Privacy Policy

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Last Updated: January 12, 2026

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1. INTRODUCTION

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This Privacy Policy describes how Vertus Limited ("Vertus,""we," "us," or "our"), a company incorporated inthe Isle of Man, collects, uses, stores, shares, and protects information about you when you use our website (vertus.ai), mobile applications, APIs, artificialintelligence systems, and related services (collectively, the"Services").
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This Privacy Policy is incorporated into and forms part of our Terms of Service. By using the Services, you consent to the data practices described in this Privacy Policy.

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IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, DO NOT USE THE SERVICES.

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2. INFORMATION WE COLLECT

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2.1 Information You Provide Directly

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Account Information:

• - Name, email address, phone number
• - Username and password
• - Billing and payment information
• - Identity verification documents (if required)
• - Company information (for business accounts)
• - Tax identification numbers (where required)
• - Communications preferences

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Profile and Preferences:

• - Trading preferences and settings
• - Risk tolerance information
• - Investment goals and interests
• - Language and timezone preferences
• - Notification settings
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Communications:

• - Messages you send to us
• - Customer support inquiries
• - Feedback, surveys, and testimonials
• - Information provided during onboarding

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2.2 Information Collected Automatically

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Usage Data:

• - Pages viewed and features accessed
• - Time, frequency, and duration of use
• - Click patterns and navigation paths
• - Search queries and commands
• - AI interactions and prompts
• - API calls and responses
• - Error logs and debugging information
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Device and Technical Information:

• - IP address and geolocation data
• - Device type, model, and operating system
• - Browser type and version
• - Screen resolution and display settings
• - Network connection type
• - Device identifiers and cookies
• - Time zone and language settings
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Performance and Analytics:

• - Service performance metrics
• - Load times and response times
• - Error rates and system failures
• - Feature usage statistics
• - A/B test assignments

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2.3 Financial and Trading Data

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When you connect third-party accounts or use our Services:

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Trading Activity:

• - Trade executions and orders
• - Portfolio holdings and positions
• - Transaction history
• - Trading strategies and patterns
• - Account balances and values
• - Profit and loss data
• - Risk metrics and exposures

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Account Connection Information:

• - Broker and exchange account credentials (encrypted)
• - API keys and access tokens
• - Account identifiers
• - Authorization permissions

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Market Data Usage:

• - Securities and assets you research
• - Watchlists and alerts
• - Market data queries
• - Price feeds accessed

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2.4 AI and Machine Learning Data

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AI Interaction Data:

• - Prompts, queries, and commands given to AI
• - AI responses and outputs
• - Training and feedback provided
• - Model parameters and settings
• - Performance and accuracy metrics
• - Usage patterns with AI systems

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Training Data:

• - All data collected may be used for AI training and improvement
• - Historical trading decisions and outcomes
• - User behavior patterns
• - Aggregate performance data

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2.5 Information from Third Parties

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Regulated Entities:

• - Information provided by Regulated Entities through which you access our technology
• - Compliance and regulatory information
• - Account verification data
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Brokers and Exchanges:

• - Account verification status
• - Trading permissions and restrictions
• - Account activity and history

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Service Providers:

• - Payment processors
• - Identity verification services
• - Analytics providers
• - Cloud infrastructure providers

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Public Sources:

• - Publicly available information about your business
• - Regulatory filings and registrations
• - Sanctions and watchlist screening results

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3. HOW WE USE YOUR INFORMATION

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3.1 Providing and Improving Services

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We use your information to:

• - Create and maintain your account
• - Provide access to the Services
• - Process transactions and payments
• - Connect to your third-party accounts
• - Execute AI-driven actions (with your authorization)
• - Provide customer support
• - Send service-related communications
• - Personalize your experience
• - Develop new features and functionality
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3.2 AI Training and Development

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IMPORTANT: We use data collected from your use of the Services to train, improve, and develop our artificial intelligence systems and machine learning models.

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This includes:

• - Training AI models on historical data
• - Testing and validating AI performance
• - Improving prediction accuracy
• - Developing new AI capabilities
• - Conducting research and development
• - Creating anonymized training datasets
• - Benchmarking and performance analysis

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You acknowledge and consent that your trading data, usage patterns, and interactions may be incorporated into our AI training processes.

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3.3 Security and Fraud Prevention

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We use information to:

• - Detect and prevent fraud and abuse
• - Verify identity and authentication
• - Monitor for suspicious activity
• - Investigate security incidents
• - Enforce our Terms of Service
• - Protect against unauthorized access
• - Conduct security audits
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3.4 Analytics and Research

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We use information to:

• - Analyze usage patterns and trends
• - Measure feature adoption and engagement
• - Conduct internal research
• - Generate aggregate statistics
• - Evaluate service performance
• - Understand user preferences
• - Improve algorithms and systems

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3.5 Legal and Regulatory Compliance

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We use information to:

• - Comply with legal obligations
• - Respond to lawful requests from authorities
• - Enforce our legal rights
• - Prevent illegal activities
• - Maintain records as required by law
• - Conduct anti-money laundering (AML) checks
• - Perform sanctions screening

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3.6 Communications

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We may use your information to send you:

• - Service announcements and updates
• - Security alerts and notifications
• - Administrative messages
• - Customer support responses
• - Marketing communications (with your consent)
• - Product updates and new features
• - Surveys and feedback requests

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You can opt out of marketing communications at any time.

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4. HOW WE SHARE YOUR INFORMATION

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4.1 We Do Not Sell Personal Data

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Vertus does not sell, rent, or trade your personal information to third parties for their marketing purposes.

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4.2 Sharing with Your Consent

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We may share information when you explicitly authorize us to do so, including:

• - When you connect third-party accounts
• - When you access Services through a Regulated Entity
• - When you authorize integrations with third-party services
• - When you request customer support through third-party channels

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4.3 Regulated Entities and Partners

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We may share information with:

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Regulated Entities: When you access Vertus technology through a licensed asset manager, broker-dealer, or financial institution, we share relevant information with that Regulated Entity to provide the Services.

Technology Partners: We share necessary information with technology partners who help us provide the Services, subject to confidentiality obligations.

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4.4 Service Providers

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We share information with third-party service providers who perform services on our behalf, including:

• - Cloud infrastructure providers (servers, storage)
• - Payment processors and billing services
• - Customer support platforms
• - Analytics and monitoring services
• - Identity verification services
• - Email and communication services
• - Security and fraud prevention services

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These providers are contractually obligated to use your information only to provide services to us and to protect your information.

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4.5 Aggregated and Anonymized Data

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We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you, including:

• - Market research and industry statistics
• - Performance benchmarks
• - Usage trends and patterns
• - Research publications
• - Training datasets for AI development

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4.6 Business Transfers

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If Vertus is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our website of any change in ownership or use of your personal information.

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4.7 Legal Requirements

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We may disclose information when we believe in good faith that disclosure is necessary to:

• - Comply with legal obligations, court orders, or subpoenas
• - Enforce our Terms of Service or other agreements
• - Protect the rights, property, or safety of Vertus, our users, or the public
• - Investigate fraud, security issues, or technical problems
• - Respond to lawful requests from public authorities
• - Comply with national security or law enforcement requirements

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5. DATA RETENTION

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5.1 Retention Period

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We retain your information for as long as necessary to:

• - Provide the Services to you
• - Comply with legal obligations
• - Resolve disputes and enforce agreements
• - Train and improve our AI systems
• - Maintain business records
• - Protect against fraud and abuse

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5.2 Specific Retention Periods

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Active Accounts: Information is retained while your account is active and as needed to provide Services.

Inactive Accounts: After account closure or extended inactivity, personal information may be retained for:

• - Up to 7 years for financial and transactional data (to comply with regulations)
• - Up to 10 years for dispute resolution purposes
• - Indefinitely for anonymized training data

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AI Training Data: Data incorporated into AI training datasets may be retained indefinitely in anonymized form.

