PRIVACY
NOTICE
Last updated February 19, 2021
Thank
you for choosing to be part of our community at Elite Assets Equity
("
Company
", "we", "us",
"our"). We are committed to protecting your personal information and
your right to privacy. If you have any questions or concerns about this privacy notice,
or our practices with regards to your personal information, please contact us at info@eliteassetsequity.com .
When you
visit our website
https://www.eliteassetsequity.com/ (the
"Website"),
and more generally, use any of our services (the
"Services", which include the
Website
), we appreciate that you are trusting us with your
personal information. We take your privacy very seriously. In this privacy notice, we seek
to explain to you in the clearest way possible what information we collect, how we use it
and what rights you have in relation to it. We hope you take some time to read through it
carefully, as it is important. If there are any terms in this privacy notice that you do not
agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information
collected through our Services (which, as described above, includes our
Website
), as well as, any related services, sales, marketing or
events.
Please read this privacy notice carefully as
it will help you understand what we do with the information that we
collect.
TABLE OF CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:
We collect
personal information that you provide to us.
We
collect personal information that you voluntarily provide to us when you
register on the
Website,
express an interest in obtaining
information about us or our products and Services, when you participate in
activities on the
Website
or otherwise when you contact us.
The
personal information that we collect depends on the context of your interactions with us
and the
Website
, the choices you make and the products and features you use. The personal
information we collect may include the following:
Personal Information Provided by You. We
collect
names ;
phone numbers ;
email addresses ;
usernames ;
passwords ;
contact or authentication data ;
and other similar information.
All
personal information that you provide to us must be true, complete and accurate, and you
must notify us of any changes to such personal information.
Information automatically collected
In Short:
Some
information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when
you visit our
Website
.
We
automatically collect certain information when you visit, use or navigate the
Website
. This information does not reveal your specific identity (like your
name or contact information) but may include device and usage information, such as your
IP address, browser and device characteristics, operating system, language preferences,
referring URLs, device name, country, location, information about how and when you use
our
Website
and other technical information. This information is primarily needed
to maintain the security and operation of our
Website
, and for our internal analytics and reporting purposes.
Like
many businesses, we also collect information through cookies and similar technologies.
The
information we collect includes:
- Log and Usage Data. Log and usage data is
service-related, diagnostic, usage and performance information our servers
automatically collect when you access or use our
Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
- Device Data. We collect device data such as
information about your computer, phone, tablet or other device you use to access the
Website . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
- Location Data. We collect location data such
as information about your device's location, which can be either precise or
imprecise. How much information we collect depends on the type and settings of the
device you use to access the
Website . For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW
DO WE USE YOUR INFORMATION?
In Short: We
process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with
our legal obligations, and/or your consent.
We use
personal information collected via our
Website
for a variety of business purposes described below. We process your
personal information for these purposes in reliance on our legitimate business
interests, in order to enter into or perform a contract with you, with your consent,
and/or for compliance with our legal obligations. We indicate the specific processing
grounds we rely on next to each purpose listed below.
We use
the information we collect or receive:
- To facilitate account creation and logon
process. If you choose to link your account with us to a third-party
account (such as your Google or Facebook account), we use the information you
allowed us to collect from those third parties to facilitate account creation and
logon process for the performance of the contract.
- To post testimonials. We post
testimonials on our
Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at info@eliteassetsequity.com and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your
information to request feedback and to contact you about your use of our
Website .
- To enable user-to-user
communications. We may use your information in order to enable
user-to-user communications with each user's consent.
- To manage user accounts. We may use
your information for the purposes of managing our account and keeping it in working
order.
- To send administrative information to you.
We may use your personal information to send you product, service and new
feature information and/or information about changes to our terms, conditions, and
policies.
- To protect our Services. We may use
your information as part of our efforts to keep our
Website safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies
for business purposes, to comply with legal and regulatory requirements or in
connection with our contract.
- To respond to legal requests and prevent
harm. If we receive a subpoena or other legal request, we may need
to inspect the data we hold to determine how to respond.
- Fulfill and manage your orders.
