Privacy Policy

This Privacy Policy for 1800Bitcoin LLC (“Company”, “we”, “us”, “our”), a
subsidiary of Immutable Holdings Inc., describes how we collect, use and
disclose information about users of the website (www.1800bitcoin.com),
together with application, content, materials, tools, features and functionality
offered on or through our website (collectively, the “Website”). For the
purposes of this Privacy Policy, “you” and “your” means you as the user of
the Website.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING OR ACCESSING
THE WEBSITE, YOU AGREE TO THE USE OF YOUR INFORMATION IT
DESCRIBES AND TO THE OTHER TERMS OF THIS PRIVACY POLICY. IF YOU DO
NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE THE
WEBSITE.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will
update the “Last Revised” date at the top of this Privacy Policy. If we make
changes that are material, we will use reasonable efforts to attempt to
provide notice to you and, where required by applicable law or otherwise in
our discretion, we will obtain your consent. Notice may be by email to you at
the last email address you provided us, by posting notice of such changes on
the Website, or by other means, consistent with applicable law. However, it
is your sole responsibility to review the Privacy Policy from time to time to
view any such changes. The updated Privacy Policy will be effective as of the
time of posting, or such later date as may be specified in the updated
Privacy Policy. IF YOU DO NOT AGREE TO ANY UPDATES TO THIS PRIVACY
POLICY PLEASE DO NOT ACCESS OR CONTINUE TO USE THE WEBSITE.

2. WHO WE COLLECT PERSONAL INFORMATION FROM

We may collect personal information from the following groups of data
subjects: visitors to, and users of, our Website; our customers; current
members of our workforce and those who apply for posted jobs; and third-
party vendors and business partners.
Personal information generally means information that can be used to
identify you or that can be easily linked to you (for example, your name,
address, telephone number, email address, social security number and date
of birth). The privacy laws in some jurisdictions include unique elements in
what they consider to be the personal information of the consumers or data
subjects they protect. If those laws apply to us, as in the case of the
California Consumer Privacy Act (“CCPA”) or European General Data
Protection Regulation (“GDPR”), our use of the phrase “personal information”
includes the unique elements required by such laws.
The categories of information we collect from each of these groups, and the
ways in which we use it, differs. As you may have noticed, it’s possible that
the same person could fall into more than one group. Most of this Privacy
Policy addresses our processing and sharing of personal information
collected from visitors to and users of our Website and our customers.
Nonetheless, we collect and retain the types of professional or employment
related personal information you would expect an employer to have about its
existing and former workforce and new job applicants. We provide legally
required notices of collection and describe our use and sharing of the
personal information of our workforce and applicants in greater detail in
confidential internal human resource manuals and documents accessible to
members of our workforce, or by publication on the proprietary
workforce/applicant portals and apps we operate. In some cases, such
portals and apps may be operated by third parties who transfer the personal
information to us. In those situations, the legal responsibility to provide
notice usually rests with the third party, not us.
In addition, like all corporate enterprises, we buy goods and services, lease
equipment and office space and attend industry events. In doing so, we
interact with many existing and potential vendors and business partners
from whom we necessarily collect certain personal information in connection
with our contractual and business relationships. As with our customers, this
information is typically limited to minimum business contact information. We
use and share personal information collected from our vendors and business
partners to manage, administer, and perform under our contracts with them,
or share information about our products. We describe our use of vendor and
business partner personal information in greater detail in our confidential
contracts with those parties or on the internal vendor management portals
we operate.