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5.3 Deletion Rights

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Subject to legal and operational requirements, you can request deletion of your personal information. However:

• - We may retain certain information to comply with legal obligations
• - Anonymized data used in AI training may not be retrievable
• - Backups may contain information for limited periods
• - Some information may be retained for fraud prevention

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6. DATA SECURITY

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6.1 Security Measures

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We implement industry-standard security measures to protect your information, including:

• - Encryption of data in transit (TLS/SSL)
• - Encryption of sensitive data at rest
• - Secure authentication and access controls
• - Regular security audits and testing
• - Network security and firewalls
• - Intrusion detection and prevention systems
• - Secure coding practices
• - Employee training on data protection

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6.2 Account Security

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You are responsible for:

• - Maintaining the confidentiality of your credentials
• - Using strong, unique passwords
• - Enabling two-factor authentication (where available)
• - Keeping your contact information current
• - Promptly notifying us of unauthorized access
• - Securing your devices and networks

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6.3 No Guarantee of Security

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Despite our security measures, no system is completely secure. We cannot guarantee the absolute security of your information. Transmission of data over the internet is inherently risky, and you use the Services at your own risk.

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6.4 Breach Notification

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In the event of a data breach that compromises your personal information, we will notify you:

• - Without undue delay
• - As required by applicable law
• - Via email or prominent notice on our website
• - With information about the breach and protective measures you can take

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7. YOUR RIGHTS AND CHOICES

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7.1 Access and Portability

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You have the right to:

• - Access personal information we hold about you
• - Request a copy of your data in a structured format
• - Receive information about how your data is used

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7.2 Correction and Update

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You have the right to:

• - Correct inaccurate personal information
• - Update your account information
• - Complete incomplete information

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7.3 Deletion and Erasure

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You have the right to request deletion of your personal information, subject to:

• - Legal and regulatory retention requirements
• - Legitimate business purposes
• - Ongoing disputes or investigations
• - Technical limitations with AI training data

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7.4 Objection and Restriction

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You have the right to:

• - Object to processing of your personal information
• - Request restriction of processing in certain circumstances
• - Withdraw consent for specific data uses
• - Opt out of marketing communications

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7.5 Automated Decision-Making

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When we use automated decision-making or AI systems that significantly affect you, you have the right to:

• - Request human review of automated decisions
• - Challenge decisions made solely by AI
• - Receive an explanation of AI decision-making (where possible)

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7.6 How to Exercise Your Rights

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To exercise any of these rights, contact us at: privacy@vertus.ai

We will respond to your request:

• - Within 30 days (or as required by applicable law)
• - After verifying your identity
• - Free of charge for the first request
• - With an explanation if we cannot fulfill your request

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8. INTERNATIONAL DATA TRANSFERS

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8.1 Location of Processing

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Vertus is based in the Isle of Man. Your information may be transferred to, stored in, and processed in:

• - The Isle of Man
• - The United Kingdom
• - The European Union
• - The United States
• - Other countries where our service providers operate

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8.2 Transfer Safeguards

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When we transfer information internationally, we implement appropriate safeguards, including:

• - Standard contractual clauses
• - Adequacy decisions by regulators
• - Privacy Shield principles (where applicable)
• - Binding corporate rules
• - Your explicit consent

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8.3 Different Privacy Standards

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Countries outside your jurisdiction may have different data protection standards. By using our Services, you consent to international transfers of your information.

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9. COOKIES AND TRACKING TECHNOLOGIES

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9.1 Use of Cookies

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We use cookies and similar tracking technologies to:

• - Maintain your session and login status
• - Remember your preferences and settings
• - Analyze usage and performance
• - Provide personalized content
• - Detect and prevent fraud
• - Measure marketing effectiveness

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9.2 Types of Cookies

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Essential Cookies: Required for the Services to function properly. Cannot be disabled.

Functional Cookies: Enhance functionality and personalization. Can be disabled.

Analytics Cookies: Help us understand how you use the Services. Can be disabled.

