Privacy Policy

Oct 23, 2023
Introduction
Municipal Solvency Research, LLC dba Pality and its affiliates (collectively, “Pality” “we” or “us”) know that data privacy is very important to you. We have created this privacy policy (the “Privacy Policy”) to describe what kinds of personal information we may obtain and process from our:
(a) Website (https://wtl.bxt.mybluehost.me/.website_16fb544e) referred to herein as our/the “Site”;
(b) Any other website, mobile or desktop application, forum, blog or digital property referred to herein as our “Digital Properties” that links to this Privacy Policy; and
(c) Interaction with you in person, electronically or any other way.

By accessing or using the Site or any of our digital properties that link to this Privacy Policy, you may learn about Pality and our technology platform (“Platform”), and customers and registered users may access services provided by Pality from time to time, (collectively with the Digital Properties and the Platform, the “Services”).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.
By accepting this Privacy Policy, accessing and/or using any Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by the Privacy Policy. If you are accepting this Privacy Policy on behalf of your employer or another organization, you hereby certify that you are authorized to bind such party to the terms of the Privacy Policy. If you do not agree to (or cannot comply with) all of the terms of the Privacy Policy, then you may not access or use the Services. This policy may change from time to time. Your continued use of the Site or Digital Properties after we make changes is deemed to be acceptance of those changes. So, please check the policy periodically for updates.
Capitalized terms that are not defined in the Privacy Policy have the meaning given them in the Terms of Use. By accessing and or using the Services, you signify that you have read, understood, and agree to be bound by this privacy policy, including our Terms of Use which are incorporated herein by reference.

Important Notice to Residents of Certain US States:
California Residents: You may have additional rights regarding your personal information under the California Privacy Rights Act. Please review the CPRA Privacy Notice for further information(https://oag.ca.gov/privacy/ccpa).
Virginia, Connecticut, Utah and Colorado Residents: You may have additional rights regarding your personal information under the consumer privacy acts in your states. Please review your state consumer privacy laws for further information.
Nevada Residents: You may have additional rights regarding your personal information under the Nevada Revised Statutes. Please review Section VIII of the Nevada Privacy Policy for further information.

Important Notice to Residents of the European Union and or the United Kingdom:
You may have additional rights regarding your personal information under the General Data Protection Law. Please review the GDPR Privacy Notice for further information. This Privacy Policy will help you understand the following:

The Information we Collect
In the course of providing the Services, we may collect or receive the following types of information about you, which may include personal information.
Contact Information:
We collect information through our Services, which may include your name, email address, phone number, business contact data (such as title, company name, office phone number and company email address), and any information you provide in messages to us (“Contact Information”). We use Contact Information for purposes such as providing you with information about the Services, responding to your inquiries, providing our newsletters, sending you email alters (including marketing emails), and or providing you with the Services.

Information You Provide
Account Information: Certain Services may require that you register for an account (“Account”) with Pality which may require that you provide certain information in addition to Contact Information. If your Account is approved, you will be required to enter into certain Commercial Agreements with Pality to access and use the Services.

Billing Information
If you enter into a Commercial Agreement for the purchase of Paid Services, you will be required to provide a third-party with your billing information, including, without limitation, bank account numbers, credit card or debt card numbers, account detail ACH information, and similar data (collectively, “Billing Information”) and such Billing Information will be collected and processed by our third-party payment processor pursuant to the terms and conditions of their privacy policies and terms of use. We do not directly obtain, store or process and Billing Information.

Communications
You agree that Pality is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques or know-how disclosed therein, for any purpose including improving and developing the Services, without compensation or attribution to you.

Other Information
You may voluntarily provide additional information to us by entering a contest, promotion, or sweepstakes sponsored by us, or completing surveys for marketing and research, or other purposes, or contacting us for additional information (using forms on our Digital Properties, via email or otherwise). All information collected from your participation in the foregoing is provided by you voluntarily. We may use such information to improve our Digital Properties and or Services, and otherwise in accordance with this Privacy Policy and , as applicable, our Subscription Services Agreement and or Trial Agreement.

Information Obtained Automatically from Your Online Activity
When you access or use any of our Services, we may use browser cookies, pixels, web server logs, web beacons, and similar technologies (collectively, “Tracking Technologies”) to recognize you, save your preferences, customize your experience, and service advertisements. The Tracking Technologies also automatically collect or receive certain standard technical information and other data (such as IP address, the URLs of sites you visit and use to access our Site, browser type and language, access times, operating system, mobile provider, mobile device, your ISP, traffic data, location data, logs and other communications data) sent by your computer, mobile device, tablet, or any other device over time on our Digital Properties, and track your online activity across their party websites, apps, and devices. We may use such information to better understand how users navigate our Digital Properties, provide and administer the Services, analyze trends, prevent fraud, and gather broad demographic information. Pality may also evaluate your computer, mobile phone or other access device to identify and malicious software or activity that may affect the availability of the Services.

