PRIVACY AND COOKIES POLICY

Invalert LLC

Last Updated on September 16, 2020

This Privacy and Cookies Policy (“Policy”) describes the treatment of information provided or collected on our website (https://www.invalert.com/) and the Invalert mobile app (collectively, the “Platform”). The purpose of this Policy is to describe how the Platform collects, uses, shares and secures Personal Information (as defined herein) provided by you. Therefore, before you provide Invalert LLC ("Invalert", “Company” “we” or “us”) with any Personal Information, you should read through this Policy in its entirety and understand its terms. We may update this Policy from time to time, so please check in occasionally.

In this Policy, "Personal Information" means any information relating to an identified or identifiable individual, such as name, address, e-mail, phone number, location, credit or debit card information, or anything other information that may be used to identify an individual.

1. COLLECTION OF PERSONAL INFORMATION
2. USE OF PERSONAL INFORMATION
3. USE OF PERSONAL INFORMATION OF RESIDENTS IN EEA
4. SHARING OF PERSONAL INFORMATION
5. COOKIES
6. DATA PROTECTION RIGHTS FOR RESIDENTS IN EEA
7. DATA SECURITY
8. YOUR CONTROLS AND CHOICES
9. CHANGES TO THIS POLICY
10. NOTICE TO CALIFORNIA RESIDENTS
11. CHILDREN UNDER 13
12. MISCELLANEOUS ISSUES
13. CONTACT US

1. COLLECTION OF PERSONAL INFORMATION:
You will be asked to provide us Personal Information when signing up or registering our Platform or otherwise using our Platform. It is your choice whether to provide us with Personal Information. If you do not provide Personal Information when requested, you will not be able to benefit from our Platform or our services if that information is necessary to provide such services.

In most cases, we collect Personal Information directly from you. However, we may also obtain Personal Information about you from third parties (such as Twitter, Telegram Stripe or Coinbase) or automatically when you interact with our Platform. Please keep in mind that when you provide any information to us on a third-party site or platform (e.g. Twitter, Telegram, Stripe or Coinbase), that any information you provide may be separately collected by the third-party site or platform and subject to the third-party site or platform’s privacy practices.

Below is a description of the different types of Personal Information we process and the sources from which we obtain them:

* Subscribers/users to our Platform. If you are a subscriber/user of our Platform, we collect your name, email, password, Telegram username, country located and any other information you provide to us, and we may also obtain from third parties other Personal Information when providing services to you, such as your account name/username, profile, photos or messages posted or sent on a third-party site or platform like Twitter, Telegram, Stripe, or Coinbase.

* Member of Telegram group. If you join us as a member of our Telegram group-“Invalert Crypto Alerts” (as amended), to receive our real-time electronic alerts on trading information and news in crypto market, we will obtain certain Personal Information from you, such as your first and last name, location, Telegram account information, profile photos and messages you sent within Telegram group.

* Communications. If you choose to contact us for any purpose, we will collect your contact details, your name, and the content, date and time of your message, as well as our reply and any follow up action we take in relation to your inquiry.
* Device data. We may receive usage, viewing and technical data, including your device identifier or IP address, type of device you use, or operating system version, when you visit our Platform. We may use mobile or website analytics software to better understand the functionality of our Platform on your device. This software may record information such as how often you use the Platform, the events that occur within the Platform, aggregated usage, performance data, and from where the Platform was downloaded.

* Other sources. We may receive Personal Information about you from other sources, including third parties that help us identify new users, process payments (e.g. Stripe and Coinbase), or prevent or detect fraud. We may also receive information about you from social media platforms (e.g. Twitter) when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the relevant social media platform, and we encourage you to review them.

2. USE OF PERSONAL INFORMATION:
We use your Personal Information for the follow purposes:

* To provide services to our subscribers, including to send you electronic alerts on trading information and news in cryptocurrency market (including uptrend/downtrend, price, stop-loss price, target prices, names of investment assets, and names of markets, etc.), to provide you with information regarding cryptocurrency markets, to send you other content such as articles, and other related services that you specifically request from us.

* For marketing purposes, including to send our subscribers/users offers or promotion alerts, newsletters and other communications to our subscribers/users and business contacts.

* To manage our business relationships with our subscribers/users, vendors, suppliers, and business partners, including processing payment and sending service-related communications.

* To communicate with you and respond to your inquiries, and to notify you about changes to our Platform or any services we provide through the Platform.

* To protect the security and effective functioning of our Platform and information technology systems.

* For other business purposes, such as to provide, operate and improve our products and services, perform data analyses, detect, prevent, and respond to actual or potential fraud or illegal activities, defend our legal rights, and comply with our legal obligations and internal policies.

3. USE OF PERSONAL INFORMATION OF RESIDENTS IN EEA:
If you are located in the European Economic Area (“EEA”), we only process your Personal Information when we can rely on a valid legal ground such as:

* Execution of a contract. We need your Personal Information to provide you with our services, including to provide crypto market information to you or to otherwise respond to your queries.

* Compliance with a legal obligation. We are required or allowed to collect and use your Personal Information, for example to detect fraud or to comply with our tax, accounting and anti-money laundering obligations.

* Legitimate interest. We or a third party, have a legitimate interest in processing your Personal Information. For example, we have a legitimate interest in using your Personal Information to conduct business analytics or to improve the safety, security and performance of our products and services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

* Consent. You have consented to the use of your Personal Information, for example to send you our electronic alerts or newsletter or for the use of certain cookies.

4. SHARING OF PERSONAL INFORMATION:
We will share Personal Information with the following categories of recipients, subject to applicable law:

* Affiliates/Employees: We share Personal Information with our affiliates (if we have any in the future), and employees all over the US as needed to provide our services, for purposes consistent with this Policy or to operate shared infrastructure, systems and technology.
* Suppliers and service providers: We share Personal Information with companies that provide product or services to us for the operation of our business. These include providers of IT and software services, remote office services, cyber security services, mailing services, marketing services and finance systems. Such parties provide reasonable security for Personal Information and to use and process such Personal Information on our behalf only.

* Professional advisors. We share Personal Information with our accountants and other outside professional advisors in the course of the services they provide to us.

* Financial institutions: We share Personal Information with financial service provider such as in connection with collection and payment of our service fees.

* Corporate purchasers: We may share Personal Information with any corporate purchaser or potential purchaser to the extent permitted by law as part of any merger, acquisition, sale of Invalert assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of Invalert.

* Mandatory disclosures and legal claims: We share Personal Information in order to comply with any subpoena, court order or other legal process, to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share Personal Information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

* Other third parties with your consent. We share Personal Information with other third parties with your consent.

If you have questions about the parties with which we share Personal Information, please contact us as specified below.

5. COOKIES:
Through the use of cookies and similar technologies, we may collect your device identifier or IP address, unique device ID, hardware and software type, internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions.

The types of cookies we use include:

* Operational Cookies: To the extent applicable, we use operational cookies which are required for the operation of our Platform, for example, cookies that enable you to log into some areas. These operational cookies are session cookies that are erased when you close your browser.

* Google Analytics: We use Google Analytics to collect information about how you use our services. We use this information to create reports and improve our services. The cookies help us understand the number of visitors to our Platform and where visitors come from. To learn more about how Google uses data, visit https://policies.google.com/technologies/partner-sites. To opt-out from these cookies across our Platform, visit http://tools.google.com/dlpage/gaoptout.

* Functional Cookies: We use functional cookies to improve the functional performance of our Platform and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Platform. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Platform.

Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to certain cookies, your experience on our Platform may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

6. DATA PROTECTION RIGHTS FOR RESIDENTS IN EEA:
If you are in the EEA, you have the following rights:

* Access. Subject to certain exceptions, you have the right to request a copy of the Personal Information we are processing about you, which we will provide to you in electronic form. At our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your Personal Information, we may charge a reasonable administration fee.

