⭕Privacy Policy

Last Updated: February, 2024

Introduction

This document outlines the procedures followed by DTX.trade (“Project”) and its affiliates ("us," "our," or "we") regarding the collection, usage, storage, and processing of personal information belonging to customers and other individuals (collectively referred to as "you") who access or utilize our websites, mobile applications, and other related services (referred to as the "Services"). By using our Services, you acknowledge and understand that we collect and utilize your personal information as described in this Privacy Policy (“Policy”).

Please note that in certain cases, we may process your personal information based on agreements with third-party organizations. In such instances, the terms of those agreements will govern the processing of your personal information. If you believe that a third-party organization has requested us to process your personal information on their behalf, please contact them directly as they will be responsible for the processing of your information. This Policy does not apply to any third-party websites or applications that you may use, including those linked within our Services. We recommend reviewing the terms and policies of such third-party websites and applications before accessing them.

We encourage you to read this Policy in its entirety to ensure that you are fully aware of how we collect, use, store, and process your personal information, as well as your privacy rights. However, if you prefer to navigate directly to a specific section of this Policy, please refer to the table of contents provided below.

1. Collection of Personal Information

You have the option to visit our websites, install our apps, and provide personal information to us. However, please note that failure to provide certain personal information may limit your access to certain parts of our Services.

Personal Information Provided by You:

You may provide us with personal information about yourself when you:

- Register or log in to your account.

- Use our services/product(s).

- Create or update your user profile.

- Contact customer support.

- Participate in surveys, sponsored events, sweepstakes, or subscribe to newsletters.

- Leave comments (if applicable).

- Refer friends (if applicable).

- Other industry practice.

Examples of the personal information categories you may provide include:

Identifiers and contact information, such as your name, email address, mailing address, phone number, or electronic signature; Commercial information, including billing and payment details (e.g., credit card number, expiration date, visual cryptogram), and products or services purchased; Geolocation data, such as your physical location; Contact and Image Data: When you grant us permission, contact information (e.g., name, email address) and image data of the contact (if uploaded) on your device that can be used to save as a profile image for your account; Biometric recognition information (including face recognition information, fingerprint recognition information) (if applicable).

Automatically Collected Personal Information:

We may automatically collect personal information from you and your devices when you use our Services, including when you visit our websites or apps without logging in.

The categories of personal information we may automatically collect include:

- Device, Usage Information, and Transactional Data: We collect personal information about how you use our Services and the devices (e.g., computers, mobile phones, tablets) you use to access our Services. This may include, but is not limited to, the following:

- IP address.

- Precise geolocation information that you allow our apps to access (usually from your mobile device).

- Unique device identifiers and device attributes, such as operating system and browser type.

- Usage data, such as web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed, the order of those pages, the amount of time spent on particular pages, the date(s) and time(s) you used our Services, the frequency of your use of our Services, error logs, and other related information.

- Transactional data, including contact list data such as names, email addresses, IP addresses, and authentication methods of parties to a transaction, subject line, history of actions that individuals take in connection with a transaction (e.g., review, sign, enable features), personal information about those individuals or their devices, such as name, email address, device contacts you authorize to obtain personal information from parties to a transaction, and photo image (if available) that is used to save as a profile image for the account.

- Cookies and Related Technologies: We use cookies, which are small text files containing information that is downloaded on your device, as well as related technologies such as web beacons, local shared objects, and tracking pixels to collect and/or store information.

Information Obtained from Other Sources:

Subject to applicable laws, we may collect personal information about you from other sources, including:

- Third-Party Sources: This includes marketers, partners, researchers, affiliates (such as companies under the common ownership or control of Project), service providers, and other entities legally allowed to share your personal information with us. For example, if you register for our Services on another website, that website may provide us with your personal information.

- Other Customers: Other customers may provide us with your personal information.

- Combination of Personal Information: We may combine the personal information we receive from other sources with personal information we collect from you (or your device) and use it as described in this Policy.

2. Use of Personal Information

Generally, and in accordance with relevant laws and with your consent where required, we may utilize your personal information for the following purposes: providing, enhancing, and refining our Services; developing new Services; and promoting our companies, products, and Services. Here are some examples of how we employ the personal information we process:

- Furnishing you with the products and Services you request and handling the associated payments.

- Establishing your account and managing our relationship with you (e.g., communicating with you, providing requested information).

- Sending you records of our interactions, including purchase details and other relevant events.

- Marketing features, products, or special events via email, phone, or other means, and sending you marketing communications about third-party products and services that we believe may interest you.

- Organizing sweepstakes, contests, and refer-a-friend programs.