When you access or use any of the Services, advertising companies, analytics networks and providers, and other third parties may also use Tracking Technologies to monitor information related to served advertisements (which may include advertisements for their party products/services), to evaluate and improve targeted advertising, and collect information about your online activities over time on our Digital Properties and across different websites, apps, online services, digital properties and devices.

The data we or third parties collect automatically is typically statistical data that may not identify you personally, however, we or third parties may maintain, associate and or combine it with personal information collected in other ways or received from third parties. We and third parties use this information to (i) personalize your experience wih the Services, understand how you use the Services, maintain a persistent session, and improve and further develop our Services, and (ii) serve targeted and other advertising and provide custom experiences, across other sites, apps, online services sigital properties and devices.

Cookies (browser cookies) a commonly used Tracking Technology, consist of small packets of data that a website or device stores on browser, hard drive or device so that your device will remember information about your visit. In addition to collecting information, cookies are used to help authenticate users, provide content of interest to you, analyze which features you use more frequently, and measure and optimize advertising and promotional effectiveness. To do this, we or third parties may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. The Privacy Policy only covers the use of cookies and other Tracking Technologies by Pality. Any use of cookies and other Tracking Technologies on our Digital Properties and elsewhere by third parties (and the data collected) is governed by their own privacy policies that Pality does not control.

If you do not want cookies placed on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this. We and third parties may also use (i) flash cookies (local stored objects) to collect and store information about your preference and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings that are used for browser cookies; and (ii) web beacons (small electronic files, also referred to as clear gifs, pixel tags, and single-pixel gifs) to count users who have visited pages on our Digital Properties, or for other related statistics, such as recording the popularity of certain content and verifying system and server integrity. If you decide not to accept cookies or other Tracking Technologies, the Services may not function properly.

De-Identified Information. Pality also may use and combine personal information and other information about you to create anonymized, de-identified, and or aggregated information (“de-identified information”), such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Pality’s Services, or other analyses we create. Pality may use de-identified information for any legally permissible purpose including research and analytics and share it with our affiliates and subsidiaries and with their parties for our or their purposes.

Information Obtained from Other Sources
Social Media: We maintain a presence on Instagram and YouTube and other social media and third-party sites, including maintaining accounts, pages and related activities. We may collect personal information when you visit or use social media, including when you access our Services from social media. We will do so in accordance with the terms of use and privacy policies of those sites, apps and applicable law. For example, we may collect the information you shared on our social media pages through an application or form, which will have a link to this Privacy Policy. Personal information may also be collected by the their-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. Overall, this information may be used to help us understand the types of visitors and users of our social media pages and use of the content. This Privacy Policy does not cover personal information collected by such their-party social media sites. For more information on their privacy and security practices please review the privacy policies and terms of use on their respective websites.

Information Obtained from Third Party Analytics Services
We use third-party analytics services to evaluate your access and use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to device and internet usage such as: the type of device, the advertising identifier, the operating system and version, carrier and network type; IP addresses (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device); browser type and language, referring and exit pages and URLs; data and time of access; the content viewed, the amount of time spent on particular pages; what features of the Services are used or visited; details of any purchases; click stream information; and precise geolocation data. These third-party analytics services use cookies and other Tracking Technologies to collect, analyze and provide us with the data and related analytics. By accessing or using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For purposes of this Privacy Policy, “process” or “processing” means any operation which is performed upon personal information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alternation, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. The information used by such analytics services is generally at the aggregate level.

We may add to or change these third-party analytics services from time to time. For more information on our analytics services, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.
Google Analytics: https://www/google.com/analytics
Mixpanel: https://mixpanel.com
Sanity: https://www.sanity.io/plugins/sanity-plug-in-google-analytics

Data Retention
Pality retains the personal information we receive as described in this Privacy Policy for as long as necessary to fulfill the purposes for which it was collected, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

