Privacy Policy

What type of information we collect

We may collect two types of data and information from our Users.

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., mouse movements, mouse clicks, actions, online browsing etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:

• Account Information: When you sign up and register to use the Services, you may be asked to provide certain details about yourself, such as your name and email address.

• KYC Information: We may collect information required to complete know-your-customer and identity verification checks, such as your name, email address, and address. KYC checks are completed using Sumsub, and such information may be processed by Sumsub in connection with those checks.

• Voluntary Information: We may collect information that you provide to us voluntarily. Further, we may collect information when you respond to communications from us, communicate with us via email, or share additional information about yourself through your use of the Services. We may also collect feedback, suggestions, complaints, bug reports, and other reports that you send to us.

• Usage and Online Activity Information: We may collect information regarding your activity through the Services, such as your clicks, actions, and other interactions with the Services.

• Device and Technical Information: We may collect certain Personal Information from your device or browser. Such information may include browser type, wallet type, and geolocation information collected through Google Analytics 4 (GA4). We do not collect IP addresses. We do not collect MAC addresses, UUIDs, or similar unique device identifiers, except to the extent such information may be incidentally processed by our service providers in connection with the Services.

For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

Pixels and other technologies

We may use pixels, tags, web beacons, and similar technologies or methods of web and mobile analytics to gather, store, and track certain information relating to your access to and activity through the Services, including when you visit our website(s).

A “pixel” is a small piece of code, often embedded in a webpage, email, advertisement, or other digital content, that allows us or our service providers to collect information about your interactions with the Services. Pixels may be used for various purposes, including measuring website traffic and usage, understanding how users interact with our Services, determining whether a page or email has been viewed, measuring the effectiveness of our marketing campaigns, and improving the performance and functionality of the Services.

We may use pixels and similar technologies to collect information such as your IP address, device and browser information, pages viewed, links clicked, referring URLs, timestamps, and other information about your interactions with the Services. These technologies may also allow third-party service providers to collect information about your interactions with our website(s) and other online services.

Because pixels are not stored on your device in the same manner as cookies, they generally cannot be removed through your browser’s cookie settings. However, you may be able to limit certain tracking by adjusting your browser or device settings, using available opt-out tools or disabling the loading of images or similar content where applicable. Please note that if you limit or block these technologies, certain features of the Services, analytics, or communications may not function as intended.

How we use the information

We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for any of the following purposes:

• To communicate with you and to keep you informed of our latest updates;

• To set up your account and to provide the Services;

• To identify and authenticate your access to certain features of the Services;

• To send you relevant push notifications, which are based on different alerts of events identified by the Services;

• To perform research or to conduct analytics in order to improve and customize the Services to your needs and interests;

• To support and troubleshoot the Services and to respond to your queries;

• To analyze consumer trends on an aggregate and anonymized basis and share such trends with our partners;

• To investigate and resolve disputes in connection with your use of the Services;

• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and

• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

With whom we share the information and for what purpose

We do not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy.

We may share information, including Personal Information, with the following recipients: (i) third party services that you choose to connect to your account on our Service; (ii) our subsidiaries and affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company. In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof), the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalization and analytics.

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by connecting your account on the Service with third party services or by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.

You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

Specifically, we use Wirex and Privy to process, use, and/or store certain user data in connection with the Services. By using our Services, you acknowledge and agree that your data may be processed, used, and stored in accordance with the respective privacy policies of: (i) Wirex, at: https://help.wirexapp.com/article/us-privacy-data-retention-global-1630; and (ii) Privy, at: https://www.privy.io/privacy-policy. We encourage you to review these policies to understand how your data may be handled by our service providers.

Wirex and Privy implement security measures designed to help protect your information. However, no method of transmission, processing, or storage is completely secure, and we cannot guarantee absolute security.

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to Personal Information, including through adequate contractual measures. You hereby consent to the transfer of Personal Information to countries outside the European Union.

For how long we retain the information

We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we will cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third-parties) or that we shall remove your Personal Information (subject to any other legal obligation that may require us to keep the information).

Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements. Without derogating from the foregoing, in any other case we will retain the information for a maximum period of three years. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your Rights

Certain jurisdictions provide users with certain statutory rights with respect to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have some/all of the following rights available to you:

• Right to verify your information (to access, delete, change or update any personal information relating to you. For example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted);

• Right to see what, if any, personal information about you we have;

• Right to request that we erase information about you (subject to any other legal obligation that may require us to keep the information);

• Right to restrict us from processing information pertaining to you; and

• Right to export information in a portable format;

If you wish to exercise any of these rights, please contact us at: info@altura.trade. When handling your request, we may ask for additional information to confirm your identity (which may include personal information). However, please note that if you choose not to allow us to process your personal information, we may not be able to provide you the Services.

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at info@altura.trade. If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with applicable law, you can complain to your applicable data protection authority.

How we protect your information

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at info@altura.trade.

Minors

The Services are not designated to individuals under the age of 13. If you are under 13 years old, you should not use the Services, nor provide any personal information to us.

We reserve the right to access and verify any personal information collected from you by us. In the event that we become aware that an individual under the age of 13 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, it will be advisable to contact us at info@altura.trade.

Updates or amendments to the Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website (as reflected in the "Last Revised" heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or via email. We encourage you to review this Privacy Policy regularly for any changes.

Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at info@altura.trade.

Information about us

The details of the Company are as follows: