. Aside from authentication purposes, we may send you promotional text messages only with your express prior written consent, which is voluntary and separate from your use of the Platform. You may opt out of promotional text messaging at any time.
We may send transactional or informational text messages (SMS/MMS) to you in connection with your use of the Platform, such as account verification, identity verification status updates, or time-sensitive service notifications. We may also, with your separate express consent, send you marketing or promotional text messages about our Platform.
Opt-In to Text Messages
By providing your mobile phone number and affirmatively selecting the option to receive text messages, you expressly consent to receive text messages from 100 at the mobile number you provide. Your consent to receive text messages is not a condition of using the Platform or any of its features. Message and data rates may apply depending on your mobile carrier plan.
Opt-Out of Text Messages
You may withdraw your consent to receive text messages at any time by replying STOP to any text message you receive directly from us, or by contacting us at info@get100.com with a request to be removed from our text messaging list. Opting out of marketing text messages will not affect your ability to use the Platform or receive essential transactional communications through other channels (such as email).
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include aDo-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. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do notcurrently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked 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 notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
13. AUTOMATED DECISION-MAKING AND AI-POWERED INTERACTIONS
Certain features of our Platform use AI Technologies to interact with you or process your information in an automated manner. This includes our AI-powered customer support agent, which generates responses to your inquiries without direct human involvement. The AI agent does not make final decisions regarding your account status, eligibility for services, or other matters that produce legal or similarly significant effects. If a support inquiry requires action affecting your rights, it will be escalated to a human representative.
Under the privacy laws of certain U.S. states, including Colorado and Connecticut, you may have the right to opt out of profiling or automated decision-making that produces legal or similarly significant effects. If you believe that an automated interaction has resulted in a decision that materially affects your rights or access to services, you may contact us at info@get100.com to request human review of that decision.
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Illinois, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category | Examples | Collected (YES OR NO)
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
B. Personal information as defined in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
YES
C. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
YES
D. Commercial information
Transaction information, purchase history, financial details, and payment information
YES
E. Biometric information
Fingerprints
YES
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
YES
G. Geolocation data
Device location
YES
H. Audio, electronic, sensory, or similar information
Images and audio, video or call recordings created in connection with our business activities
YES
I. Professional or employment-related information
Business contact details in order to provide our Platform at a business level or job title, work history, and professional qualifications if you apply for a job with us
YES
J. Education Information
Student records and directory information
NO
K. Inferences drawn from collected personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics
YES
L. Sensitive personal Information
Account login information, geolocation, biometric data, citizenship or immigration status, debit or credit card numbers, drivers' licenses, financial information including account access details, passport numbers, social security numbers and state id card numbers
YES
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Platform and to respond to your inquiries.
Sources of Personal Information
Learn more about the sources of personal information we collect in Section 1 "WHAT INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn about how we use your personal information in Section 2, "HOW DO WE PROCESS YOUR INFORMATION?"
We collect and share your personal information through:
• Beacons/Pixels/Tags
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in Section 3, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
• Right to know whether or not we are processing yourpersonal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personaldata you previously shared with us
• Right to non-discrimination for exercisingyour rights
• Right to opt out of the processing of your personaldata if it is used for targeted advertising (or sharing as defined underCalifornia's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
• Right to obtain a list of specific third parties to which we have disclosed personaldata (as permitted by applicable law, including Oregon's privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)
• Right to opt out of the collection of sensitive data and personal data collectedthrough the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting info@get100.com,by emailing us at info@get100.com, or by referring to the contact details at the bottom of this document.
We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and forsecurity or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submitsuch request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@get100.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in Section 16, "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
15. DO WE MAKE UPDATES TO THIS NOTICE?
YIn Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at info@get100.com or contact us by post at:
Hi Cavalry, Inc. dba 100
5 Union Square W#1485, New York, NY 10003, USA
New York, NY 10003
United States
If you have a disability, you may access this privacy notice in an alternative format by contacting us at: info@get100.com.
In addition to the general privacy rights described in this policy notice, individuals whose biometric information we collect or control have the right to: (a) request access to their biometricinformation we hold; (b) request deletion of their biometric information (subject to applicable legal holds); and (c) withdraw consent to future biometric collection, which may limit or terminate their ability to use the identity verification features of the Platform. To exercise any of these rights, please submit a request to info@get100.com. We will respond within the timeframe required by applicable law and no later than within 45 days.
Subject to applicable privacy law, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint with your local data protection authority and/or competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the European Economic Area, you may find the contact details for your appropriate data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are a resident of the United Kingdom you may contact the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/. If you are a resident of Texas, you may lodge a complaint at https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/.
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: info@get100.com.