We may use your information to fulfill and manage your orders,
payments, returns, and exchanges made through the
Website .
- Administer prize draws and
competitions. We may use your information to administer prize draws
and competitions when you elect to participate in our competitions.
- To deliver and facilitate delivery of
services to the user. We may use your information to provide you
with the requested service.
- To respond to user inquiries/offer support
to users. We may use your information to respond to your inquiries
and solve any potential issues you might have with the use of our Services.
- To send you marketing and promotional
communications. We and/or our third-party marketing partners may use
the personal information you send to us for our marketing purposes, if this is in
accordance with your marketing preferences. For example, when expressing an interest
in obtaining information about us or our
Website , subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
- Deliver targeted advertising to
you. We may use your
information to develop and display personalized content and advertising (and work
with third parties who do so) tailored to your interests and/or location and to
measure its effectiveness.
In Short: We only share
information with your consent, to comply with laws, to provide you with
services, to protect your rights, or to fulfill business
obligations.
We
may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data
if you have given us specific consent to use your personal information for a
specific purpose.
- Legitimate Interests: We may
process your data when it is reasonably necessary to achieve our legitimate
business interests.
- Performance of a Contract: Where
we have entered into a contract with you, we may process your personal
information to fulfill the terms of our contract.
- Legal Obligations: We may
disclose your information where we are legally required to do so in order to
comply with applicable law, governmental requests, a judicial proceeding, court
order, or legal process, such as in response to a court order or a subpoena
(including in response to public authorities to meet national security or law
enforcement requirements).
- Vital Interests: We may disclose
your information where we believe it is necessary to investigate, prevent, or
take action regarding potential violations of our policies, suspected fraud,
situations involving potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or
share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In Short:
We may use cookies and other tracking
technologies to collect and store your
information.
We may use cookies and similar
tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how
we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice
.
5. HOW LONG DO
WE KEEP YOUR INFORMATION?
In Short:
We keep your information for as long
as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by
law.
We will only keep your
personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer
retention period is required or permitted by law (such as
tax, accounting or other legal requirements). No purpose in
this notice will require us keeping your personal
information for longer than
the period of time in
which users have an account with us
.
When we have no ongoing
legitimate business need to process your personal
information, we will either delete or anonymize such
information, 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.
6. HOW DO WE
KEEP YOUR INFORMATION SAFE?
In Short:
We aim to protect your personal
information through a system of organizational and
technical security measures.
We have implemented
appropriate technical and organizational security measures
designed to protect the security of any personal information
we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security, and improperly
collect, access, steal, or modify your information. Although
we will do our best to protect your personal information,
transmission of personal information to and from our
Website
is at your own risk. You should only access the
Website
within a secure environment.
7. DO WE
COLLECT INFORMATION FROM
MINORS?
In
Short: We do not knowingly collect
data from or market to children under 18 years of
age.
We do not knowingly solicit
data from or market to children under 18 years of age. By
using the
Website
, 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
Website
. If we learn that personal information from users
less than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become
aware of any data we may have collected from children under
age 18, please contact us at
info@eliteassetsequity.com
.
8. WHAT ARE
YOUR PRIVACY RIGHTS?
In
Short:
In some regions, such as the European Economic
Area, you have rights that allow you greater access to
and control over your personal information.
You may review, change, or terminate your account
at any time.
In some regions (like the
European Economic Area), you have certain rights under
applicable data protection laws. These may include the right
(i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii)
to restrict the processing of your personal information; and
(iv) if applicable, to data portability. In certain
circumstances, you may also have the right to object to the
processing of your personal information. To make such a
request, please use the contact
details
provided below. We will consider and act upon any
request in accordance with applicable data protection
laws.
If we are relying on your
consent to process your personal information, you have the
right to withdraw your consent at any time. Please note
however that this will not affect the lawfulness of the
processing before its withdrawal, nor will it affect the
processing of your personal information conducted in
reliance on lawful processing grounds other than
consent.
If you have questions or
comments about your privacy rights, you may email us at
info@eliteassetsequity.com
.
