Privacy Policy

This Privacy Policy describes the policies and procedures of Funding Gates Corporation (“we”, “our” or “us”) on the collection, use and disclosure of Your information on (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”). We receive User Information (as defined below) and information about You, Your company and any and all officers, directors and employees thereof (“You” or “Your”) from various sources, including: (i) if You register for the Site and the Services, through Your user account on the Services (Your “Account”); (ii) Your use of the Services generally; and (iii) from third party websites and services. When You use the Services, You are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of Your information and User Information as described in this Privacy Policy.

1. What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”), User Information (as defined below), and financial information of Yours, including information relating to Your and Your customers’ accounts and receivables (“Financial Information”), gathered when You are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information or User Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that You elect to access through the Services or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage You to carefully review the privacy policies of any Third Party Services You access, including without limitation Twilio, Inc’s privacy policy (available at if You use or intend to use the call feature made available on the Services (the “Call Feature”).

2. What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some Personal Information. We collect the following types of information from our users.

3. Account Information:

When You create an Account, You will provide information that could be Personal Information, such as Your username, password, email address and, as applicable, other information related to Your business. You acknowledge that this information may be personal to You, and by creating an account on the Services and providing Personal Information to us, You allow us to identify You and therefore may not be anonymous. We may use Your contact information to send You information and deliverables created in conjunction with our Services. You may unsubscribe from certain communications from us through Your Account settings, although we, regardless, reserve the right to contact You when we believe it is necessary, such as for account recovery purposes.

4. User Information:

Some features of the Services, including some features provided by Third Party Services and made available on the Services, require You to provide content to the Services, such as the Personal Information and financial information of Your customers and Call Information (defined below) (collectively, “User Information”). Please do not input, upload, provide or otherwise make available to or through the Services any User Information of any party unless You reasonably believe You have the consent of such party to do so. Where appropriate, and solely in furtherance of the Services, User Information (including Financial Information) that You may provide us as a result of Your use of the Services, may be used by us and may be disclosed to Third Party Services that You authorize us to use. For example, if You use the Call Feature to call one of Your customers, and enter such customer’s phone number in the Call Feature information screen, we collect and store that phone number, and we share it with the Third Party Service that powers our Call Feature so that they can provide the service to You. By agreeing to this Privacy Policy along with our Terms of Service, You acknowledge that (i) Your privacy policy, where applicable, clearly and sufficiently discloses to Your customers that You may provide us with (and we may in turn provide to other Third Party Services) User Information used in conjunction with the Services; and (ii) in furnishing or disclosing such User Information to us, You have complied, and shall continue to comply with all applicable federal, state and local laws and regulations, including but not limited to, the Fair Debt Collection Practices Act (FDCPA) (16 USC §160 et. seq.), the Fair Credit Reporting Act (FCRA) (15 USC §1681 et. seq.), as amended by the Fair and Accurate Credit Transactions Act of 2003 (PL 108-159, 12/04/03), the Equal Credit Opportunity Act (16 USC §1691 et. seq.), the Telephone Consumer Protection Act, 47 U.S.C. § 227 et. seq. administered by the Federal Communication Commission, the Telephone Sales Rule, (16 C.F.R. § 310.1 et. seq.), the Federal Trade Commission Act (15 USC §41-58), Title V of the Gramm-Leach-Bliley Act of 1999, 15 U.S.C. § 6801, et. seq.; Regulation P, “Privacy of Consumer Financial Information,” 12 C.F.R. Part 332; “Interagency Guidelines for Establishing Standards for Safeguarding Customer Information”, 12 C.F.R. Part 364, Appendix B; Regulation S-P, “Privacy of Consumer Financial Information,” 17 C.F.R. Part 248; FTC Standards for Safeguarding Consumer Information, 16 C.F.R. Part 314; and 45 C.F.R. Parts 160 and 164 promulgated under the Health Insurance Portability and Accountability Act of 1996 and any state versions of the foregoing. All content submitted by You to the Services, including but not limited to User Information, may be retained by us indefinitely, even after You terminate Your account.

5. Payment Information

While the Services are offered to You for a subscription fee, we do not currently collect Your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy. However, as many of the Services we offer involve receivables and accounts services, we may, as a result of Your use of the Services, obtain from You Financial Information pertaining either to You or Your customers, that You provide us as a result of Your use of such Services. We shall use such Financial Information solely in furtherance of the Services and in accordance with this Privacy Policy.

6. IP Address Information and Other Information Collected Automatically:

  • We automatically receive and record information from Your web browser when You interact with the Services, including Your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning Your interaction with the Services (e.g., what links You have clicked on).
  • Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify You personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

7. Email Communications:

We may receive a confirmation when You open an email from us. We use this confirmation to improve our customer service.

