Privacy Policy

Last updated: October 30, 2023

Thank you for choosing R-Squared Labs LLC (together with our subsidiaries and affiliates, “Company”, “we”, “us”, or “our”). This Privacy Policy applies to all personal information that may be collected through our platform, mobile applications, products and websites, including without limitation rsquared.digital, portal.rsquared.digital and services and related websites, and any related services, sales, marketing or events (collectively, the “Products and Services”).

In this Privacy Policy we describe how we might collect, use, store and share your personal information and what rights you have in relation to it if we were to. Nothing herein should be construed as an intention or plan to perform, or to spend time and/or resources to perform, any particular marketing or promotional activity or activities or events, though we reserve the right to do so. If there are any terms or statements in this privacy policy that you do not agree with, please discontinue access and use of our Products and Services.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at contact@rsquared.digital.

Contents

1. What kinds of information might we collect?
2. How might we use this information?
3. How might we share this information?
4. International transfers
5. Retention
6. How do we secure this information?
7. Minors
8. Your choices
9. Changes to this Privacy Policy
10. Contact us
11. Notice to California residents
12. Notice to Nevada residents
13. Notice for EEA

1. What kinds of information might we collect?

Information you provide us

We may collect personal information that you provide us through the Products and Services, including when you use the Products and Services, express an interest in obtaining information about our products or services, participate in activities and events related to the Products and Services or otherwise contact us. The personal information that we may collect depends on the context of your interactions with us, the choices you make, the Products and Services and the products and features you use, such as:

• Identity. First and last name, username, profile picture and other identifiers. When required by law, we may request additional information, such as identification documents, to verify your identity.
• Contact information. Email address, mailing address and phone number.
• Usage information. Information about how you use the Products and Services, such as the products and features you use and actions you take.
• Marketing data. Your preferences for receiving our marketing communications and details about how you engage with them to the extent such activity occurs.
• User communications. Your communications when you contact us with questions or feedback, including feedback about the Products and Services and customer support correspondences.
• Payment and financial information. Credit card information and other financial information when you make purchases or payments and related transaction information.
• Technical data. Blockchain wallet address and network transactions.

Information we might automatically collect

We may automatically collect certain information when you access, use, download or interact with the Products and Services, such as:

• Device data. Browser and device characteristics, operating system, IP address, public blockchain wallet address and language preferences.
• Usage data. URLs, country, location, how and when you use the Products and Services and other technical information.
• Transaction data. Information about your purchase activity or other transactions, such as product details, purchase price, and the date and location of the transaction.
• Cookies. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we may use such technologies and how you can manage cookies is described below.

We might also use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here.

Information we may collect automatically through cookies and similar technologies

By accessing any of our websites or using any Products and Services, we may also automatically collect certain data from your browser, including server log information (such as login details, IP address and details on the time spent on various pages of our website) and device and browser information (such as the type of device, universally unique identifiers (‘UUID’), advertising identifiers (‘IDFA’), type of browser, operating system, hardware and processor information, plug-ins and add-ons).

Similarly to other websites, our website may utilize, and other Products and Services may utilize, browser cookies (small text files stored on a user’s web browser when you visit a website), web beacons and similar tracking technologies (collectively, Cookies) to collect and store certain information when you use, access, or interact with our Products and Services. We may, for example, use Cookies to collect information about the type of device you use to access the Products and Services, your browser type, the operating system and version, your IP address or other identifier, your general geographic location as indicated by your IP address, features you access on the Products and Services, whether and how you interact with content available on the Products and Services, and the search terms you enter on the Products and Services. Emails may also contain small transparent image files or lines of code to record how you interact with them.

This information helps developers better analyze and improve services. We may also use Cookies to remember your preferences and settings, to remember information that you may enter online, to keep you logged in to portals that we may offer, to generate aggregate statistics about how people use our Products and Services, to help you share content with others and to improve your experience of the Products and Services.

You can choose how Cookies are handled by your device through your browser or device settings, including refusing or deleting all Cookies. If you choose not to receive Cookies at any time, websites may not function properly and certain services may not be provided. Each browser and device is different, so check the settings menu of the browser or device you are using to learn how to change your advertising settings and Cookie preferences.

Information we might collect from third party sources

We may obtain information from third party sources, such as:

• Service providers, such as third-party service providers we may use to facilitate commerce services, provide analytics or process payments. Your interactions with such third-party service providers are governed by those businesses’ own privacy policies. Companies and individuals that provide services on our behalf or help us operate the Products and Services, such as payment processing, customer support, marketing, hosting, event organization, logistics planning, analytics, technology development, email delivery, database management services and identity verification services, as well as lawyers, bankers, auditors, and insurers, in the course of the professional services that they render to us.
• Public sources, including blockchains and social media companies.