Account Information
If you would
at any time like to review or change the
information in your account or terminate
your account, you can:
-
Log in to your account settings and update your user account.
Upon your request to
terminate your account, we will deactivate or delete
your account and information from our active databases.
However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply
with applicable legal requirements.
Cookies and similar
technologies: Most Web browsers are set
to accept cookies by default. If you prefer, you can usually
choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies,
this could affect certain features or services of our
Website
.
Opting out of email
marketing: You can unsubscribe from our
marketing email list at any time by clicking on the
unsubscribe link in the emails that we send or by contacting
us using the details provided below. You will then be
removed from the marketing email list — however, we may
still communicate with you, for example to send you
service-related emails that are necessary for the
administration and use of your account, to respond to
service requests, or for other non-marketing purposes. To
otherwise opt-out, you may:
-
Access your account settings and update your preferences.
9. CONTROLS
FOR DO-NOT-TRACK FEATURES
Most web browsers and some
mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to
signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this
stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do
not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to
be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform
you about that practice in a revised version of this privacy
notice.
10. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short:
Yes, if you are a resident of
California, you are granted specific rights regarding
access to your personal information.
California Civil Code Section
1798.83, also known as the "Shine The Light" law, permits
our users who are California residents to request and obtain
from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to
third parties for direct marketing purposes and the names
and addresses of all third parties with which we shared
personal information in the immediately preceding calendar
year. If you are a California resident and would like to
make such a request, please submit your request in writing
to us using the contact information provided
below.
If you are under 18 years of
age, reside in California, and have a registered account
with
the Website
, you have the right to request removal of unwanted
data that you publicly post on the
Website
. To request removal of such data, please contact us
using the contact information provided below, and include
the email address associated with your account and a
statement that you reside in California. We will make sure
the data is not publicly displayed on the
Website
, but please be aware that the data may not be
completely or comprehensively removed from all our systems
(e.g. backups, etc.).
CCPA Privacy Notice
The California
Code of Regulations defines a "resident"
as:
(1) every individual who is in
the State of California for other than a temporary or
transitory purpose and
(2) every individual who is
domiciled in the State of California who is outside the
State of California for a temporary or transitory
purpose
All other individuals are
defined as "non-residents."
If this definition of
"resident" applies to you, we must adhere to certain rights
and obligations regarding your personal
information.
What categories of
personal information do we
collect?
We have collected the
following categories of personal information in the past
twelve (12) months:
Category |
Examples |
Collected |
A.
Identifiers
|
Contact
details, such as real name, alias, postal
address, telephone or mobile contact number,
unique personal identifier, online
identifier, Internet Protocol address, email
address and account name
|
|
B. Personal
information categories listed in the
California Customer Records
statute
|
Name, contact
information, education, employment,
employment history and financial
information
|
YES
|
C. Protected
classification characteristics under
California or federal law
|
Gender and
date of birth
|
|
D. Commercial
information
|
Transaction
information, purchase history, financial
details and payment
information
|
|
E. Biometric
information
|
Fingerprints
and voiceprints
|
|
F. Internet or
other similar network activity
|
Browsing
history, search history, online behavior,
interest data, and interactions with our and
other websites, applications, systems and
advertisements
|
|
G. Geolocation
data
|
Device
location
|
|
H. Audio,
electronic, visual, thermal, olfactory, or
similar information
|
Images and
audio, video or call recordings created in
connection with our business
activities
|
|
I.
Professional or employment-related
information
|
Business
contact details in order to provide you our
services at a business level, job title as
well as work history and professional
qualifications if you apply for a job with
us
|
|
J. Education
Information
|
Student
records and directory
information
|
|
K. Inferences
drawn from other personal
information
|
Inferences
drawn from any of the collected personal
information listed above to create a profile
or summary about, for example, an
individual’s preferences and
characteristics
|
|
We may also collect other
personal information outside of these categories instances
where you interact with us in-person, online, or by phone or
mail in the context of:
- Receiving help through our
customer support channels;
- Participation in customer
surveys or contests; and
- Facilitation in the
delivery of our Services and to respond to your
inquiries.
How do we use and
share your personal information?
