Purple Trader Privacy Policy

Effective Date: January 3rd, 2022
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Purple Creator, Inc (or “Purple Trader” or “we,” “us” or “our”) respects your privacy. This Privacy Policy (“Policy”) describes how we collect, use, protect and disclose Personal Data in connection with your use of our websites, including, but not limited to, www.purpletrader.io along with the features, functionalities, browser extensions and other services available through our websites (collectively, our “Websites”) and/or interacting with us or submitting anything to us through our Websites or other platform operated by us or on our behalf, including, without limitation our presence on any social media sites and our communities on third party platforms, including, without limitation, our Community Discord (collectively, with our Websites, our “Platform”).

You can access and interact with our Platform in many ways, including from a computer or mobile device. This Policy applies regardless of how you access or interact with our Platform. Depending on how you interact with our Platform, there may be some cases where we need to provide you with additional information about how we collect, use, protect or disclose your Personal Data and/or what options you have regarding our collection, use or disclosure of your Personal Data. We may provide this additional information through notices on our Websites or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Policy.

Please read this Policy carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Policy, please do not use, or otherwise interact with our Platform, provide us with your Personal Data or authorize any third party to make your Personal Data available to us. By using or interacting with our Platform, you acknowledge that you understand that we may use your Personal Data as described in this Policy. Please note, as described in this Policy, we may receive your Personal Data from third parties that have not expressly told you that they will provide your Personal Data to us. If you have any questions about how we collect, use, protect or disclose your Personal Data in connection with our Platform, please contact us by email at purpleteam@purpletrader.io.

THE BLOCKCHAIN

Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.

This means that by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain can’t be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.

In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens) it will be necessary to write certain personal data, such as your wallet address, onto the blockchain; this is done through a smart contract and requires you to execute such transactions using your wallet’s private key.

In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

PERSONAL DATA AND OTHER INFORMATION WE COLLECT

Our primary goals in collecting Personal Data are to provide and improve our Platform, conduct our business operations, to communicate with people and to enable visitors to our Websites to easily navigate and enjoy them.

When we refer to “Personal Data” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us, such as a person’s activity on our Websites when associated with their username. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.

Categories of Personal Data We Collect

Depending on how you access, use, or otherwise interact with our Platform, we, or third parties acting on our behalf, may collect the following categories of Personal Data about you:
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Identifiers and contact information, such as your real name, alias, email address, telephone number, postal address, physical address, unique personal identifier, government-issued identification number, online identifier, IP address and other similar information;
Demographic information, such as your age, gender, ethnicity, national origin, and other similar information;
Financial information, such as your bank account number, credit card number, debit card number, digital wallet information and other similar information;
Internet and other similar network activity information, such as your browsing history, search history, interactions with our Platform and online advertisements and other similar information;
Communication information, such as information contained in voice mails, chats, emails, and other similar information;
Location information, such as where you live, where you are located and other similar information;
Preference information, such as your interests, hobbies, opinions, and other similar information; and
Other information you provide to us.

Other Information We Collect
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We, or third parties acting on our behalf, may collect certain information about the device you use when you interact with our Platform through the normal operation of our Platform and through the use of cookies, pixels, and other web technologies (collectively, “Usage Data”). Usage Data, by itself, generally does not identify the specific person using the device that generated it. This means that Usage Data usually will not be considered Personal Data and our use of such Usage Data is not subject to this Policy unless required pursuant to applicable law. However, if we link Usage Data directly with other Personal Data or other information that could identify you, we will treat the linked Usage Data as Personal Data and use the linked Usage Data as described in this Policy.

Depending on how you interact with our Platform, the Usage Data that we, or third parties acting on our behalf, may collect may include:

Device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a device used to access, use, or interact with our Platform;
Information about online interactions with our Platform, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with a device used to access, use, or interact with our Platform;
Information about internet and network activity, such as websites visited, search engine results and similar information associated with a device that accesses or interacts with our Platform online;
Internet and other similar network activity information, such as your browsing history, search history, interactions with our Platform and online advertisements and other similar information;
Other information automatically collected by cookies and other technologies on our Platform; and
Any other information that a browser or device automatically sends whenever connected to a website or an online application.

HOW WE COLLECT PERSONAL DATA
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A large portion of the Personal Data we, or third parties acting on our behalf, collect is collected directly from our users and others who provide their Personal Data to us directly. In some cases, we may collect Personal Data from third parties in the ways described in this Policy.

Directly from You

When you access, use, or otherwise interact with our Platform, or otherwise engage with us in connection with our Platform, such as requesting more information about us or communicating with us, we may ask you to provide certain Personal Data. Some of the Personal Data we request with respect to certain features of our Platform may not be required, however, we will let you know if specific Personal Data is required to use those features. If you do not provide us with the Personal Data required to use a certain feature on our Platform, you will not be able to use that feature, especially those features where we are legally required to collect the Personal Data and those where it is impossible for the feature to operate without the required Personal Data.