How we use and share information.
We may use and share your personal information as set forth below:
To operate our business and provide the Services;
To monitor, support analyze, customize and improve the Services;
To communicate with you regarding the Services and your purchase history;
To provide you with a safe, smooth, efficient and customized experience;
To provide customer support you request with respect to the Services and your purchases;
To troubleshoot problems and prevent potentially prohibited or illegal activities;
To tell you about and administer service updates, contests, sweepstakes, rewards, and promotional offers based on your communication preferences;
To conduct and administer surveys;
To monitor and enforce our Terms of Use;
To communicate with you about third-party products and or services you may be interested in;
To fulfill your requests for information regarding new or improved products and services;
To engage in marketing, advertising, and tracking activities, targeted advertising, and to evaluate the efficacy of our efforts, provided that, where required under applicable law, we will obtain your prior opt-in consent to send electronic marketing communications and or our newsletter;
To engage research, project planning, troubleshooting problems, and detecting and protecting eagainst error, fraud, or other criminal activity.
To protect the safety and security of our Services, and our business;
To investigate fraud, intellectual property infringement, piracy, or other unlawfiul activity;
To our promotional partners so they can offer you special products, services, discounts, tickets and other items;
To our business partners, parent company, affiliates, and subsidiaries for our and their business purposes such as jointly offering products/services;
To their-party contractors and service providers that provide services to us in the operation of our business and assistance with the Services, such as marketing and advertising companies, consulting service organizations, IT and cloud service providers, payment processing, and customer service;
To process and disclose de-identified data to our affiliates, agents, business partners, and other third parties for lawful purposes;
To share with our parent company, subsidiaries, affiliates and of other companies under common control with us;
To fulfill our legal and regulatory requirements, enforce our Terms of Use, Subscription Services Agreement and or Trial Agreement and other rights;
To comply with applicable laws, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and
To assess or complete a corporate sale, merger, reorganization, sales of assets, dissolution, investment, or similar corporate event where we expect that your personal information will be part of the transferred assets; and Otherwise with your consent.
We will take reasonable measures (such as by contract) to require that any party receiving any of your personal information from us for purposes of providing the Services agrees to (i) process such information only for the purposes of providing or assisting us provide the Services; (ii) not disclose your personal information except with your consent, as permitted by applicable lay, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.

Accessing and Modifying Information and Communication Preferences
If the personal information we have for you changes, or if you no longer desire our Services, you may contact us at solutions@pality.com.
You cannot opt out of receiving transactional emails. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” hyperlink located on the bottom of any of our marketing emails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases if links were clicked.

How We Protect your Information
We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the internet. In particular, email sent to or from the Services may not be secure, and you should therefore take special care in deciding what information you send to us via email.

Children
We do not knowingly collect personal information from any person under the age of 18. If an individual under the age of 18 has provided us with personal information, a parent or guardian of that child may contact us and request that such information be delete and we will endeavor to delete that information from our databases. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. Please see your state’s privacy laws for more information.

External Websites and Third Parties
Unless explicitly stated otherwise, our Privacy Policy addresses only our use and disclosure of information we collect from and or about you in your interactions with Pality and the Services. If you choose to disclose information to third parties, the use and disclosure restrictions contained in this Privacy Policy will not apply, as we do not control the privacy policies of such third parties, nor are we subject to them.
The Services may also contain hyperlinks to third-party websites, apps or advertisements (“External Websites”) including, for example, opportunities to purchase third party products or services that are offered and provided by independent companies, If you click on a link for any External Site, you will be redirected to a third-party site. The information collected by such third parties or that you choose to provide is governed by the third-party site’s privacy policy and practices. We have no control over the privacy policies or practices, the content, or the products and services of any External Websites we provide or allow hyperlinks on our Services including but not limited to our business partners, advertisers, and sponsors. As such, we are not responsible for the content or the privacy policies of those External Websites. You should check the applicable third-party privacy policy and terms of use when visiting any External Websites.

Do Not Track
We do not monitor, recognize, or honor any opt-out or do-not-track mechanisms, including general web browser “do not track” settings and or signals.

Notice to Nevada Residents
We do not sell your personal information as defined under Nevada law.

Important Notice to non-US Residents
The Services are operated in the United States. If you are located outside of the United States, please be aware that any information we collect or receive may be transferred and or processed in the United States and any other jurisdiction where Pality conducts business, where the data protection laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to access or use the Services, you consent to any transfer and or processing of your personal information in any such jurisdiction in accordance with this Privacy Policy, and you do so at your own risk.

Updates to this Privacy Policy
This Privacy Policy is effective as of the data stated at the top of this Privacy Policy. We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing any of the Services after we change this Privacy Policy, you are deemed to have accepted such changes.

How to Contact Us
If you have any questions or comments about this Privacy Policy or our privacy practices, please click on the Contact Us link on the bottom of any page on this website.