- Selecting and delivering tailored content and advertisements, as well as supporting the marketing and advertising of our Services.

- Generating and evaluating user data to better understand how our users utilize our Services.

- Testing modifications to our Services and developing new features and products.

- Addressing any issues you may encounter with our Services, including providing support, customer education and training, and resolving disputes.

- Managing the Services platform, including support systems and security.

- Preventing, investigating, and responding to fraud, unauthorized access or usage of our Services, violations of terms and policies, or other inappropriate activities.

- Complying with legal obligations and adhering to legal retention periods.

- Establishing, exercising, or defending our rights in legal claims.

Other Uses: We may combine or anonymize the personal information we collect in order to prevent or limit the identification of specific users or devices. This helps us conduct research and carry out marketing activities. Once the information has been aggregated and anonymized to the extent that it no longer qualifies as personal information under applicable data protection laws, this Policy no longer applies.

Lawful Basis for Processing Your Personal Information: If European data protection law is applicable and Project acts as a data controller, the lawful basis for collecting and using the personal information described in this Policy depends on the type of personal information involved and the specific context in which we collect or use it.

We typically collect or use personal information when we have your consent, when it is necessary to fulfill a contract with you, or when the processing is in our legitimate interests and does not override your data protection interests or fundamental rights and freedoms. In some instances, we may have a legal obligation to collect or retain personal information, or we may require the personal information to protect your vital interests or those of another person. For example:

- When we create and manage an account using personal information, we do so to provide you with relevant Services and fulfill our contractual obligations.

- When we use names and email addresses for email marketing purposes, we do so with your consent (which you can withdraw at any time) or, where permitted under applicable law, based on our legitimate interests.

- When we collect and analyze usage data to improve our Services or ensure the security of our websites, we do so based on our legitimate interest in safeguarding and enhancing our Services.

If you have any questions or need further information regarding the lawful basis for collecting and using your personal information, please contact us using the contact details provided in this Policy. Please note that when Project acts as a processor, the appropriate legal basis associated with processing activities is determined by our customer, and any inquiries about the applicable lawful basis should be directed to them.

3. Sharing of Personal Information

In accordance with applicable laws, including required consent, we may share your personal information as outlined below:

-Service Providers: We share your personal information with trusted service providers who assist us in supporting our Services. These companies offer various services such as intelligent search technology, analytics, advertising, authentication systems, bill collection, fraud detection, and customer support. Our service provider agreements ensure the proper use and protection of your personal information.

-Affiliates: We may share your personal information with other companies that are under common ownership or control with Project. These affiliated companies will use your personal information as described in this Policy.

-Marketing Partners: We may share your personal information with sponsors of events, webinars, or sweepstakes in which you participate, as well as other parties involved in joint marketing activities.

-Public or Government Authorities: To fulfill our legal obligations, comply with regulations or contracts, or respond to court orders, administrative or judicial processes (such as subpoenas, government audits, or search warrants), we may share your personal information. We may also disclose information in cases where there are threats to the physical safety of individuals, violations of Project policies or agreements, or to protect the legal rights of third parties, including our employees, users, or the public.

-Corporate Transactions: In the event of any proposed or actual reorganization, sale, merger, consolidation, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including bankruptcy or similar proceedings), your personal information may be disclosed or transferred to relevant third parties as part of due diligence. If such a corporate transaction occurs, we will inform you about any changes regarding the control of your information and provide you with any available choices.

-Consent: We may share your personal information in other ways if you have explicitly requested or given consent. For example, with your consent, we may publish user testimonials that identify you.

Additionally, your personal information may be shared as described below:

- Third Parties: When you make a payment to another user within our Services, we share your payment method details with the third-party payment processor chosen by you.

- Public Information: User-Generated Content, your comments on blogs or community forums, may be read, collected, and used by others. Profile Information, when you create a Project profile, other Project users can view your profile information. If you prefer to keep this information private, you can adjust your account settings accordingly.

4. Retention of Personal Information

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and used, and as required by applicable laws. The duration of retention depends on the specific purposes and may also be subject to our data retention policy and information handling standards. Typically, we retain personal information to comply with retention or statutory limitations or for the purpose of fulfilling a contract with you. If technical limitations prevent deletion or anonymization, we take measures to safeguard the personal information and limit its active use.

5. Your Options

This section outlines various actions you can take to modify or restrict the collection, use, storage, or processing of your personal information:

- Profile: Filling out a profile is optional. If you choose to do so, you can access and review your personal information. In case of any inaccuracies or incompleteness, you can make changes in your account settings.