From Third Parties

We, or third parties acting on our behalf, may collect Personal Data about you from third parties, such as online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Services”). When you access, use, or interact with our Platform through certain Third Party Services, associate your access, use or interaction with our Platform with Third Party Services or share our content via Third Party Services, you acknowledge that you are authorizing use to collect, share, store and use any Personal Data we receive from those Third Party Services about you. In some cases, you may be able to revoke our access to your Personal Data and other content and information we receive from a Third Party Service by changing the appropriate settings for your account with the that Third Party Service.

We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with the operation of our Platform (“Operational Service Providers”). Operational Service Providers may include, without limitation, hosting providers and payment providers.

We, or third parties acting on our behalf, may receive Personal Data about you from our affiliates (our “Affiliates”). This Personal Data may include, without limitation, information related to your access, use or interaction with our Affiliates and/or the services, products, and other things they provide.

We, or third parties acting on our behalf, may also receive Personal Data about you from other third parties, such as other users of our Platform and those that refer you to our Platform.

Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more third parties.

HOW WE COLLECT USAGE DATA

We, and third parties acting on our behalf, collect Usage Data in a variety of ways. Some Usage Data, such as the IP address of a device attempting to access, use or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Data, such as information about what features of our Platform are popular, help us to improve and advertise our Platform. The primary ways Usage Data is collected in connection with our Platform are through:
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The systems we use to make our Platform available to you. When you access, use, or interact with our Platform, these systems automatically record certain information that your browser or device sends whenever you visit a website or utilize an online application as well as information about how long your device is connected to our Platform and the activities that device engages in while connected.
Cookies, which are small data files that are uploaded to the hard drive or other storage on devices that access, use, or interact with portions of our Platform. Among other things, cookies help us improve our Platform and our users’ experience. We use cookies to see which areas and features are popular and to understand usage of our Platform. We use first party cookies, served directly by us to the devices that access our Platform, to recognize those devices when they revisit. We also use third party cookies, which are cookies that are placed by other parties we work with. These third parties may upload unique cookies to your device to collect information about your use of our Platform and potentially other online activities you engage in over time across different websites and other online applications. The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be uploaded to your device, including how to disable such technologies. You can disable our cookies, or all cookies, through your browser settings, but please note, disabling cookies may impact some of the features of our Platform and prevent them from operating as intended. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/
Financial information, such as your bank account number, credit card number, debit card number, digital wallet information and other similar information;
Other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Platform, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
Third party analytic tools, such as:

Google Analytics, a web analytics that assists us in understanding how our Websites are used. Google Analytics will place cookies on your device that will generate information we select about your use of our Websites, including your device’s IP address. That information will be transmitted directly to and stored by Google. The information will be used for the purposes of evaluating use of our Websites, compiling reports on activity on our Websites for our use and providing other services relating to activity on, and usage of, our Websites. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of our Websites. Google’s practices with respect to the Personal Data collected through Google Analytics are covered by Google’s privacy policy, available at https://policies.google.com/privacy. Google allows you to opt out of Google Analytics. You may opt-out by visiting https://tools.google.com/dlpage/gaoptout.
Cookies, which are small data files that are uploaded to the hard drive or other storage on devices that access, use, or interact with portions of our Platform. Among other things, cookies help us improve our Platform and our users’ experience. We use cookies to see which areas and features are popular and to understand usage of our Platform. We use first party cookies, served directly by us to the devices that access our Platform, to recognize those devices when they revisit. We also use third party cookies, which are cookies that are placed by other parties we work with. These third parties may upload unique cookies to your device to collect information about your use of our Platform and potentially other online activities you engage in over time across different websites and other online applications. The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be uploaded to your device, including how to disable such technologies. You can disable our cookies, or all cookies, through your browser settings, but please note, disabling cookies may impact some of the features of our Platform and prevent them from operating as intended. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/
Facebook Audience, an advertising service provided by Facebook, that uses data collected through cookies and other tracking technologies and advertising identifiers and other similar information to display ads based on user’s interests and other information. We use the information collected in connection with Facebook Audience to deliver advertisements to people who may be interested in the features and functionalities available through our Platform. Facebook’s practices with respect to the Personal Data collected through or in connection with Facebook Audience are covered by Facebook’s privacy policy, available at https://www.facebook.com/about/privacy/. Facebook provides users with the ability to control certain advertising sent in connection Facebook Audience through the tools available at https://www.facebook.com/adpreferences/ad_settings/?entry_product=settings_ads_page_redirection

Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

HOW WE USE PERSONAL DATA
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We use Personal Data for various purposes to operate and improve our Platform and to conduct our business operations. The primary purposes for which we use Personal Data are:
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Marketing Purposes – we may, either on our own or jointly with our third party marketing partners (“Marketing Partners”), use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Policy) and use such linked information for Marketing Purposes. Our Marketing Purposes may include using Personal Data collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our Marketing Partners on and off our Platform. If you do not want us to use your Personal Data for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Data” section below.
Non-Marketing Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Platform; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) sending you emails to provide you with alerts and updates about your engagement with our Platform; (5) conducting statistical or demographic analysis; (6) complying with legal and regulatory requirements; (7) customizing your experience with our Platform; (8) protecting and defending Purple Trader against legal actions or claims; (9) preventing fraud; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (12) those you authorize or instruct us to do; and (13) other business purposes permitted under applicable law.

