Financial companies choose how they share your personal information. Applicable law gives consumers the right to limit some but not all sharing. Applicable law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depend on the product or service you have with us. This information can include: ID documents and employment information; bank account information, Bio data, balances, and history; assets and investment experience and history.

When you are no longer our customer, we continue to share your information as described in this notice.

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons ComiBlock chooses to share; and whether you can limit this sharing.

We share your personal information only for the following two purposes:

1. For our everyday business purposes, such as processing your transactions, maintaining your account(s), responding to court orders and legal investigation.
2. For our marketing purposes, to offer our products and services to you

We do not share your information for joint marketing with other financial companies or with any affiliates or non-affiliates.

Please go to support@comiblock.com for further information.

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.

We collect your personal information, for example, when you register to become a ComiBlock customer, access and use our services, otherwise provide us your personal information

Applicable law gives you the right to limit only sharing for affiliates’ everyday business purposes – information about your creditworthiness, affiliates from using your information to market you, sharing for non-affiliates to market you. Applicable laws and individual companies may give you additional rights to limit sharing.

Affiliates are defined as companies related by common ownership or control. They can be financial and non-financial companies.

Non-affiliates are defined as companies not related by common ownership or control. They can be financial and non-financial companies.

Joint marketing is defined as a formal agreement between non-affiliated financial companies that together market financial products or services to you.

ComiBlock Online Privacy Policy

Effective Date: August 2022

Introduction

This Online privacy policy, set forth above, (the “Privacy Policy”) applies to all websites and mobile applications linking to or posting this Privacy Policy (each a “Platform”) that are operated by ComiBlock Capital Limited, a subsidiary of AltraBlock.INC LLC d/b/a ComiBlock (“ComiBlock”, “we”, or “us”). This Privacy Policy describes how we use, store, disclose, and process information that we obtain about you through our Platforms, including information that we obtain through any of the investment advisory services that we provide, in whole or in part, through any of our Platforms (collectively, the “Service”), as well as any information related to your use of the Service that you provide to us outside our Platforms (such as via email).

Please read this information carefully before accessing any of our Platforms or using the Service. By accessing any of our Platforms, or by setting up an account with us or using our Service, you agree to the terms of this Privacy Policy.

What types of information do we collect through our Platforms?

We may collect personally identifiable information as well as non-personally identifiable information associated with you, including:

1. ‍Registration Information. When you register to use the Service, you will be asked to establish a login ID and password, and to provide us with certain personal information, including, but not limited to, your first and last name, email address, mailing address, telephone number, date of birth, and social security number. You may also be asked to provide similar information to us from time to time as you use the Service and/or access any of our Platforms.
2. Investment Information. When you register to use the Service, you will be asked to provide information regarding your investment preferences, including your risk tolerance, investment objectives and experience, time horizon, liquidity needs, and the like.
3. Banking Information. To use the Service, you will be asked to provide information regarding your banking relationship, including the bank name and your account number, bank routing number, and bank account login credentials.
4. Activity and Demographics Information. When you use the Service or otherwise access any of our Platforms, we may record certain details about your computer or mobile phone, the name of your Internet Service Provider (ISP), your IP Address, the website from which you visit us, the pages on our Platforms that you visit and in what sequence, the date and length of your visit and other statistical information about your visit to our Platforms. We may also collect aggregated demographic information regarding users of the Service (e.g., age, gender, and income information). Information Collected Via Cookies, Web Beacons, and Similar Technologies. When you use the Service or otherwise access any of our Platforms, we also may send “cookies” to your computer or device or use similar technologies to enhance your experience. These technologies can identify you as a unique customer and store your personal preferences as well as product preferences, to tell us which webpages you have visited and in what order, and identify your computer or device. On their own, cookies or web beacons do not contain or reveal personally identifiable information; however, if you choose to provide us with such information, it can be linked to the anonymous data stored in the cookies and/or web beacons. We may allow select third parties to place cookies on our Platforms to provide us with better insights into the use of the Platforms or user demographics, or to provide relevant advertising to you. These third parties may collect information about a user’s online activities over time and across different websites when using any of our Platforms.

How do we use information about you collected through our Platforms?

We may use information collected about you through our Platforms for a variety of commercial purposes, including without limitation the following purposes:

1. to provide the Service to you, and to conduct our other everyday business purposes (including processing your transactions and maintaining your account with us);
2. to inform you of changes made to the Service or any of our Platforms;
3. to respond to questions that you may have about the Service or any of our Platforms, or about our company;
4. to market our products and services to you, and to inform you of certain products or services of third parties which may be of interest to you;
5. to organize or carry out promotional activities or other promotional events;
6. to develop an online customer profile for you;
7. to understand general customer trends and patterns, so we can develop and support existing and ongoing marketing strategies for our products and services; and
8. to conduct other marketing and commercial activities (consistent with this Privacy Policy).

We may also use information about you that we collect through any of our Platforms for security, administrative, and legal purposes.

How long do we maintain information about you collected through our Platforms? We will retain information about you collected through any of our Platforms for at least as long as it serves the purposes for which it was initially collected or subsequently authorized, and we may keep such information indefinitely.

To whom do we disclose information about you collected through our Platforms? We will not disclose to any third-party information collected about you through any of our Platforms, except as described in this Privacy Policy. Specifically, we may disclose to third parties' information collected about you either (i) when we have your permission, or (ii) in any of the following situations without your permission:

1. We may disclose information collected about you to third-party service providers or other partners who perform services on our behalf in connection with the Service or any of our Platforms, including without limitation in connection with our service provider or partner completing or confirming a transaction that you conduct with us. When we transfer personally identifiable information about you to such a service provider or partner, that entity will be contractually required to use such information only to carry out those services that we have requested and to provide adequate protection for such information.
2. We may also share information collected about you with our auditors, attorneys, and similar advisors in connection with our receiving their professional services, subject to standard confidentiality obligations.
3. We may disclose the results of aggregate information or blind data about users of the Service or any of our Platforms to any third party. In such circumstances, we do not disclose to these entities any personally identifiable information about you or other users of the Service or any of our Platforms.
4. As noted above, any aggregate information or blind data collected by third-party services integrated with any of our Platforms will be disclosed to such third parties.
5. We may transfer and disclose information obtained about you through the Platforms to a third party as part of a merger, acquisition, or other sale or transfer of all or substantially all of our assets or business.
6. We may disclose information about you to the government or to third parties under certain circumstances when legally obligated to do so, such as in connection with suspected illegal activity in connection with the Service or any of our Platforms, or to respond to a subpoena, court order or other legal process.
7. We reserve the right to release such information to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.
8. We may also disclose information about you to third parties if needed to enforce any of our Terms of Use; to conduct any investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; to protect the rights, property or safety of ComiBlock or others; or to protect against harm to any element of the Platforms.

Your rights over personal information

1. Subject to your local law, you have rights regarding your personal information, including access, rectification, erasure, and blocking; restriction of use; objection to using, data portability, and the lodgement of a claim to your local data protection authority.
2. We encourage you to contact us to update your information if it changes or is inaccurate.
3. Following the CAN-SPAM compliance, all our email campaigns contain an unsubscribe option if you wish to stop receiving our campaigns emails.
4. We will also stop sending email campaigns after 15 drips of inactivity.
5. If you would like to discuss or exercise these rights, please contact us using the details set out at the end of this policy

Analytics & Advertising Tools we use

1. Our Services use Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies to help us analyze how users use our Website. The information generated by the cookie about your use of our Services (including your IP address) will be transmitted to and stored by Google on servers in the United States.
2. Our Services use Fullstory a US-based web analytics service provided by Amplitude, Inc (“Fullstory ”). Amplitude uses cookies to help us analyze how users use our Website. The information generated by the cookie about your use of our Services (including your IP address) will be transmitted to and stored by Fullstory on servers in the United States.
3. Our Services use SendGrid, a US-based Email service, to store your details and send you our newsletter. In the process of working with Mailchimp, your data may be transferred outside the EEA, to the US. SendGrid is self-certified under Privacy Shield and lawfully transfers EU/EEA personal data to the US according to its Privacy Shield Certification.
4. Our Services use Osano, Inc, a data privacy platform that instantly helps us become compliant with laws such as GDPR and CCP.
5. We also use Segment Inc, a US-based Customer Data Platform (CDP), to simplify collecting, transforming, sending, and archiving your data and digital properties across our services.

Information storage and retention

1. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on the Platform.
2. All personal information shall be dealt with by The General Data Protection Regulation 2016/679 and the General Data Protection Regulation.
3. We will retain your personal information for a period that enables us to: maintain business records for analysis and/or audit purposes; comply with record retention requirements under Applicable Law; defend or bring any existing or potential legal claims; deal with any complaints regarding the services.
4. We will delete your personal information when it is no longer needed for these purposes. If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

We shall not sell, trade, or rent your personal information to others.

Security measures do we employ for information about you collected through our Platforms

To help protect the privacy of information collected through our Platforms, we employ reasonable technical, physical, and organizational measures intended to protect such information against accidental or intentional manipulation, loss, misuse, or destruction, and against unauthorized disclosure or access, as well as to protect such information, both during transmission and once it is received, including encrypting the transmission of any sensitive information (such as bank account information or payment card information).

NOTWITHSTANDING THE FOREGOING, PLEASE NOTE THAT DESPITE OUR BEST INTENTIONS NO TECHNOLOGY IS COMPLETELY SECURE. PLEASE BE AWARE THAT OUR PLATFORMS ARE OPERATED ON SOFTWARE, HARDWARE AND NETWORKS, ANY COMPONENT OF WHICH MAY, FROM TIME TO TIME, EXPERIENCE BREACHES OF SECURITY OR OTHER PROBLEMS BEYOND OUR CONTROL. Accordingly, we cannot guarantee that any information obtained about you through our Platforms, whether during transmission or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others who do not have your authorization. Any such transmission or sharing of that information is done at your own risk.

You also play a role in protecting your personal information. Please do not share your user name or password/pin with others. If we receive an order or instructions using your information, we will consider that you have authorized the transaction.

Our policy on the use of our Platforms by children

You must be 18 years or older to register to use the Service. Our Platforms are not designed or intended to be attractive to use by children under 13 years old, and we do not knowingly collect personally identifiable information from anyone under 13 years old. IF YOU ARE UNDER 13 YEARS OLD, PLEASE DO NOT USE ANY OF OUR PLATFORMS AT ANY TIME OR IN ANY MANNER. If you learn that your child under 13 years old has provided us with personal information without your consent, please contact us. We will delete that data from our systems.

Terms regarding any future changes to this Privacy Policy

It may become necessary to change the terms of the Privacy Policy from time to time as necessary to comply with the law or for legitimate business purposes. By continuing to use our service, you agree to remain bound by the Privacy Policy. You acknowledge and agree that it is your responsibility to periodically review this policy and check for any changes.

Law governs this Privacy Policy

You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of Delaware, without reference to the choice of law or conflicts of law principles thereof, and will be subject to the dispute resolution clause contained in our Terms of Use (www.comiblock.com/terms).

If any provision of this Privacy Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced.

Contact

If you have any questions about the Privacy Policy or our processing of your data, please contact us at compliance@comiblock.com

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