- “Non-personal Information” is non-identifiable information that cannot be reasonably used to identify or contact you. As such, we are not aware of the identity of the user from which the Non-Personal Information was collected.
- Aggregated Information: Our servers automatically record certain information regarding the use of the Service. Such information includes information such as the website that a User was visiting before accessing to our Webpage and other statistics related to our Services. We analyze this information to improve and enhance the Services by expanding their features and functionality. Such information is also used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
- Anonymous Information: We anonymize information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we disclose it to others in our sole discretion.
Legal Basis
The Company processes Personal Information for the performance of the Services, and for its risk and compliance processes, in accordance with our agreement with you on the entity on behalf of which you were authorized to use the Service, and to improve our Services in accordance with our legitimate business interest.
Do We Use Cookies and Pixels?
We and our partners (e.g. third-party service providers, third- party analytic companies, etc.) use cookies and pixels, including when you visit our Website or access the Services.
A “cookie” is a small piece of information that a website assigns to your device while you are viewing the website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages of the website efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of the Services.
We use the following types of cookies:
- ‘Session cookies’ which are stored temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
- ‘Persistent cookies which are saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, to store your preferences for the next log-in and to improve our users’ experience of the Services;
- ‘Third party cookies’ which are set by other websites or services that run content on the page you are viewing, such as by third party analytic companies who monitor and analyze your web access.
By accessing and using the Services, you consent to the placement of cookies and pixels on your device in accordance with this Privacy Policy.
You can remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of the Services will not operate properly and your online experience can be limited.
How Do We Use Personal Information Related to You?
In addition to the purposes listed herein, the information we collect, which includes Personal Information related to you, is used for the following purposes:
- To set up Customers’ accounts and process their related billing information;
- To complete our AML, KYC and other compliance and risk evaluations;
- To identify and authenticate Users’ access to our Services;
- To provide you with the information and services that you request from us;
- To support and troubleshoot our Services and to respond to queries;
- To obtain Users’ feedback with regard to the Services;
- To improve and customize our Services to Customer’s needs and interests;
- To empower our learning system, which performs statistical analysis on all the data and metadata which is collected through our Services;
- To communicate with you and to keep you informed of our latest updates and newsletters;
- To calculate various payment aspects of the Service;
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With Whom Do We Share Personal Information Related to You?
We do not rent or sell any Personal Information related to you. We disclose Personal Information related to you to other trusted third- party service providers or partners for the following purposes:
- Assisting us with our business operations (e.g., issuing credit cards and processing transactions);
- Storage (e.g., our cloud computing service providers);
- Research and analytics that will enable us to improve our Services;
- If we have a good faith belief that disclosure of such Personal Information related to you is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; and/or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
In addition, we will transfer or disclose Personal Information related to you to our subsidiaries and other affiliated companies, as necessary.
We will also share information, including Personal Information related to you, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will respect the rights and obligations as described in this Privacy Policy.
Do We Transfer Personal Information Related to You?
Since we operate globally, it can be necessary to transfer information, including Personal Information related to you, to countries outside the United States of America.
We will take steps to ensure that a similar level of protection is given to Personal Information related to you, as applicable.
You hereby consent to the transfer of Personal Information related to you to countries outside the United States of America.
What Are Your Privacy Rights?
You can contact us at any time and request:
- To access, delete, change, amend, or update any Personal Information related to you (for example, if you believe that Personal Information related to you is incorrect);
- That we will cease any further use of Personal Information related to you, to the extent permitted by applicable law.
If you wish to raise a complaint on how we have handled Personal Information related to you, you can contact our privacy champion who will investigate the matter, available at the following email address [email protected].
If you are not satisfied with our response or believe we are collecting or processing Personal Information related to you not in accordance with applicable laws, you can complain to the applicable data protection authority.
If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of Personal Information relating third- parties to which we have disclosed certain categories of Personal Information related to you during the preceding year for the third parties’ direct marketing purposes. To make such a request, please contact us at [email protected].
In addition, as a California resident, the California Consumer Privacy Act (“CCPA”) can apply to you, and, if so, the information, rights, and obligations stated in Exhibit A will also apply to you in relation to the Services.
For How Long Do We Retain Personal Information Related to You?
We retain Personal Information related to you for as long as needed to provide our Services, improve our operations and functionality and comply with our legal obligations, as well as resolve, disputes, and enforce our agreements (unless we are instructed otherwise). Under applicable regulations, we may keep records containing Users’ Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations for as long as needed.
How Do We Safeguard Personal Information Related to You?
We take great care in implementing and maintaining the security of our Services and Personal Information related to you. We employ industry standard procedures to ensure the confidentiality, integrity, availability, and safety of Personal Information related to you, and prevent unauthorized use of Personal Information related to you.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information related to you despite our efforts. You should note that by using our Services, Personal Information related to you will be transferred through third- party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information related to you, we cannot guarantee its absolute security. If we discover that Personal Information related to you is accessed by unauthorized entities, we will seek to notify you in compliance with the applicable law.
If you feel that your privacy was treated not in accordance with this Privacy Policy, please contact us directly at [email protected].
Marketing
We may use Personal Information related to you, such as your full name and email address, directly or by using our third-party subcontractors for the purpose of providing you with promotional materials concerning our Services.
We provide you within such marketing materials with means to decline receiving further marketing offers from us (an opt-out mechanism). In addition, at any time, you can request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to [email protected].
Please note that even if you unsubscribe from our marketing mailing list, we will continue to send you service-related updates and notifications to provide you with the Services and/or comply with applicable laws.
Minors
The Services are not designated to individuals under the age of 18. If you are under 18 you should not use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information which is collected from you by us. In the event that we become aware that an individual under the age of 18 shared any information, we will make commercially reasonable efforts to discard such information.
If you have any reason to believe that a minor shared any information with us, please contact us at [email protected].
Updates and Amendments
We can revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Website.
We encourage you to review this Privacy Policy regularly for any changes. In case of material changes we will notify you through our Services or via an email message.
Your continued use of the Website and/or Services, following the notification of such amendments on our Website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
Contact Us
If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at [email protected]. The details of the Company are as follows: 980 North Federal Highway, Suite 110, Boca Raton, FL 33432
Exhibit A – CCPA
Categories of Personal Information Related to You
The Company has collected the following categories of Personal Information related to you from consumers within the last twelve (12) months:
- Identifiers such as your real name, online identifier Internet Protocol address, cellphone number, and email address.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as address, credit card number, and billing details.
- Your Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application or advertisement.
- Inferences drawn from any of the information identified to create a profile about you which reflects your preferences, characteristics, behavior, attitudes, intelligence and abilities.
In the preceding twelve (12) months, the Company has disclosed the categories of Personal Information related to you for business purposes to vendors, service providers and partners, as further described in this Privacy Policy.
The Company collects and uses Personal Information related to you in order to provide you with the Services and shares Personal Information related to you as indicated in this Privacy Policy.
The CCPA further provides you with the following privacy rights about Personal Information related to you, as follows –
Access to Specific Information and Data Portability Rights
You have the right to request that the Company will disclose certain Personal Information related to you about our collection and use over the past 12 months. Following our confirmation of your request, we will disclose to you –
- The categories of Personal Information related to you we have collected.
- The categories of sources for the Personal Information related to you we have collected.
- Our business and commercial purposes for collecting such Personal Information related to you.
- The categories of third parties with whom we have shared such Personal Information related to you.
- The specific pieces of Personal Information related to you we have collected.
If we disclose Personal Information related to you for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.
Deletion Request Rights
To the extent applicable, you have the right to request that we delete any of Personal Information related to you that we have collected from you.
Upon confirmation of your request, we will delete – and direct our service providers to delete – Personal Information related to you from our records, unless retaining the information is necessary for us or for our service providers to complete the transaction with you, detect security incidents, identify and repair errors, exercise free speech, or another right provided by law, comply with specific laws or legal obligations or any other internal and lawful use.
Exercising Access and Deletion Rights
In order to exercise your access, data portability, and deletion privacy rights, as described above, please submit a request here or email us to [email protected].
Only you or a person authorized to act on your behalf, can make a request related to Personal Information related to you. You can also submit a request on behalf of your minor child. Please note that a request for access can be made by you only twice within a 12-month period.
We will need to ask you to provide us with credentials to verify your identity or authority, address your request, and confirm the Personal Information related to you. Note that we will only use the Personal Information related to you provided in your request to verify your identity or authority and address your request.
We will do our best to respond to your request within 45 days of its receipt. If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding receipt of your request.
The response we provide will also explain the reasons we cannot comply with a request, where applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.
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