We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Platform for materially different, unrelated, or incompatible purposes without providing you notice.
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Please note, we may use and disclose aggregated, anonymized, or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Policy.
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SHARING PERSONAL DATA WITH THIRD PARTIES
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For business purposes, we may share certain Personal Data we, or third parties acting on our behalf, collect in connection with our Platform from and about you and about your relationship with us, with certain third parties. Doing so allows us to operate our Platform and conduct our business operations. The third parties that we may share Personal Data with include:
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Our Operational Service Providers in connection with the services they provide to us, including, without limitation, marketing, data hosting, payment processing and fraud protection and prevention. We require these Operational Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which it was provided to them.
Our Affiliates for purposes related to: (1) our business operations, including, without limitation, to operate our Platform, to process, fulfill or administer orders you place through our Platform and to market or promote our Platform; and (2) their business operations, including, without limitation, marketing and promoting the services they provide. Each Affiliate’s use of your Personal Data is subject to that Affiliate’s privacy policy. In the event a particular Affiliate does not have a privacy policy, unless we inform you otherwise, that Affiliate’s use of your Personal Data will be in accordance with this Policy.
Our Marketing Partners to facilitate the delivery of targeted ads, promotions and offers to you, on behalf of ourselves and our Marketing Partners, on and off our Platform.
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us, including Personal Data. We reserve the right, in connection with these types of transactions, to transfer or assign your Personal Data and other information we, or third parties acting on our behalf, have collected to third parties or to authorize such third parties to use any such information. Except as ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to this Policy. However, any Personal Data you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
Government and law enforcement individuals or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available or to comply with applicable laws.
Any third party to whom you consent and/or instruct us to provide your Personal Data.

THIRD PARTY INFORMATION COLLECTION
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Based on the nature of our Platform, third parties may collect information from or about you through or in connection with our Platform. In addition to other information provided in this Policy, including, without limitation, the section titled “How We Collect Usage Data” the categories of third parties that may collect information about you through or in connection with our Platform include:
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Third parties whose content is linked to on our Platform. Any links to other websites, applications or other third party content on our Platform, are not an endorsement, authorization, or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications, or content you access.
Other users of our Platform. Depending on how you interact with our Platform, other users may collect information about you that is published or otherwise generally made available on our Platform. All users of our Platform are subject to our Terms of Service, which are available at www.purpletrader.io/terms. While we place restrictions on what our users are allowed to do with information made available to them on our Platform, we are not responsible for any misuse of any information, including your Personal Data, by any user. If you believe that another user has misused your Personal Data or any other information available on our Platform, please contact us at purpleteam@purpletrader.io.

HOW TO MANAGE YOUR PERSONAL DATA
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We offer you several choices with respect to how we use your Personal Data. The mechanisms available to you to control the Personal Data are:

To update any Personal Data you have provided us, update your preferences, or otherwise contact us about our use of your Personal Data, please email us at purpleteam@purpletrader.io.
To manage the communications we send you:
For marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Platform.
If you do not want us to use your Personal Data to deliver targeted advertisements to you according to our target audience preferences, you can opt out by sending us an email with your request to purpleteam@purpletrader.io. We do not control third parties’ collection or use of your Personal Data to serve interest-based advertising. However, these third parties, which may include our Marketing Partners, may provide you with ways to choose not to have your Personal Data used to deliver targeted to you according to their target audience preferences. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org, and from members of the Digital Advertising Alliance (“DAA”) on their website, located https://youradchoices.com. Please note, even if you opt out from receiving targeted advertisements, you may still see advertisements based on factors such as your general location derived from your IP address, your browser type and your search terms.
Government and law enforcement individuals or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available or to comply with applicable laws.
Please note that we do not control information posted to a public decentralized network or blockchain, and will likely not be able to remove information or prevent external parties from processing any personal data which has been written onto the blockchain.

We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the use of email and the internet. Your Personal Data and other information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us. We cannot guarantee the security of any information, including your Personal Data, that you disclose online, and you do so at your own risk.