3. WHAT WE COLLECT


There are two types of information that we obtain from you online and then
store and use: (i) non-personal information that’s collected automatically
from each visitor, such as your device operating system; and (ii) personal
information that you voluntarily provide to us or that is collected
automatically.
By using our Website or purchasing our products or services, you are
signifying to us that you agree with this section of our Privacy Policy and that
we may use and disclose your information as described.
Voluntarily Submitted Information.
If you participate in certain activities via our Website, you may be asked to
provide us with information about yourself. The types of personal information
we collect in those situations includes identifiers (such as your name, email
address, physical address, and phone number), professional information
(such as the business you are in), and financial account information (such as
your credit card information). We do not sell, rent, or trade voluntarily
submitted personal information with third parties.
If you don’t want us to collect this type of personal information, please don’t
provide it. This means you shouldn’t participate in the activities on our
Website that request or require it and you may want to communicate with us
by phone or regular mail instead. Participation is strictly your choice. Not
participating may limit your ability to take full advantage of the online and
mobile resources, but it will not affect your ability to access certain
information available to the general public on the online and mobile
resources.
Some of the ways you voluntarily give us your personal information and how
we use it:
Emails and Online Forms – When you send us an email or fill out an online
form, such as to contact us, your email address and any other personal
information (e.g., home address or phone number) that may be in the
content of your message or attached to it, are retained by us and used to
respond back directly to you and to process your request. Depending on the
personal information provided, communications from us may be in the form
of emails, telephone calls, and/or text messages. We may also send you
information about any of our products or services we think may be of interest
to you.
Registering for an Account – When you register for an account or you register
your child for a sub-account, you submit personal information to us such as
your name and email address (or your child’s name and email address)
which we then retain. We use that information to create and manage your
account and, in some cases, establish a password and profile to
communicate with you and any sub-accounts you created via email.
Registering for Events – When you register for services, webinars, events,
conferences, or programs we ourselves may host (rather than outsource to a
third-party event manager with its own privacy policies), you will be
submitting the types of identifiers described above. If the event requires a
fee, we may also ask you to submit credit card or other financial information.
We use this information to register you for the event and send you
communications regarding the event.
Becoming a Subscriber to Our Service – We use any information provided
from our customers to perform our contractual obligations and provide the
products and services purchased to them, to manage their accounts and
communicate with them.
Social Media and Community Features – Some of our Website may offer
social media-like community features letting users post messages and
comments, and/or upload an image or other files and materials. If you
choose to make use of these features, the information you post, including
your screen name and any other personal information, will be in the public
domain and not covered/protected by this Privacy Policy.
Automatically Collected Information.
When you visit our Website, basic information is passively collected through
your web browser via use of tracking technologies, such as a “cookie” which
is a small text file that is downloaded onto your computer or mobile device
when you access the online and mobile resources. It allows us to recognize
your computer or mobile device and store some information about your
preferences or past actions.
We allow third party vendors to use cookies or similar technologies to collect
information about your browsing activities over time following your use of
the site. For example, we use Google Analytics, a web analytics service
provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us
analyze how you use the online and mobile resources and enhance your
experience when you visit the online and mobile resources. For more
information on how Google uses this data, go to
www.google.com/policies/privacy/partners/. You can learn more about how to
opt out of Google Analytics by going to
https://tools.google.com/dlpage/gaoptout.
The internet activity information collected through cookies and other similar
means includes such things as: the domain name and IP address from which
you accessed our Website; the type of browser and operating system you
use; the date and time and length of your visit; the specific page visited,
graphics viewed and any documents downloaded; the specific links to other
sites you accessed from our Website; and the specific links from other sites
you used to access our Website.
Additionally, if you access our Website from a phone or other mobile device,
the mobile services provider may transmit to us uniquely identifiable mobile
device information which allows us to then collect mobile phone numbers
and associate them with the mobile device identification information. Some
mobile phone vendors also operate systems that pinpoint the physical
location of devices and we may receive this information as well if location
services are enabled on your device. If you do not want us to collect and use
geolocation data, disable location services through your device settings.
Regardless, we use both automatically collected information and mobile
device information to compile generic reports about popular pages on our
Website, and to see how our customers and followers are accessing our
Website. We then use that data to administer the online and mobile
resources and make them better, make your activities more convenient and
efficient and to enhance the functionality of our Website, such as by
remembering certain of your information in order to save you time.
We use and retain your personal information in accordance with applicable
law and as long as necessary to carry out the purposes described above in
accordance with our internal data retention procedures.
User Beware: External Sites, Apps, Links and Social Media.
We maintain a presence on one or more external social media platforms
such as Twitter, Facebook, YouTube and LinkedIn. We may further allow
features of our Website to connect with, or be viewable from, that external
social media presence. Similarly, our Website may contain links to other
websites or apps controlled by third parties.
We are not responsible for either the content on, or the privacy practices of,
social media platforms, or any third-party sites or apps to which we link.
Those apps, sites and platforms are not controlled by us and therefore have
their own privacy policies and terms of use. If you have questions about how
those apps, sites and platforms collect and use personal information, you
should carefully read their privacy policies and contact them using the
information they provide.

4. WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION

We use non-personal information to administer our Website, make them
better, and to make business decisions about what programs our customers
might like.
We use voluntarily provided personal information to respond to your inquiries
and provide you with the services you have requested, amongst other uses
as further described below. We do not sell or rent your personal information
to third party data vendors or marketing companies. As you might expect,
we disclose your information when required by law.
Affiliates
In addition to those third parties set forth above, we may share your
information, including personal information, within our family of companies.
Those companies will use such information in generally the same manner as
we do under this Privacy Policy which includes sending you information
about their products, services, or initiatives that may be of interest to you.
Legally Compelled Disclosures
We may disclose your information, including personal information, to
government authorities, and to other third parties when compelled to do so
by such government authorities, or at our discretion or otherwise as required
or permitted by law, including but not limited to responding to court orders
and subpoenas.
To Prevent Harm
We may disclose your information, including personal information, when we
have reason to believe that someone is causing injury to or interference with
our rights or property, other users of the online and mobile resources, or
anyone else that could be harmed by such activities.
Business Transfer
If we or any of our affiliates, or substantially all its or their assets, are
acquired by one or more third parties as a result of an acquisition, merger,
sale, reorganization, consolidation, or liquidation, personal information may
be one of the transferred assets.
Vendors and Business Partners
We may share your information, including personal information, with our
vendors and other third parties with whom we have a contractual
relationship. We may also share your information, including personal
information, with vendors who provide third party software services that you
have chosen to assist you with your sales funnels. We do our best to disclose
only the information each of those parties need.
We have adopted standards for those vendors and business partners who
receive personal information from us. We attempt to bind such vendors and
business partners to those standards via written contracts. We further
attempt to contractually restrict what our vendors and business partners can
do with the personal information we provide to them such that it is used only
to the extent necessary to carry out the business purpose for which it was
provided; is not disclosed to anyone else without our consent or under our
instruction; remains, as between us and the applicable vendor or business
partner, our property; and is not transferred out of the United States without
our consent.
Please note, however, that we cannot guarantee that all of our vendors and
business partners will agree to these contractual requirements; nor can we
ensure that, even when they do agree, they will always fully comply.

5. YOUR RIGHTS AND OPTIONS

You do not have to provide personal information to enjoy most of the
features of our Website. Moreover, you can opt out of certain activities like
newsletters and announcements. Residents of California and data subjects
whose personal information was obtained while they were in the GDPR
Jurisdictions have certain additional rights.
GDPR Jurisdictions means the countries composed of the European Economic
Area (including Iceland, Lichtenstein, and Norway) and the following
countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic,
Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy,
Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal,
Romania, Slovakia, Slovenia, Spain, and Sweden.
Furthermore, Andorra, Argentina, Canada (only commercial organizations),
Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand,
Switzerland, Uruguay and Japan have received an “adequacy decision” from
the European Commission, adheres to the material terms of the GDPR.
Switzerland also has its own data protection via its Federal Act of Data
Protection (“DPA”).
GDPR no longer has jurisdiction over The United Kingdom. Since the United
Kingdom (“UK”) has now formally left the European Union, it is no longer
regulated domestically by the material terms of the GDPR. The United
Kingdom General Data Protection Regulation (“UK-GDPR”) is the UK's data
privacy law that governs the processing of personal data domestically.
If we are using personal information you provided to us in order to enable us
to send you materials, such as newsletters or product alerts via text or email,
and you decide you don’t want to receive such materials, you may opt out by
following the opt-out instructions in the email or other communication (e.g.,
by responding to the text with “STOP”), or by contacting us using the contact
information below. When we receive your request, we will take reasonable
steps to remove your name from our distribution lists. You need to
understand it may take a period to remove your name from our lists after
your request and due to such latency, you may still receive materials for a
period of time after you opt out. In addition to opting out, you have the
ability to access, amend, and delete your personal information by contacting
us using the contact information below.
Some browsers have a “do not track” feature that lets you tell websites that
you do not want to have your online activities tracked. At this time, we do
not specifically respond to browser “do not track” signals.

6. CHILDREN’S PRIVACY

Children under the age of thirteen (13) are not permitted to use the Website,
and we do not seek or knowingly collect any personal information about
children under thirteen (13) years of age. If we become aware that we have
unknowingly collected information about a child under thirteen (13) years of
age, we will make commercially reasonable efforts to delete such
information from our database.
If you are the parent or guardian of a child under thirteen (13) years of age
who has provided us with their personal information, you may contact us
using the information in Section 11 to request that it be deleted.

7. HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We will take all reasonable security precautions to protect your personal
information provided to our Website. We have adopted a security program
that includes technical, organizational, administrative, and other security
measures designed to protect, in a manner consistent with accepted industry
standards and applicable law, against anticipated or actual threats to the
security of personal information (the “Security Program”). We cannot,
however, guarantee that your information, whether during transmission or
while stored on our systems or otherwise in our care, will be free from
unauthorized access or that loss, misuse, destruction, or alteration will not
occur. Except for our duty to maintain the Security Program under applicable
law, we disclaim any other liability for any such theft or loss of, unauthorized
access or damage to, or interception of any data or communications
including personal information. We have every reason to believe our Security
Program is reasonable and appropriate for our business and the nature of
foreseeable risks to the personal information we collect. We further
periodically review and update our Security Program, including as required
by applicable law.
Nonetheless, as part of our Security Program, we have specific incident
response and management procedures that are activated whenever we
become aware that your personal information was likely to have been
compromised. We further require, as part of our vendor and business partner
oversight procedures, that such parties notify us immediately if they have
any reason to believe that an incident adversely affecting personal
information, we provided to them has occurred.