Marketing Cookies: Used for targeted advertising (if applicable). Can be disabled.

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9.3 Cookie Management

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We use a third-party cookie consent management platform to manage your cookie preferences. When you visit our website, you can:

• - Accept or reject different categories of cookies
• - Change your preferences at any time
• - Access detailed information about specific cookies

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You can also control cookies through your browser settings, though this may affect Service functionality.

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9.4 Other Tracking Technologies

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We may also use:

• - Web beacons and pixel tags
• - Local storage and IndexedDB
• - Mobile device identifiers
• - Fingerprinting techniques (limited use)
• - Session replay tools (with proper notice)

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10. THIRD-PARTY SERVICES AND LINKS

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10.1 Third-Party Services

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The Services may integrate with third-party services, including:

• - Brokerage accounts and exchanges
• - Payment processors
• - Identity verification services
• - Analytics platforms
• - Cloud infrastructure
• - Social media platforms

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Each third-party service has its own privacy policy. We are not responsible for their privacy practices.

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10.2 Third-Party Links

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Our Services may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. Review their privacy policies before providing information.

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10.3 Social Media Features

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Our Services may include social media features (e.g., share buttons). These features may collect your IP address and set cookies. They are governed by the privacy policies of the social media companies.

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11. CHILDREN'S PRIVACY

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The Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.

If you believe a child under 18 has provided us with personal information, please contact us immediately at privacy@vertus.ai, and we will take steps to delete such information.

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12. CALIFORNIA PRIVACY RIGHTS

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If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including:

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12.1 Right to Know

• - Categories of personal information collected
• - Sources of personal information
• - Business purposes for collection
• - Categories of third parties with whom information is shared
• - Specific pieces of personal information collected

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12.2 Right to Delete

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Request deletion of personal information we have collected, subject to exceptions.

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12.3 Right to Opt-Out

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We do not sell personal information. If this changes, we will provide an opt-out mechanism.

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12.4 Right to Non-Discrimination

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You have the right to not receive discriminatory treatment for exercising your CCPA rights.

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12.5 Exercising California Rights

To exercise these rights, contact us using our contact form.

We will verify your identity before responding to requests.

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13. EUROPEAN PRIVACY RIGHTS (GDPR)

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If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

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13.1 Legal Basis for Processing

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We process personal data based on:

• - Contract: Necessary to provide the Services
• - Legitimate Interests: To improve Services and ensure security
• - Consent: Where you have given explicit consent
• - Legal Obligation: To comply with laws and regulations

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13.2 Your Rights

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Under GDPR, you have the right to:

• - Access your personal data
• - Rectify inaccurate data
• - Erase data ("right to be forgotten")
• - Restrict processing
• - Object to processing
• - Data portability
• - Withdraw consent
• - Lodge a complaint with a supervisory authority

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13.3 Supervisory Authority

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You have the right to lodge a complaint with your local data protection authority. For Isle of Man users, the relevant authority is the Isle of Man Information Commissioner.

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14. CHANGES TO THIS PRIVACY POLICY

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14.1 Updates

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We may update this Privacy Policy from time to time to reflect:

• - Changes in our practices
• - New legal requirements
• - Technological developments
• - User feedback

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14.2 Notification of Changes

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We will notify you of material changes by:

• - Posting the updated Privacy Policy on our website
• - Updating the "Last Updated" date
• - Sending email notifications (for significant changes)
• - Providing prominent in-app notices

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14.3 Continued Use

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Your continued use of the Services after changes constitutes acceptance of the updated Privacy Policy. If you do not agree to changes, you must stop using the Services.

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15. CONTACT US

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15.1 Privacy Inquiries

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For questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us using our contact form.

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15.2 Data Subject Requests

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To exercise your privacy rights (access, deletion, correction, etc.), please use the subject line: "Privacy Rights Request" and include:

• - Your full name
• - Email address associated with your account
• - Description of your request
• - Verification information (we may request additional proof of identity)

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We will respond within 30 days (or as required by applicable law).

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BY USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED HEREIN.

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