For attribution: we use products and/or services from TradingView (including TradingView's Advanced Charts libraries) located at the website TradingView.com. TradingView's Privacy Policy is unrelated to our own.

2. How might we use this information?

To provide and improve our service

We may use your personal information to:

• Enable you to access and use the Products and Services.
• Provide and deliver products and/or services that you may request.
• Maintain and improve our products and/or services.
• Personalize your experience on the Products and Services.
• Process and complete transactions, and send you related information, including purchase confirmations and ticketing information.
• Facilitate events and provide information about events that you indicate an interest in.
• Send information, including technical notices, updates, security alerts and administrative messages.
• Provide support for the Products and Services, including resolving issues and responding to your questions and feedback.

To comply with the law

In some cases, we may have a legal obligation to collect or use your personal information. We may use your personal information as we believe necessary or appropriate to:

• Comply with applicable laws, including without limitation anti-money laundering (AML) laws and know-your-customer (KYC) requirements.
• Comply with lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Compliance, fraud prevention and safety

We may use your personal information as we believe necessary or appropriate to:

• Prevent, detect and investigate fraudulent, harmful or illegal activity, including cyberattacks and scams.
• Enforce the User Agreement that governs the Products and Services.
• Comply with our internal policies and procedures.

To send marketing communications

We and our third-party marketing partners may use your personal information for marketing purposes, such as to send you communications (including via text message and/or email and/or other electronic means as permitted by law) about promotions, upcoming events, and other news about products and/or services offered by us.

Targeted advertising

We may engage third party advertising partners to display ads to you. Our advertising partners may use cookies and similar technologies to collect information about your online activity for the purpose of targeting ads to you.

Research and analytics

We may use your information for data analysis, including identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services, products, marketing and your experience. We may use, store and share this information in aggregated or anonymized form so that it is not associated with individual end users and does not include personal information.

With your consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Products and Services, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.

3. How might we share this information?

We do not share your personal information with anyone else without your express consent, except as described in this Privacy Policy. We may disclose personal information to third parties under the following circumstances:

Service providers and professional advisors

Companies and individuals that provide services on our behalf or help us operate the Products and Services, such as payment processing, customer support, marketing, hosting, event organization, logistics planning, analytics, technology development, email delivery, database management services and identity verification services, as well as lawyers, bankers, auditors, and insurers, in the course of the professional services that they render to us.

Compliance with laws and law enforcement; protection and safety

For legal, protection and safety purposes, such as to:

• Comply with laws, including without limitation KYC and AML requirements.
• Respond to lawful requests and legal processes.
• Protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies and User Agreements.
• Protect the safety of our employees and agents, our customers or any person.

Affiliates

We may share your personal information with our subsidiaries and corporate entities affiliated for purposes consistent with this Privacy Policy.

Business transactions

When we enter into a business transaction, or negotiate a business transaction, involving a corporate divestiture, merger, consolidation, acquisition, reorganization, bankruptcy, sale or other transfer of all or a part of our business or assets.

Event partners

We may share your personal information with co-organizers, co-hosts and co-sponsors of any events, such as conferences, webinars, hackathons, whether in-person or virtual, that we organize, host or sponsor.

Other users

Certain of our Products and Services might enable you to connect to and interact with other users of those Products and Services. If you access or use such Products and Services, we may share your personal information with such other users.

Other

You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entities. We may also share aggregated and/or anonymized data with others for their own uses.

4. International transfers

We and our service providers collectively have offices in the United States and in other countries. As such, your personal information may be processed in, transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where data protection laws may not be as protective or comprehensive as those in your jurisdiction.

If you are a European user, please review the “Notice for EEA” section.

5. Retention

We may retain personal information for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law, such as tax, accounting, fraud prevention, to assist in investigations, to resolve disputes, to establish or defend legal claims or other legal requirements.

In some circumstances we may anonymize your personal information such that it can no longer be associated with you, in which case we may use this information indefinitely without further notice to you.

6. How would we secure this information?

We employ standard technical and organizational security measures to protect the security of any personal information we might process. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Products and Services are responsible for maintaining the security of any password, biometrics, user ID, private keys, seed phrases or other form of authentication involved in obtaining access to password protected or secure areas of or for any of our Products and Services. In order to protect you and your data, we may suspend your use of any of the Products and Services, without notice, pending an investigation, if any breach of security is suspected.

7. Minors

We do not knowingly solicit data from or market to persons under the age of 18. By using the Products and Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Products and Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate any related account under our control to and take reasonable measures to delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at contact@rsquared.digital.

8. Your choices

Access, update, correct or delete

To the extent to which we may have collected your personal information, you may contact us to request a copy of this personal information (if collected). You may also request that we update, correct or delete this personal information or that we update your preferences (to the extent to which such preferences exist). We are permitted to request additional information from you to verify your identity and authority to take such action.

Opt out of marketing communications

You may opt out of receiving newsletters, promotional emails and other marketing communications by following the instructions in such communications we send you.

Opt out of sharing information with third parties

To the extent to which we collect and share your personal information with third parties, you may opt out of sharing your personal information with third parties by contacting us.

Opt out of tracking technologies generally

Regular cookies may generally be disabled through the preferences and settings of most web browsers.

Opt out of Google Analytics

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on. Your use of such add-ons is subject to Google’s terms of use.

Do Not Track

Most web browsers and some mobile operating systems and mobile applications include a Do Not Track (“DNT”) feature setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not currently respond to DNT browser signals.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

Any modifications to this Privacy Policy will be effective upon our posting of the updated terms. In all cases, your continued use of the Products and Services following the posting of any updated Privacy Policy indicates your acceptance of the terms of the updated Privacy Policy.

10. Contact us

We welcome your comments or questions about this Privacy Policy. You may contact us at contact@rsquared.digital.

11. Notice to California residents

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of personal information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at contact@rsquared.digital. This request may be made no more than once per calendar year.

If you are a California resident, you have certain additional rights with respect to your personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

We are required to inform you of:

• What categories of information we may collect about you, including during the preceding 12 months: See the section “What kinds of information might we collect?”.
• The purposes for which we may use your personal information, including during the preceding 12 months: See the section “How might we use this information?”.
• The purposes for which we may share your personal information, including during the preceding 12 months: See the section “How might we share this information?”. In addition, we may share the following categories of information with the following parties:

• Identity information: Service providers such as KYC service providers.
• Contact information: Marketing partners and event partners.
• Financial information: Service providers such as payment service providers and logistics providers.

• In the preceding 12 months, we have not sold any personal information of consumers.

Your rights

You have the right to request to know: (i) the categories of personal information we have collected about you in the last 12 months; (ii) the specific pieces of personal information we have about you; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your personal information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your personal information. These rights are subject to limitations as described in the CCPA. We may deny your request if we need to do so to comply with our legal rights or obligations.

We will not discriminate against any consumer for exercising their CCPA rights.

You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

If you would like to exercise any of these rights, please contact us at contact@rsquared.digital.

12. Notice to Nevada residents

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information to third parties. At this time, we do not sell your information to third parties. If that were to change, we will update this Privacy Policy.

13. Notice for EEA

If you are a data subject in the European Economic Area, the United Kingdom or Switzerland, you have certain rights with respect to your personal data pursuant to the General Data Protection Regulation of the European Union (“GDPR”). This section applies to you.

References to “personal information” in this Privacy Policy are equivalent to “personal data” as defined under GDPR.

In the event that we would collect your personal information, Company would be the controller of your personal information as covered by this Privacy Policy for purposes of GDPR.

We would process your personal data in reliance on the legal bases below. Where the purpose of processing is:

• To provide and improve our service: We would process your personal data as necessary to perform the contract under which we provide our Products and Services or to take steps that you request prior to signing up for the Products and Services.
• To comply with the law: We would process your personal data as necessary to comply with applicable laws and our legal obligations.
• For compliance, fraud prevention and safety: We would have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so would outweigh any prejudice to your data protection rights. We would also process your personal data as necessary to comply with our legal obligations.
• To send marketing communications; for targeted advertising; or for research and analytics: We would have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so would outweigh any prejudice to your data protection rights.
• With your consent: We would process your personal data in reliance on your consent. You would be able to withdraw it any time in the manner indicated when you provided consent or in the Products and Services.

Your rights

You may: (i) ask whether we have any personal data about you and request a copy of such personal data; (ii) request that we update or correct inaccuracies in your personal data; (iii) request that we delete your personal data; (iv) request a portable copy of your personal data; (v) request that we restrict the processing of your personal data if such processing is inappropriate; and (vi) object to our processing of your personal data. These rights are subject to applicable law.

If you would like to exercise any of these rights, please contact us at contact@rsquared.digital. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents.

If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, please contact us at the same email. You may also lodge a complaint with your local data protection authority.

Transfers outside of the EEA

If we transfer your personal data outside the European Economic Area, we will do so in accordance with the terms of this Privacy Notice and applicable data protection law.

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