- Marketing Messages: You have the choice to unsubscribe from our email marketing messages by clicking on the "unsubscribe" link in the email or visiting the unsubscribe page on our website. Please note that we may send one confirmation message to verify your opt-out request. However, if you are a registered user or have engaged in transactions with us, we may still send transactional or relationship messages (e.g., account notifications) even after opting out of marketing messages.

- Cookies and Related Technology: You can decline cookies by adjusting your browser settings or following the instructions provided in our Cookie Notice Website. However, please be aware that declining cookies may limit your access to certain parts of our Services. Additionally, please note that we do not acknowledge or act upon browser-initiated Do Not Track signals.

- Device and Usage Information: If you prefer not to share your device location with us, you can disable location sharing on your device, modify your device privacy settings, or choose not to share location information through your browser.

- Closing Your Account: If you wish to close your account, you can log in and edit your plan settings.

- Complaints: We are committed to addressing valid complaints regarding your privacy and the collection, use, storage, or processing of your personal information. If you have any questions or complaints about our data practices or this Policy, please contact us via: [e-mail].

6. Children's Privacy

Our Services are not intended for individuals under the age of 18 or the designated age specified by applicable law for minors. We do not knowingly collect or request personal information from minors, nor do we allow them to use our Services. If you are a minor, please refrain from using our Services or providing us with any personal information. If we become aware that we have unintentionally collected personal information from a minor without verified parental consent, we will delete such information. If you believe we may have collected personal information from or about a minor that should be removed from our system, please contact us through our website.

7. Information for California Residents

In addition to the information and rights described in this Policy, residents of California have additional rights and access to specific information under the California Consumer Privacy Act ("CCPA") concerning their personal information. This section of the Privacy Policy applies to you if you are a California resident (referred to as a "Consumer" as defined by the CCPA). If you are not a Consumer, this section does not apply to you, and you should not rely on it.

A. Information Collection and Usage

The following is a summary of the personal information (as defined by the CCPA) we collect and use in connection with our Services for commercial and business purposes. For more details, please refer to the relevant sections of this Policy.

Categories of Personal Information we may collect and use for commercial and business purposes:

• Contact and account registration information: When you register for an account or get in touch with us, you may provide us with your name, email address, physical address, phone number, account username and password, electronic signature, and other relevant details.

• Financial or payment information: We collect information related to the payment methods you provide, billing details, and information about the products or services you purchase.

• Transaction information: When you use our Services for transactions, we may collect the names and email addresses of transaction participants, subject lines, the history of actions taken within a transaction (e.g., reviews, signatures, enabling features), and personal information of individuals involved or their devices, such as names, email addresses, IP addresses, and authentication methods.

• Customer service information: We gather information regarding your customer service interactions with us, including any questions or messages you send us directly through online forms, email, phone, or mail.

• Information about your web browser, mobile device, or internet connection: When you access our Services online, we may automatically collect your IP address, device identifiers, device attributes (including cookie IDs and mobile advertising IDs), data on how you interact with our online Services (usage data), location information (such as city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation), and, with your permission based on your mobile device settings, precise geolocation information obtained from GPS functionality on your mobile device.

Commercial and Business Purposes for Using Collected Personal Information:

- Providing requested products and services to you and processing payments.

- Creating and managing your account, and maintaining our relationship with you (e.g., communication, providing requested information).

- Sending you transaction records, including those related to purchases or other events.

- Marketing features, products, or special events via email or phone, and sending you marketing communications about third-party products and services we believe may interest you.

- Conducting sweepstakes, contests, and refer-a-friend programs.

- Selecting and delivering tailored content and advertising, and supporting marketing and advertising efforts for our Services.

- Generating and analyzing data about our users and their usage of our Services.

- Testing changes and developing new features and products for our Services.

- Addressing issues you may encounter with our Services, including providing support and resolving disputes.

- Managing the Services platform, including support systems and security.

- Preventing, investigating, and responding to fraud, unauthorized access or use of our Services, violations of terms and policies, or other inappropriate activities.

- Complying with legal obligations and applicable retention periods.

- Establishing, exercising, or defending our rights in legal claims.

B. The Right to Opt Out of Personal Information Sales:

Consumers have the right to opt out of the "sales" of their personal information as defined by the CCPA. According to the CCPA, with certain exceptions, a "sale" occurs when a business sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or electronically, a consumer's personal information to another business or a third party in exchange for monetary or other valuable consideration.

As explained in more detail in Section 3 of this Policy, we share personal information with other companies. Consumers can submit requests to opt out of such sharing using the following methods:

1. Adjusting cookie settings and selecting the option to opt out of respective cookie activities.

2. Clicking the “unsubscribe” link at the bottom of any Project marketing communication.

C. The Right to Access:

Consumers have the right to request specific details about the personal information we have collected about them within the past 12 months. This includes the right to request:

- The specific pieces of personal information and categories of personal information we collected about them.