8. Call Information:

In addition to User Information that we may collect about a call recipient when You use our Call Feature, we also collect and store information about the communication itself (“Call Information”), such as by recording the call for Your later reference and providing You with a transcript of the call on the Services. We may share Call Information and other related information with the Third Party Service that powers our Call Feature, and the Third Party Service may share such information with us. By using the Call Feature, You hereby consent to our collection, storage and use of Call Information in accordance with this Privacy Policy. Please note that the Call Feature is powered by Twilio, Inc. and use of the Call Feature is also subject to its privacy policy at

9. Information Collected Using Cookies:

  • Cookies are pieces of text that may be provided to Your computer through Your web browser when You access a website. Your browser stores cookies in a manner associated with each website You visit. We use cookies to enable our servers to recognize Your web browser and tell us how and when You visit the Site and otherwise use the Services through the Internet.
  • Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who You are. As noted, however, we do use cookies to identify that Your web browser has accessed aspects of the Services and may associate that information with Your Account if You have one.
  • Most browsers have an option for turning off the cookie feature, which will prevent Your browser from accepting new cookies, as well as (depending on the sophistication of Your browser software) allowing You to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that You leave cookies active, because they enable You to take advantage the most attractive features of the Services.
  • This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on Your computer. For example, third party websites to which a link points may set cookies on Your computer.

10. Information Related to Advertising and the Use of Web Beacons:

To support and enhance the Services, we may serve advertisements, and also allow third parties advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category may be based on anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on Your activity on Third Party Services. We do not provide Personal Information to any ad networks for use outside of the Services.

To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to You through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to You when You visit other websites. Because Your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if You had requested a web page from their site.

11. Aggregate Information:

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to You, Your Account or Your web browser.

12. How, and With Whom, Is My Information Shared?

13. IP Address Information:

While we collect and store IP address information, that information is not made public. We may at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

14. Information You Elect to Share:

As set forth above, we may share Your Personal Information and User Information (including any Financial Information You provide to us) with Third Party Services through the Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and You are responsible for reading and understanding those Third Party Services’ privacy policies, as well as ensuring that Your privacy policy, where applicable, is consistent with the User Information sharing policies and protocol set forth in this Privacy Policy. This Privacy Policy only governs information collected on the Services.

15. Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about You that they have independently developed or acquired.

16. Email Communications with Us:

As part of the Services, You may receive email and other communications from us, such as communications relating to Your Account.

17. Payment Information:

As stated above, we do not currently collect Your payment method, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of Your financial information from our Payment Processor for the purposes of completing transactions You have initiated through the Services, enrolling You in discount, rebate, and other programs in which You elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business. As stated above, we may, as a result of Your use of the Services, obtain from You Financial Information pertaining either to You or Your customers, that You provide us as a result of Your use of such Services. Such Financial Information may be used by us and may be disclosed to Third Party Services that You authorize us to use, solely in furtherance of the Services.

18. Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf in furtherance of the Services and who are under our control (our “Agents”). We may need to share Personal Information and User Information (including Financial Information) You provide us as a result of Your use of the Services, with our Agents in order to provide products or services to You. Unless we tell You differently, our Agents do not have any right to use Personal Information, User Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information and User Information You provide us as a result of Your use of the Services, with our Agents.

19. Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use Your Personal Information and User Information (including Financial Information) You provide us as a result of Your use of the Services, as set forth in this policy.

20. Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy or our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

21. Information We Share With Your Consent:

Except as set forth above, to the extent You have not already pre-authorized us to do so, You will be notified when Your Personal Information and/or Your User Information (including Financial Information) of Yours may be shared with third parties (including but not limited to Third Party Services), and will be able to prevent the sharing of this information.

22. Is Information About Me Secure?

Your Account information will be protected by a password for Your privacy and security. You need to prevent unauthorized access to Your Account, Personal Information and User Information (including Financial Information) of Yours, as applicable, by selecting and protecting Your password appropriately and limiting access to Your computer and browser by signing off after You have finished accessing Your Account.

We use industry standard methods and techniques to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information (including Personal Information and User Information of Yours that You provide us). Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

23. What Information of Mine Can I Access?

If You are a registered user, You can access information associated with Your Account (including User Information) by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If You are a California resident and would like a copy of this notice, please submit a written request to the following address:

Funding Gates Corporation
333 W 39th St Suite 1101
New York, NY 10018

24. What Choices Do I Have Regarding My Information?

  • You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.
  • You can inactivate Your Account. Please note that we will need to verify that You have the authority to inactivate the Account, and activity generated prior to inactivation will remain stored by us and may be publicly accessible on an anonymous basis.
  • You can choose not to use certain features on the Services.

25. What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify You by posting an announcement on the Services or sending You an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

26. What If I Have Questions or Concerns?

If You have any questions or concerns regarding privacy using the Services, please send us a detailed message to [email protected]. We will make every effort to resolve Your concerns.

Effective Date: December 4, 2014

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