* Rectification. You have the right to require that any incomplete or inaccurate Personal Information that we process about you is amended.

* Deletion. You have the right to request that we delete Personal Information that we process about you, unless we are required to retain such information in order to comply with a legal obligation or to establish, exercise or defend legal claims.

* Restriction. You have the right to request that we restrict our processing of your Personal Information where:

    - You believe such information to be inaccurate;
    - Our processing is unlawful; or
    - We no longer need to process such information for a particular purpose, but where we are not able to delete the information due to a legal or other obligation or because you do not want us to delete it.

* Portability. You have the right to request that we transmit the Personal Information we hold in respect of you to another data controller, where this is:

    - Personal Information which you have provided to us; and
    - We are processing that information on the basis of your consent or in order to perform our obligations under contract to you (such as to provide our services).

* Objection. Where the legal justification for our processing of your Personal Information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.

* Withdrawing Consent. If you have consented to our processing of your Personal Information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.

If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Access a list of local data protection authorities in EEA countries.

7. DATA SECURITY:
We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.

8. YOUR CONTROLS AND CHOICES:
In addition to Section 6, We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. In accordance with local law, your controls and choices as described in this Section:

* You may correct, update and delete your registration account in our Platform. You may also update and correct inaccuracies in your account information at any time by logging in your registration account.
* You may change your choices for subscriptions, alerts and newsletters.
* You may choose whether to receive offers and updates from us and promotions for our services.
* You may request access to the Personal Information we hold about you and that we amend or delete such information.
* You may set your browser to refuse all or some browser cookies, or to alter you when cookies are being sent.

You may exercise your controls and choices, or request access to your Personal Information, by contacting us as specified below. Please be aware that if you do not allow us to collect Personal Information from you, some of our services may not be available to you. If you have questions regarding the specific Personal Information about you that we process or retain, please contact us as specified below.

9. CHANGES TO THIS POLICY:
We may make changes to this Policy. The “Last Updated” date at the top of this page indicates when this Policy was last revised. If we make material changes, we may notify you via a notice posted on our Platform or other method. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices.

10. NOTICE TO CALIFORNIA RESIDENTS:
If you are a California resident, California Civil Code Section 1798.83 permits you to request a notice regarding the disclosure of your Personal Information by the Company to partners for the partners’ direct marketing purpose. If you are a California resident and would like a copy of this notice, please contact us at [email protected]

11. CHILDREN UNDER 13:
The Company is committed to protecting the online privacy of children and making the internet safe. We do not provide products and services to children, or knowingly collect or solicit Personal Information from children under 13 years of age. Any communication We get that is identified as being from a child under 13 will not be kept by the Company. We encourage parents or guardians of children under 13 to regularly check and monitor their children’s use of email and other activities online.

12. MISCELLANEOUS ISSUES:
* What are the consequences of not providing Personal Information?
You are not required to provide all Personal Information identified in this Policy to visit our Platform or to interact with us offline, but certain functionality will not be available if you do not provide Personal Information. If you do not provide Personal Information, we may not be able to respond to your request, provide services to you, or provide you with information that we believe you would find valuable.

* Does the Platform honor do not track ("DNT") signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.

* How long do we retain Personal Information?
We typically retain Personal Information related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For Personal Information that we collect and process for other purposes, we will typically retain such Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise specified in applicable record retention policies and procedures.

* Are third party websites governed by this Policy?
Our Platform may contain links and references to other websites administered by unaffiliated third parties. This Policy does not apply to such third-party sites. When you click a link to visit a third-party website, you will be subject to that website's privacy practices. We encourage you to familiarize yourself with the privacy and security practices of any linked third-party websites before providing any Personal Information on that website.

13. CONTACT US:
If you have any questions about this Policy, or if you would like to exercise your rights to your Personal Information, you may contact us at: [email protected] , attention: Data Protection Officer or at https://invalert.com/contact.html.