More information about
our data collection and sharing practices can be
found in this privacy notice
.
You may contact us
by email at
info@eliteassetsequity.com
,
or by referring to the
contact details at the bottom of this document.
If you are using an
authorized agent to exercise your right to opt-out
we may deny a request if the authorized agent does
not submit proof that they have been validly
authorized to act on your behalf.
Will your
information be shared with anyone
else?
We may disclose your
personal information with our service providers
pursuant to a written contract between us and each
service provider. Each service provider is a
for-profit entity that processes the information on
our behalf.
We may use your
personal information for our own business purposes,
such as for undertaking internal research for
technological development and demonstration. This is
not considered to be "selling" of your personal
data.
Your rights
with respect to your personal
data
Right to request
deletion of the data - Request to
delete
You can ask for the
deletion of your personal information. If you ask us
to delete your personal information, we will respect
your request and delete your personal information,
subject to certain exceptions provided by law, such
as (but not limited to) the exercise by another
consumer of his or her right to free speech, our
compliance requirements resulting from a legal
obligation or any processing that may be required to
protect against illegal activities.
Right to be
informed - Request to know
Depending on the
circumstances, you have a right to know:
- whether we collect
and use your personal information;
- the categories of
personal information that we collect;
- the purposes for
which the collected personal information is
used;
- whether we sell
your personal information to third parties;
- the categories of
personal information that we sold or disclosed
for a business purpose;
- the categories of
third parties to whom the personal information
was sold or disclosed for a business purpose;
and
- the business or
commercial purpose for collecting or selling
personal information.
In accordance with
applicable law, we are not obligated to provide or
delete consumer information that is de-identified in
response to a consumer request or to re-identify
individual data to verify a consumer
request.
Right to
Non-Discrimination for the Exercise of a
Consumer’s Privacy Rights
We will not
discriminate against you if you exercise your
privacy rights.
Verification
process
Upon receiving your
request, we will need to verify your identity to
determine you are the same person about whom we have
the information in our system. These verification
efforts require us to ask you to provide information
so that we can match it with information you have
previously provided us. For instance, depending on
the type of request you submit, we may ask you to
provide certain information so that we can match the
information you provide with the information we
already have on file, or we may contact you through
a communication method (e.g. phone or email) that
you have previously provided to us. We may also use
other verification methods as the circumstances
dictate.
We will only use
personal information provided in your request to
verify your identity or authority to make the
request. To the extent possible, we will avoid
requesting additional information from you for the
purposes of verification. If, however, we cannot
verify your identity from the information already
maintained by us, we may request that you provide
additional information for the purposes of verifying
your identity, and for security or fraud-prevention
purposes. We will delete such additionally provided
information as soon as we finish verifying
you.
Other privacy
rights
- you may object to
the processing of your personal data
- you may request
correction of your personal data if it is
incorrect or no longer relevant, or ask to
restrict the processing of the data
- you can designate
an authorized agent to make a request under the
CCPA on your behalf. We may deny a request from
an authorized agent that does not submit proof
that they have been validly authorized to act on
your behalf in accordance with the CCPA.
- you may request to
opt-out from future selling of your personal
information to third parties. Upon receiving a
request to opt-out, we will act upon the request
as soon as feasibly possible, but no later than
15 days from the date of the request
submission.
To exercise these
rights, you can contact us
by
email at
info@eliteassetsequity.com ,
or by referring to the
contact details at the bottom of this document. If you have
a complaint about how we handle your data, we would like to
hear from you.
11. DO
WE MAKE UPDATES TO THIS
NOTICE?
In Short:
Yes, we will update this notice as
necessary to stay compliant with relevant
laws.
We may update this
privacy notice from time to time. The updated
version will be indicated by an updated "Revised"
date and the updated version will be effective as
soon as it is accessible. If we make material
changes to this privacy notice, we may notify you
either by prominently posting a notice of such
changes or by directly sending you a notification.
We encourage you to review this privacy notice
frequently to be informed of how we are protecting
your information.
12.
HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
If you have questions
or comments about this notice, you may
email us
at
info@eliteassetsequity.com