- The categories of personal information we sold or disclosed for business purposes and the categories of third parties to whom we sold or disclosed that information for a business purpose.

- The categories of sources from which we collected personal information.

D. The Right to Deletion:

Consumers have the right to request the deletion of personal information we have collected from them. However, the CCPA allows us to retain information in certain circumstances (e.g., legal obligations, specific exceptions outlined by the CCPA).

E. How to Exercise Access and Deletion Rights:

Consumers can submit requests for accessing or deleting their personal information by accessing and reviewing personal information associated with your account by contacting us via [e-mail].

For security purposes, we will verify your identity before fulfilling your request. If you have an account with us, we may verify your identity by having you log in. If you don't have an account, we may need to contact you or request additional information (such as your name, email address, or telephone number) to verify your identity.

Once your identity is verified, we will respond to your request to the extent permitted by law. If we're unable to verify your identity, we may ask for more information or deny your request. If we can't fulfill your request completely, we will provide you with further details explaining why.

Please note that certain personal information may be exempt from these requests under applicable law. Additionally, we require certain types of personal information to provide our products and services. If you request deletion of such information, you may no longer be able to access or use our products and services.

F. The Right to Non-Discrimination

Consumers have the right to be free from discrimination for exercising their CCPA rights. We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to Consumers who choose to exercise their CCPA rights.

G. Authorized Agents

If you designate an agent to make CCPA requests on your behalf, we will verify both your identity and your agent's authorization to act on your behalf. We may request a signed written authorization or a copy of a power of attorney to verify the agent's authority.

H. "Shine the Light"

If you are a California resident, you have the right to request a list of third parties that received your personal information for direct marketing purposes in the previous year. This list will include the types of personal information shared. We provide this list at no cost. To request this information, please contact us via the Official Website.

8. Your Privacy Rights

You have certain rights regarding your personal information, as described below and subject to local data protection laws. To exercise any of these rights, please contact us via the Official Website.

• You can access and review the personal information associated with your account at any time by visiting Official Website.

• You can request information about how we collect and use your personal information, the categories of personal information involved, the recipients of your personal information, the sources from which we obtained your personal information, our business purposes for using your personal information, and how long we use or store your personal information.

• You have the right to correct any inaccurate personal information we hold about you. Please notify us if you believe your personal information is inaccurate, incomplete, or out-of-date.

• In certain situations, you can request the erasure or cessation of the use of your personal information, object to or restrict the use of your personal information, or export your personal information to another controller.

• If we rely on your consent to process your personal information, you have the right to decline or withdraw your consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. You can also request that we stop using your personal information for direct marketing purposes.

• If you are unsatisfied with our response to your complaint, you have the right to raise questions or complaints with your local data protection authority.

If you make a request to exercise the rights mentioned above, we will require certain information for identity verification purposes. If you have an account with us, we may verify your identity by having you log in. If you don't have an account, we may ask for additional information to confirm your identity. If you authorize an agent to make a request on your behalf, we will verify both your identity and the agent's authorization.

Please note that certain personal information may be exempt from these requests under applicable law. We require certain types of personal information to provide our products and services. If you request deletion of such information, you may no longer be able to access or use our products and services.

International Data Transfers

Project operates globally, which means that personal data may be transferred, stored, and processed outside the country or region where it was initially collected, including the United States and other countries outside the EEA, Switzerland, and the UK. By using Project products and services or providing personal data, you acknowledge that your personal data may be transferred to these locations, which may have different and potentially less protective data protection laws than your country.

We protect your personal data in accordance with this Policy and take appropriate steps to ensure its protection under applicable laws, such as using the European Commission's standard contractual clauses when transferring personal data from the EEA, Switzerland, or the UK to countries without adequate data protection levels. If you would like more information about this, please contact us.

9. How We Safeguard Your Personal Information

To protect your personal information from misuse, destruction, loss, alteration, disclosure, acquisition, or unauthorized access, we have implemented appropriate technical, physical, and organizational measures. Our staff members are only allowed to access customer personal information to the extent necessary to fulfill their job responsibilities and the applicable business purpose, subject to confidentiality obligations.

10. Changes to Policy

We may update this Policy to reflect changes in the law, our companies, our services, our data processing practices, or technological advancements. The use of personal information we collect will be governed by the Privacy Policy in effect at the time of its use. Depending on the nature of the change, we may notify you of such changes by posting them on this page.

11. Contacting Us

If you have any questions or complaints regarding the use of your personal information or this Policy, you can reach out to us via email at [e-mail].