PRIVACY POLICY
This Privacy Policy explains how Great One Digital Asset Holdings LLC (collectively, "we," "our" or "us"), collects and uses your Personal Information and how we keep it secure. By accessing this website or other of our domains and URLs that post this Privacy Policy, using our services, including any mobile applications (collectively, "Services"), you agree you have read and understood this Privacy Policy and our Terms & Conditions. If you do not agree with any portion of this Privacy Policy, please do not access or use our Services or provide us with any Personal Information.
INFORMATION WE COLLECT AND HOW WE COLLECT IT
Depending on how you interact with us, we may collect personal information from or about you. When we use the term "Personal Information," we mean information that can help us directly or indirectly identify you. We may collect this information directly from you, from other third-party sources, and automatically from your use of our website. We may also collect some information that could be considered "sensitive" or "special category" information under certain data protection laws.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. We will endeavor to effect those changes within a reasonable timeframe.
A. INFORMATION YOU PROVIDE TO US
We or our service providers may collect the following Personal Information about you when you use the website and/or our Services:
Identifying Information. Such information may include your name, email address, phone number, and location information. This information may also include certain information required for Know Your Customer/Anti-Money Laundering ("KYC/AML"), such as postal address, country of residence, date of birth, Social Security Number, tax identification, photo identification, passport/driver's license, proof of residency, utility bill information, and other contact information you provide. If you provide your mobile phone number during registration or account verification, we may send you transactional SMS messages such as one-time passcodes (OTP) for authentication and security purposes. SMS consent is not shared with third parties or affiliates for marketing purposes.
Institutional Information. This includes information about our institutional clients, for onboarding and compliance purposes including: headquarters location, Federal Employer Identification Number (FEIN); names of affiliated entities, certificate of good standing, information required for KYC/AML and financial history and details (investment activity, bank statements, balance sheets, etc.).
Account Information. Such as information used to create your account such as login credentials (e.g., email/password), secure authentication information and account preferences.
Geolocation. This includes your approximate location (city/region) inferred from IP address.
Correspondence and Content. This includes information provided when you communicate with us, such as when you send us messages providing feedback, requesting support or seeking information, we may collect the information contained in such messages.
Financial and Transactional Information. Such information includes transaction activity including account activity, transaction details, investment selections, and wallet address (as described below). We may also collect information about your personal assets and liabilities including annual income, investments, and debts.
Other Information. You may choose to voluntarily provide other Personal Information to us that we have not solicited from you and in such instances, you are solely responsible for such information.
B. INFORMATION WE COLLECT AUTOMATICALLY
We may collect the following Personal Information automatically through your interactions with our website:
Wallet Address. We may collect the wallet address you use to connect to the website to block wallets that are associated with certain legally prohibited conduct from the website. Separately, we may collect your wallet address as part of "Usage Information" (as described below) to improve the website and user experience of the website.
Device Information. We may collect information about the device you use to access the Website such as the device type, operating system, browser type, and screen height and width. This information helps us optimize the website for different devices and troubleshoot any technical issues.
Usage Information. We may collect information about how you use the website including the time you access our website, pages you visit, the features and assets you interact with, the links you click, and the search queries you make. By analyzing this data, we gain a deeper understanding of user behavior which in turn allows us to make continuous improvements to the website and enhance the overall user experience.
We may collect this information through cookies and similar tracking technologies. Please also see our Cookie Notice for additional details regarding our use of cookies and other technologies to gather such information. We may use third party service providers like Google and MailChimp to collect such information. For example, Google utilizes the data collected to track and examine the use of this application, prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. To learn more about Google's privacy practices, click here. Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States. MailChimp enables us to, among other things, send and manage email campaigns across channels, serve advertisements, and create websites and landing pages. MailChimp also provides other related services, such as real-time data analytics and insights to help us track and personalize its marketing activities.
C. INFORMATION COLLECTED FROM OTHER SOURCES
We may collect certain Personal Information through third parties, including businesses we partner with to offer referrals to and integrations with our Services. This includes your name, email address, etc. We may also collect certain Personal Information through third-party sign in processes and other identity verification services. This includes your name, email address, phone number, postal address, username/account login, password. Finally, we may collect Personal Information through third-party social media companies and marketing vendors with whom we have agreements with to provide such services to us.
WHY WE COLLECT PERSONAL INFORMATION
We may use the Personal Information we collect for the following purposes:
Establish and Maintain Our Relationship with You. This includes creating and managing your account with us, processing requests for changes to your account.
Administering our Website and Services. For example, providing our products and services to you, understanding your needs and eligibility, processing billing and collection of any fees, administering our website and services, system administration and detecting usage patterns (including broad demographic information for aggregated use).
Communicating with You. We may provide you with information on developments and new features or products and service announcements, and use information to respond to your communications and requests.
Security. We may use information and measures to maintain the security or integrity of our website and services, including to prevent or stop an attack on our computer systems or networks, investigate possible wrongdoing in connection with the website and services, enforce our terms.
Legal Rights. We use information to exercise, establish or defend our legal rights, or to protect your vital interest or those of any other person.
Improve Our Products and Services. For example, we may conduct surveys, analytics, and troubleshooting.
Compliance with Law. We process information to comply with legal and regulatory requirements, including managing risk assessments for cryptocurrency transactions, checking your identity for authentication and KYC purposes and against money laundering and terrorist financing or answering your requests, and complying with industry self-regulatory, audit and security requirements.
We may also aggregate personal and other data captured by us so that the data is no longer capable of identifying an individual. Aggregated data may cover patterns of usage or information and data that you provide to us, and we reserve the right to use this aggregated information for the purposes of improving and enhancing our Services, generating insights, for use in marketing to other users and current and potential partners and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be Personal Information and is not covered by this Privacy Notice.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
HOW WE DISCLOSE PERSONAL INFORMATION
We may share Personal Information to the following categories of recipients:
Within our Company and Group. We may share information with our employees, officers, directors, partners, affiliates, direct or indirect subsidiaries, our ultimate holding company and any other subsidiary of that holding company, including their respective shareholders, directors, officers, affiliates, employees, contractors, agents, partners, insurers, and attorneys or representatives.
Service Providers. We may share your information with service providers that help us operate our business such as accountants, administrators, attorneys, auditors, compliance and IT consultants, custodians, SAAS (software as a service) providers, analytics providers, hosting providers and other third parties engaged by us to assist with or support our provision of services.
Authorities and Law Enforcement Agencies Worldwide. We will share information where we reasonably believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
Transactions. We may share information as part of a transaction, with third parties that require the personal information to execute the contemplated transactions.
We may also disclose Personal Information to third parties in the following circumstances:
In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others, including to defend ourselves from legal claims.
We reserve the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the digital tokens purchased or redeemed on the website.
HOW WE PROTECT PERSONAL INFORMATION
We use reasonable and appropriate technical and organizational measures designed to protect your Personal Information. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee complete security, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of Personal Information is at your own risk.
HOW LONG WE KEEP PERSONAL INFORMATION
We keep Personal Information for as long as reasonably necessary for the purposes described in this Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
INTERNATIONAL DATA TRANSFERS
The Personal Information that we collect or receive about you may be transferred to and processed by recipients who are located in a jurisdiction where the level of data protection may not be equivalent to the level of protection applicable at your location. Where local laws require, we will take steps to ensure that any transfer of Personal Information outside of the originating jurisdiction is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place. If your location lacks international data transfer instructions or standard forms from the local supervisory authority, we may use other legally acceptable mechanisms from other jurisdictions.
CHILDREN
The website is intended for general audiences and is not directed at children. We do not knowingly collect Personal Information from children. If you are a parent or guardian and believe we have collected Personal Information about a child, please contact us at [email protected].
LINKS TO OTHER WEBSITES
The website may contain links to third-party websites. Any access to and use of such third-party websites is not governed by this Privacy Notice, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
SMS MESSAGING
If you provide your phone number on the GreatX® platform, you may receive SMS messages for account authentication, verification codes (OTP), or important account-related notifications. Message frequency varies depending on user activity. Message and data rates may apply. You can reply STOP to opt out of SMS messages at any time. Reply HELP for support. SMS consent and phone numbers collected for SMS communication are not shared with any third parties or affiliates for marketing purposes.
YOUR RIGHTS AND CHOICES
Depending on how you interact with us, you have certain rights regarding your Personal Information. Please note any rights described in this Privacy Policy are subject to exemptions and other limitations under applicable law.
Depending on where you are located and applicable law, you may have the following rights:
Right to Know and Access. You may have the right to know and access the Personal Information we have collected about you.
Right to Delete. You may have the right to request that we delete the Personal Information we have collected about you, subject to certain legal exceptions.
Right to Correct. You may have the right to request that we correct any inaccurate Personal Information we have collected about you.
Data Portability. At your request, we will provide you with your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Information to another controller.
To Object to or Restrict Processing. You may object to or restrict processing of your personal information so long as we are processing such personal information on the legal basis of pursuing our legitimate interest, under applicable data protection laws.
Right to No Discrimination. You will not receive any discriminatory treatment by us for the exercise of your privacy rights as outlined in this Privacy Policy.
Right to Contact Supervisory Authority. You may have the right to complain to the relevant supervisory authority.
Right to Appeal. Depending on where you are a resident, you may have the right to appeal our responses to your requests to exercise any of the rights listed in this Privacy Policy.
To exercise these rights, please use the information below in How to Contact Us and include "Rights Request" in the subject line.
MARKETING COMMUNICATIONS
In addition to the rights listed above, you have certain controls on our marketing communications. We may use your Personal Information to inform you about our products or services that we believe will be of interest to you and/or to provide you with our newsletter. We may contact you by email, post, or telephone, or through other communication channels and we may use cookies or other online tracking as described in our Cookie Notice. In all cases, we will respect your preferences regarding how you would like us to manage marketing activity with you. You can manage your marketing preferences in several ways:
Direct Marketing. You can ask us to stop direct marketing at any time. You can ask us to stop sending email marketing by clicking on the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively, you can contact [email protected]. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email).
Cookies and Online Tracking. You can change the way your browser manages Cookies, which may be used to deliver online advertising and by using the options explained in our Cookie Notice.
CALIFORNIA SHINE THE LIGHT
Under California's "Shine the Light" law (Civil Code section 1798.83), California customers can ask certain businesses to share details about their practices related to disclosing or sharing personal information. If you want to find out how this might apply to you and what rights you might have, just email us at [email protected] and include "Shine the Light Request," in the subject line.
UPDATES TO THIS PRIVACY POLICY
If we make changes to this Privacy Policy, we may notify you by updating it with a "Last Updated" date at the top. The most current version of our Privacy Policy will be available on our website.
SOCIAL SECURITY PROTECTION POLICY STATEMENT
We seek to protect the confidentiality of Social Security numbers (SSNs) by maintaining physical, electronic, and procedural safeguards. We limit access to SSNs to help protect against their loss, misuse or unlawful disclosure. We do not disclose SSNs to third parties except where required or permitted by law.
HOW TO CONTACT US
Great One Digital Asset Holdings LLC is committed to protecting your privacy. For any privacy-related inquiries, please contact us at: Email: [email protected] Address: GreatX® · One Cowboys Way · Frisco, TX 75034. Our Data Protection Officer can be reached at [email protected] for any specific privacy concerns or data protection inquiries.