8. THE CALIFORNIA CONSUMER PRIVACY ACT

When we collect personal information from California residents, we become
subject to, and those residents have rights under, the California Consumer
Privacy Act or “CCPA”. This section of our Privacy Policy is used to allow us to
fulfill our CCPA obligations and explain your CCPA rights. For purposes of this
section, the words “you” and “your” mean only such California residents.
What did we collect from California Residents?
We collect the following categories of personal information: identifiers such
as name, address, IP address, and other similar identifiers; personal
information described in subdivision (e) of Section 1798.80 (California
customer records statute) such as a name, address, telephone number,
credit card number; commercial information such as products or services
purchased; internet/electronic activity such as browsing history and search
history; geolocation data including geographic coordinates/physical location;
and audio, video, electronic or other similar information. We may disclose
this information for one or more business purposes permitted by the CCPA.
We do not sell, and within the last 12 months have not sold, personal
information to third parties.
Rights of California Residents
You have the following rights under the CCPA, in summary disclosure, access
and delete. It’s important to us that you know that if you exercise these
rights, we will not “discriminate” against you by treating you differently from
other California residents who use our sites and mobile resources or
purchase our services but did not exercise their rights.
You can exercise these rights up to two different times every 12 months. To
do so, you may contact us using the information in Section 11. We may ask
you to fill out a request form. The CCPA only allows us to act on your request
if we can verify your identity or your authority to make the request so you
will also need to follow our instructions for identity verification.
If you make a verifiable request per the above, we will confirm our receipt
and respond in the time frames prescribed by the CCPA.

9. THE EU GENERAL DATA PROTECTION REGULATION

We do collect or otherwise obtain personal information from data subjects
located in the GDPR Jurisdictions. We fulfill our GDPR obligations with respect
to our workforce/job applicants, our customers (and their own end-clients),
and our vendors and business partners through a series of separate notices,
contracts or other terms provided to them at the time, and in the manner
and form, GDPR and local law within each GDPR Jurisdiction requires.
We describe, in the immediately following section of this Privacy Policy, how
we comply with the GDPR for personal information collected from visitors to
and users of our Website while they were in a GDPR Jurisdiction. Thus, for
purposes of that section, the words “you” and “your” mean only such GDPR
Jurisdiction-based visitors and users.
What do we collect from you in the GDPR Jurisdictions and how do we use it?
We collect from you the categories of personal information already
described. The lawful basis on which we rely for such collection, later use
and disclosure, is what the GDPR refers to as legitimate interest. As stated
elsewhere in this Privacy Policy, we do not sell any of your personal
information to third parties nor do we use it for automated decision making.
Cross-border Data Transfers and Third-Party Processors
If we transfer personal information from the GDPR Jurisdictions to a location
that has not been deemed by the European Commission to have adequate
privacy protections, we do so in the manner the GDPR permits.
Rights of Data Subjects in the GDPR Jurisdictions
While we attempt to allow all visitors and users of our Website to exercise a
degree of control over their personal information, under the GDPR we have a
legal obligation to do so for you. More specifically, with respect to personal
information collected from you while you were in a GDPR Jurisdiction, you
have these rights: transparency, access, correction and deletion, portability,
who, what, why and where, and restriction/objection.
If you would like to exercise any of these rights, you may contact us using
the information in Section 11. Your ability to exercise these rights is subject
to certain conditions and exemptions that you can read about in Articles 12
through 23 of the GDPR. Among those conditions is our right to decline part
or all of a request if we cannot satisfy our reasonable doubts and concerns
about your identity in a manner that helps us minimize the risk that
unauthorized persons might use a GDPR right to access your personal
information. We will respond to all requests without undue delay, and in
accordance with the time frames, if any, prescribed by the GDPR. If you are
not satisfied with how we use your personal information or respond to your
requests, you have the right to complain to your data protection regulator.

10. RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS

In other jurisdictions, with similar data privacy regulations, we may collect
from you the categories of personal information already described. We
collect and manage (including disclose) such data in compliance with
applicable local law(s). As noted, we do not sell any of your personal
information to third parties nor do we use it for automated decision making.

11. CONTACTING US


If you have questions about our Privacy Policy or privacy practices, please
contact us at:
1800Bitcoin, LLC
Attn: Legal Dept.
151 Calle de San Francisco, STE 200 PMB 0024
San Juan, PR 00901
support@1800bitcoin.com