Privacy Policy

1. Information We Collect

1.1 Personal Information

We collect personal information that you provide to us, including:

• Name, email address, phone number, and mailing address
• Date of birth and Social Security number (for identity verification)
• Government-issued identification documents
• Employment information and income details
• Investment experience and accredited investor status
• Bank account and payment information

1.2 Financial Information

To comply with securities regulations and provide our services, we collect:

• Investment portfolio information and transaction history
• Net worth and income verification documents
• Tax identification numbers and related documentation
• Banking and payment method details
• Credit and background check information

1.3 Technical Information

We automatically collect certain technical information, including:

• IP address, browser type, and operating system
• Device identifiers and mobile network information
• Usage data, including pages visited and time spent on our platform
• Cookies and similar tracking technologies
• Location data (with your consent)

1.4 Blockchain and Token Information

Related to our tokenized investment platform:

• Digital wallet addresses and transaction records
• Token ownership and transfer history
• Smart contract interactions
• Blockchain network data

2. How We Use Your Information

2.1 Platform Operations

• Creating and managing your account
• Processing investment transactions and managing your portfolio
• Providing customer support and responding to inquiries
• Sending important account notifications and updates
• Facilitating token transfers and marketplace transactions

2.2 Compliance and Legal Requirements

• Verifying your identity and accredited investor status (KYC)
• Monitoring for suspicious activities and preventing fraud (AML)
• Complying with securities laws and regulatory reporting
• Responding to legal requests and court orders
• Maintaining records as required by law

2.3 Service Improvement

• Analyzing platform usage to improve our services
• Developing new features and investment opportunities
• Conducting research and analytics
• Personalizing your platform experience

2.4 Marketing and Communications

• Sending promotional materials about new investment opportunities
• Providing educational content about critical minerals and investing
• Conducting surveys and market research
• Inviting you to events and webinars

3. Information Sharing and Disclosure

3.1 Service Providers

We may share your information with trusted third-party service providers who assist us in:

• Payment processing and banking services
• Identity verification and background checks
• Cloud hosting and data storage
• Customer support and communication services
• Legal and accounting services
• Marketing and analytics platforms

3.2 Regulatory and Legal Compliance

We may disclose your information to:

• Securities and Exchange Commission (SEC) and other regulatory bodies
• Financial Crimes Enforcement Network (FinCEN)
• Law enforcement agencies when required by law
• Courts and legal proceedings
• Tax authorities for reporting purposes

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

3.4 Consent-Based Sharing

We may share your information with your explicit consent for specific purposes, such as connecting you with investment advisors or participating in research studies.

4. Data Security

4.1 Security Measures

We implement industry-standard security measures to protect your information:

• 256-bit SSL encryption for data transmission
• Advanced encryption for data storage
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Employee background checks and security training
• Secure data centers with physical access controls

4.2 Blockchain Security

For blockchain-related data:

• Private key management and secure wallet infrastructure
• Smart contract security audits
• Immutable transaction records on secure blockchain networks
• Cold storage for digital assets

4.3 Incident Response

In the event of a data breach, we will notify affected users and relevant authorities within 72 hours as required by applicable laws.

5. Your Privacy Rights

5.1 Access and Portability

• Request a copy of your personal information
• Download your investment data in a portable format
• Review your transaction history and account details

5.2 Correction and Updates

• Update your personal and contact information
• Correct inaccurate data in your profile
• Modify your communication preferences

5.3 Deletion and Restriction

• Request deletion of your personal information (subject to legal requirements)
• Restrict processing of your data for specific purposes
• Object to certain uses of your information

5.4 Marketing Opt-Out

You can opt out of marketing communications at any time by clicking the unsubscribe link in emails or updating your preferences in your account settings.

6. Cookies and Tracking Technologies

6.1 Types of Cookies

We use several types of cookies and similar technologies:

• Essential Cookies: Required for platform functionality and security
• Performance Cookies: Help us understand how users interact with our platform
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Used to deliver relevant advertisements

6.2 Cookie Management

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some platform features.

6.3 Third-Party Analytics

We use third-party analytics services, including:

• Google Analytics for website usage analysis
• Mixpanel for user behavior tracking
• Hotjar for user experience optimization

7. International Data Transfers

7.1 Data Location

Your information may be processed and stored in the United States and other countries where our service providers operate. We ensure appropriate safeguards are in place for international transfers.

7.2 Transfer Mechanisms

For international transfers, we rely on:

• Standard Contractual Clauses approved by regulatory authorities
• Adequacy decisions for countries with equivalent privacy protections
• Binding Corporate Rules for transfers within corporate groups

8. Data Retention

8.1 Retention Periods

We retain your information for different periods based on the type of data:

• Account Information: For the duration of your account plus 7 years
• Transaction Records: 7 years after the transaction date
• Identity Verification: 5 years after account closure
• Marketing Data: Until you opt out or 3 years of inactivity
• Blockchain Records: Permanently stored on the blockchain

8.2 Legal Requirements

Some information must be retained longer to comply with securities laws, tax regulations, and anti-money laundering requirements.

9. Children's Privacy

Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

10. State-Specific Privacy Rights

10.1 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected and how it's used
• Right to delete personal information (subject to exceptions)
• Right to opt out of the sale of personal information
• Right to non-discrimination for exercising privacy rights
• Right to correct inaccurate personal information
• Right to limit use of sensitive personal information

10.2 Other State Laws

We comply with privacy laws in other states, including Virginia's Consumer Data Protection Act (VCDPA) and Colorado's Privacy Act (CPA), providing similar rights to residents of those states.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by:

• Sending an email to your registered email address
• Posting a notice on our platform
• Updating the "Last Updated" date at the top of this policy

Your continued use of our platform after the effective date of changes constitutes acceptance of the updated Privacy Policy.

12. Contact Information

If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact us: