Privacy Policy, Vertalo, Inc

Effective: March 8, 2023

Scope

Vertalo, Inc (“Vertalo,” “we,” “us,” or “our”) provides this Privacy Policy because we know that you care about how your information is collected, used, shared, and retained.

Our website at https://vertalo.com/ (the “Site”) is available to the general public (“Site Visitors”) for informational and marketing purposes. We also provide a data storage platform (the “Platform”) at https://app.vertalo.com (or relevant corporate domain) (“Platform Services”) that enables our registered Platform users (“Users”) other users and platform visitors (“Platform Visitors”) to store important information (collectively, Site Visitors, Users, and Platform Visitors are referred to as “Participants”). We may, without limitation, collect your‎ name, postal address, email address, phone number, username, password, demographic information (such as your occupation), social security number, tax ID, bank account information, as well as other information you directly give us on our Platform Services (“Records”) , which may include marketing, promotions and when communicating to you about new features.  Please note that in some cases Site Visitors may also be Users or Platform Visitors.

For customers who have paid software services, we collect your billing details such as credit card information, banking information, and/or billing address.

Information We Get From Others

We may get information about you from other sources, such as an Issuer when they issue you options or shares. We may add this to information you provide us through our Platform Services.

Information Automatically Collected

• Device Information
  We may collect information about the devices accessing our Platform Services. Some examples are: type of device, operating system used, application information, unique device identifiers and crash data. The type of information we collect depends on the type of device used and its settings.
  
  
• Transactional and Usage Information
  We may automatically log information about you and your computer, subject to your consent where required by law. For example, like most services when using our Platform Services, we log your computer operating system type, browser type, browser language, pages or screens you viewed, how long you spent on a page or screen, location (your IP address), access times and information about your use of and actions on our Plaform. This is information we collect from every user of the Platform Services, whether they have an account or not. This information may include personal information.
  
  

Consent

By visiting our Site or using our Platform, Participants agree to this Privacy Policy and the accompanying Terms of Use. 

Information We Collect and What We Do With It

Use and disclosure of personal information

We may use, process and/or disclose personal information for the following purposes:

• To operate, maintain, and improve the Platform Services. This includes use of other information to support delivery of our services, assist with service requests, monitor for errors, remedy security or technical issues, analyze website and application performances.
• To respond to comments and questions, verify permission access, and provide customer service.
• To send information including confirmations, invoices and billing, technical notices, updates, security alerts, and administrative messages.
• To communicate upcoming events and other news about products and services offered by us.
• To communicate and inform you about system updates and important services-related notices, such as privacy and policy update notices or changes in our terms of service. These communications are administrative and you may not opt out of them.
• To send marketing emails related to the Platform Services, which you may opt out of using provided unsubscribe links or the opt-out mechanism in those communications.
• To link or combine user information with other personal information. An example is when we combine the information a company has provided about their shareholders with the information entered by shareholders in their personal portfolios to improve the user experience.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, including, but not limited to, validating your identity and preventing fraud on your account, and complying with KYC rules and regulations.
• To provide and deliver products and services to our business customers with respect to their employees or investors. An example is when an employee exercises their employee stock options and we provide a tax form to their employer to facilitate compliance with tax laws.
• To facilitate online advertising. Third-party advertising companies and social media companies may use cookies and similar technologies to collect information about your interaction over time across the Platform Services, our communications and other online services, and use that information to serve online ads that they think will interest you.

We may also use and disclose personal information as follows:

• Our business customers’ equity administrators, authorized users, and other designated representatives can access information that we hold about the equity information of their employees and investors.
• To comply with laws, lawful requests and legal or regulatory processes.
• To protect the rights, safety and property of Vertalo, our agents, users, customers, and others. This includes enforcing our agreements, policies, and terms of use, reporting on security breaches, or assisting with investigating and preventing fraud or security issues.
• We may create, use, and share aggregated or anonymized data for any lawful purpose, such as marketing, analytics or research purposes permitted by law.
• We may share personal information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Vertalo (including, in connection with a bankruptcy or similar proceedings).
• We may share other information with third parties in other ways not described in this Privacy Policy when we have consent to do so.
• We may share personal information with third party companies or individuals that we engage as service providers to process information and support our business and services. Examples include providers of cloud hosting and storage services, analytics services, email delivery services, and customer support services.
• We may share personal information with our lawyers, accountants, and other professional advisors in the course of the services they render to us.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Age Limitations

Vertalo does not allow the use of our Platform Services by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data through the Platform Services, please contact us and we will take steps to delete such information.

Site Information

We collect and use the following information from Site Visitors when they interact or link from our Site.

• Contact Information
  We collect contact information from Site Visitors that e-mail Vertalo via the Contact Us link and/or sign up for our blog feed/update form.
  
  
• Contact Us
  When contacting Vertalo, we will collect your e-mail address and its contents to provide the requested information, support, to enhance the Site or Platform, and put your e-mail on a contact list for future marketing messages to your inbox.
  
  
• Newsletter/Update Form
  By signing up for our Newsletter or filling out our form to receive updates, you will receive our Newsletter and other marketing messages to your inbox. See Direct Marketing and Site and Platform Generally below.

Platform Information

We collect and use the following information from Users and Platform Visitors, as applicable, when interacting with the Platform and/or using the Platform Services:

• Account Profile Information
  In order to become a registered User, a person must create an account profile on the Platform. To that end, we may collect certain information such as the User’s name, e-mail addresses, a blockchain address (also referred to as a ‘wallet ID’), phone number, and postal address. In the case of corporate accounts, additional information is collected such as business ID #, business category, admin addresses, etc. We may also keep a record of how often Users visit their profile, such as when logging into their account.
  
  A User must initially authenticate itself to the Platform using a third party account. When using a third party account, Users authorize us to collect, store, and use, in accordance with this Privacy Policy, any and all information that the User has authorized that third party to provide. For example, in the case of a social media account, such information may include a User’s first and last name, profile image, e-mail address, birthdate, and/or gender. Where a User wishes to register an organization with us, the User must authenticate herself by demonstrating sufficient control of the organization by some means.
  
  

Site and Platform Generally

We collect and use the following information from Participants generally across both the Site and Platform:

• Direct Marketing
  We may use a Participant’s personal information provided to us through the Site or Platform for direct marketing purposes, such as e-mails advertising our Platform Services.
  
  A Participant may opt-out at any time from the use of the User’s personal information for direct marketing purposes, and/or the transfer of such personal information to third parties for direct marketing purposes by contacting us at privacy@vertalo.com. Please allow us a reasonable time to process the request.
  
  Further, a Participant may manage receipt of marketing and non-transactional communications by clicking on the “Manage E-mail Preferences” link located on the bottom of any Vertalo marketing e-mail and following the instructions found on the page that the link brings the Participant to. A Participant cannot opt-out of receiving transactions e-mails related to their account or purchases.
  
  
• Usage Data
  We collect information about Participants regarding how they use our Site or Platform, such as actions Users take in their account profile on the Platform (like sharing, editing, viewing, and moving files or folders).
  
  We also collect information from and about the devices Participants use to access the Site or Platform, such as through Google Analytics. This includes information such as IP addresses, the type of browser and device used, identifiers associated with such devices, and/or the web page visited before coming to our Site or Platform.
  
  We may anonymize usage data and process it in aggregate form to operate, maintain, manage, and improve the Site or Platform. This aggregate information does not identify a Participant personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated statistics in order to describe our Site or Platform generally to current and prospective business partners and to other third parties for other lawful purposes.
  
  
• Analytics Tools
  Like most organizations, we rely on analytic tools (“Analytics”  when a Participant visits our Site or Platform. Analytics may use tracking technologies such as, but not limited to, cookies (see Cookie Data below) to collect information our behalf such as the Participant’s IP address, Internet service provider (ISP), browser type, operation system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the website visited, number of links clicked while on the website, search terms, and other data. By accessing and using the Site or Platform, Participants consent to the processing of data about them by Analytics in the manner and for the purposes set out in this Privacy Policy.
  
  
• Cookie Data
  We use technologies such as cookies and pixels to collect information from Participants (including personal information), which we process in order to provide, improve, protect, and promote our Site or Platform. For example, cookies help us with things like remembering a username for a User’s next visit to the Platform, understanding how Site Visitors are interacting with our Site, and improving them based on that information. Participants can set their browser to not accept cookies. Please consult your internet browser’s documentation for information on how to do this, such as by using your browser in private mode to block cookies However, if a Participant decides not to accept cookies, this may limit the Participant’s ability to use the Site or Platform.
  
  
• Additional Uses
  We may also use contact information, billing information, account profile information, and other information collected pursuant to this Privacy Policy to respond to general inquiries, solicit feedback regarding our Site or Platform and support, provide relevant content on our Site or Platform including advertisements, communicate with Participants via e-mail regarding our current and future services, and administer our promotional programs.

Other Important Privacy Information

• Security
  Vertalo takes the security and privacy of the personal information that it collects pursuant to this Privacy Policy very seriously. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.
  
  
• Data Storage and Transfer
  Our database servers are located in the United States of America and will be accessed by Vertalo located in the United States of America, and our affiliate SeriesX.net, Inc. (“SeriesX”) or other service providers located in the United States or other countries. SeriesX will access and process Participant’s data held in our European Union servers from the U.S. pursuant to SeriesX’s E.U.-U.S. and Swiss-U.S. Privacy Shield certification. SeriesX’s Privacy Policy is located here.
  
  
• California Residents
  We do not monitor any opt-out or do not track mechanism, including general web browser “Do Not Track (DNT)” settings and/or signals.
  
  
• Children’s Online Privacy Protection Act (COPPA)
  We do not knowingly collect any personal information from children under the age of thirteen through the Site or Platform. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information to us. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@vertalo.com and we will endeavor to delete that information from our databases.
  
  
• Changes to this Privacy Policy
  We may change this Privacy Policy from time to time, and will post any changes as soon as they go into effect. By accessing and using the Site and/or the Platform after we post any changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
  
  
• Contact Vertalo
  Have questions or concerns about Vertalo, our Site/Platform, and/or privacy? Contact us at privacy@vertalo.com.