CHILDREN’S PRIVACY

We do not direct or target any piece of our Platform to children under the age of 13. If we learn that we have collected the Personal Data of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Data to us, please contact us at purpleteam@purpletrader.io. We will make reasonable efforts to remove such information from our databases.
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CALIFORNIA PRIVACY RIGHTS

If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your personal information to third parties for direct marketing purposes: (1) the categories of personal information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.

You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
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Purple Creator, Inc

Attn: CA Privacy Rights Request
2930 Domingo Ave #1112
Berkeley, CA 94705
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Cooperation
‍Whenever it is feasible and legal to do so, both the operator and You will give the other prompt notice of user rights requests, regulatory inquiries, and other communications under the California Consumer Privacy Act. Both sides agree to cooperate in good faith to respond to and honor such communications, and to meet other obligations under the California Consumer Privacy Act.
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Prohibitions
The operator may not:‍

sell personal information collected from consumers covered by the California Consumer Privacy Act that You disclose to the operator
retain, use, or disclose such information for any purpose other than for the specific purpose of performing the services in the Terms of Service, including retaining, using, or disclosing such information for a commercial purpose other than providing the services Terms of Service
retain, use, or disclose such information outside of a direct business relationship between the operator and You

Certification
The operator understands the restrictions in Prohibitions and will comply with them.
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Minimization
Both You and the operator agree to limit use of personal information covered by the California Consumer Privacy Act to that reasonably necessary and proportionate to achieve the purpose of the Terms of Service, consistent with the meaning of “business purpose” under that law.
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Subcontracting
The operator agrees to ensure that each subcontractor that processes Your information covered by the California Consumer Privacy Act will also qualify as a “service provider”, and not as a “third party”, under that law.

Conflicts
If the terms of this addendum conflict with terms of the Terms of Service or Privacy Policy, the terms of this addendum take precedence.]
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CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the services we provide are continually evolving, this Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Platform after any changes to this Policy become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Policy.

CONTACT US
We welcome your questions, comments, and concerns about privacy. Please email us at purpleteam@purpletrader.io with any questions or feedback you have pertaining to our privacy practices.
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Transferring Your data outside of the EU
The data mentioned in this document will be stored in the United States. [We use Amazon Web Server, which is based in the US. Amazon is certified under the EU-US Privacy Shield. Fabric.io and Firebase are part of the Google LLC., which is based in the US. Google is certified under the EU-US Privacy Shield.]
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Your Rights as a Data Subject
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
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Right Information and access
You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source). This document provides that information, and you may contact us for additional information.
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Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information. The accuracy of your information is important to us. If you do not want us to use your Personal Information in the manner set out in this Privacy Policy, or need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and use your Personal Information, please contact us at the above details.
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Right to erasure (right to be ‘forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:‍

the personal information is no longer necessary for the purpose for which it was collected;
you withdraw your consent to consent based processing and no other legal justification
for processing applies;
you object to processing for direct marketing purposes;
we unlawfully processed your personal information; and
erasure is required to comply with a legal obligation that applies to us.

But, when interacting with the blockchain we may not be able to ensure that your personal data is deleted. This is because the blockchain is a public decentralized network and blockchain technology does not generally allow for data to be deleted and your right to erasure may not be able to be fully enforced. In these circumstances we will only be able to ensure that all personal data that is held by us is permanently deleted.We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
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Exercising the right of freedom of expression and information;
Complying with a legal obligation under EU or other applicable law;
for processing applies;
The performance of a task carried out in the public interest;
Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
The establishment, exercise, or defense of legal claims.

Right to restrict processing and right to object to processing
You have a right to restrict processing of your personal information, such as where:‍

you contest the accuracy of the personal information;
Complying with a legal obligation under EU or other applicable law;
where processing is unlawful you may request, instead of requesting erasure, that we restrict the use of the unlawfully processed personal information;
we no longer need to process your personal information but need to retain your information for the establishment, exercise, or defense of legal claims.
Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or

You also have the right to object to processing of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent. This may impact the services we can provide and we will explain this to you if you decide to exercise this right.But, when interacting with the blockchain, as it is a public decentralized network, we will likely not be able to prevent external parties from processing any personal data which has been written onto the blockchain. In these circumstances we will use our reasonable endeavors to ensure that all processing of personal data held by us is restricted, notwithstanding this, your right to restrict to processing may not be able to be fully enforced.
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Contact
The identity and contact details of the organization, its representative, and its Data Protection Officer are as follows: []
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Right to data portability
Where the legal basis for our processing is your consent or the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.

Right to freedom from automated decision-making
We do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.

Right to object to direct marketing (‘opting out’)
You have a choice about whether or not you wish to receive information from us. We will not contact you for marketing purposes unless:
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you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
you have otherwise given your prior consent (such as when you download one of our guides)

You can change your marketing preferences at any time by contacting us on the above details. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.
Please note that any administrative or service-related communications (to offer our services, or notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.
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Right to request access
You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.

Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details.

Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.
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