The following terms and conditions, together with any documents they expressly incorporate by reference (collectively, these “Terms of Service”), set forth the Agreement (“Agreement”) that governs your access to and use of the services provided by UNITARITY, INC and its affiliates (collectively, “Portfolio.io”). By using any services (“Services”) made available through Portfolio.io’s website, located at https://portfolio.io.com/ (the “Site”) or Portfolio.io affiliates, you agree that you have read, understood and accepted these Terms of Service, as well as our Privacy Policy. As this is a legally binding contract, please carefully read through this Agreement before using any of our Services. By registering, accessing or using Portfolio.io, you have agreed to the Terms of Service as laid out in this Agreement. If you disagree to this Agreement, please stop using Portfolio.io, the Site and the Services.

For more information on Portfolio.io, you can refer to the company and license information found on the Site. If you have questions regarding this Agreement, please feel free to contact Portfolio.io for clarification via our Customer Support Team at support@portfolio.io

Eligibility

By registering for Portfolio.io, you have affirmed that you are at least 18 years old and are an individual, legal person or other organization with full legal capacity to enter into this Agreement between you and Portfolio.io. By using the Services, you represent and warrant that you meet all of the foregoing eligibility requirements. By accessing and using Portfolio.io and any of its Services, you acknowledge and declare that you are not on any trade or economic sanctions lists, such as the United Nations Security Council Sanctions List. Portfolio.io maintains the right to select its markets and jurisdictions to operate and may restrict or deny its Services to certain countries. The content of this Agreement shall not be excluded from the laws of the country under which the user belongs. If you do not meet all of these requirements, you must not access the Site or use the Services. Portfolio.io reserves the right to terminate your account for any reason.

Changes to the Terms of Service

Portfolio.io reserves the right to modify or change these Terms of Service at any time and at its sole discretion. Any and all modifications or changes to the Terms of Service will be effective immediately upon being announced on the Site or released to users. As such, your continued use of Portfolio.io’s Services acts as acceptance of the revised Terms of Service.

Description of Services

Portfolio.io provides an online platform to invest in cryptocurrencies. Investors must register and open an account with Portfolio.io and deposit assets prior to the commencement of investing. Investors may request the withdrawal of their cryptocurrencies via Bitcoin, subject to the limitations as stated in the Terms of Service. 

Portfolio.io is not an investment advisor. Portfolio.io does not provide investment advice. No content published on the Site constitutes a recommendation that any particular cryptocurrency or digital token or portfolio of cryptocurrencies and digital tokens is suitable for any specific person. You further understand that we are not advising you personally concerning the nature, potential, value or suitability of any particular cryptocurrency or digital token or portfolio of cryptocurrencies and digital tokens or any particular investment strategy.

Portfolio.io strives to maintain the accuracy of information posted on its Site, however, it cannot guarantee the accuracy, suitability, reliability, completeness, performance or fitness for particular purpose of the content on the Site. Information on the Site is provided for educational purposes and is subject to change without notice. Portfolio.io does not accept liability for any loss or damage that may arise directly or indirectly from the content.

Account Registration

All users must register at https:/portfolio.io for a Portfolio.io platform user account before using the Site. To register for a user account, you must provide personally identifiable information, which may include your real name, email address and password (collectively, “Personal Information”), as well as accept the Terms of Service, Privacy Policy. In our sole discretion, we may refuse to open an account for you for any reason.

When registering for an account on Portfolio.io, you agree to share Personal Information requested for the purposes of identity verification. This information is used specifically for the detection and prevention of money laundering, terrorist financing, fraud and other financial crimes on the Portfolio.io platform. In addition to providing this information, to facilitate compliance with global industry standards for data retention, you agree to permit us to keep a record of such information for the lifetime of your account plus 5 years beyond account closing. You also authorize us to make inquiries, either directly or through third parties, that are deemed necessary to verify your identity or to protect you and/or us against financial crimes such as fraud.

The Personal Information we request for identity verification may include, but is not limited to, your: name, email address, contact information, phone number, username, and government-issued ID. In providing this Personal Information, you confirm that it is accurate and authentic. Post-registration, you must guarantee that the Personal Information is truthful, complete and updated promptly with any changes. If there is any reasonable doubt that any Personal Information provided by you is wrong, untruthful, outdated or incomplete, Portfolio.io shall have the right to send you a notice to demand corrections, remove relevant information directly and, as the case may be, terminate all or part of Portfolio.io’s Services to you. You shall be solely and fully responsible for any loss or expenses incurred during the use of Portfolio.io’s Services if you cannot be reached through the contact information provided. 

You hereby acknowledge and agree that you have the obligation to keep all Personal Information provided up to date if there are any changes.

By using Portfolio.io and any of its Services, you declare that all information provided to Portfolio.io in connection with these Terms of Service are true, accurate and complete.

Account Security

Portfolio.io prioritizes maintaining the security of user accounts and has implemented industry standard protections for our platform. With that said, there are account-level risks that are created by individual user actions. You must independently take safety precautions to protect your own account and Personal Information.

You shall be solely responsible for the safekeeping of your Portfolio.io account and password and for all activities under your Portfolio.io account, including, but not limited to, information disclosure, information posting, consent to or submission of various rules and agreements by clicking on the Site, online renewal of this Agreement, etc.

You are the only person who may use and operate your account. Portfolio.io reserves the right to suspend, freeze or cancel accounts that are used by persons other than the persons whose names they are registered under. Accordingly, Portfolio.io will not take legal responsibility for these accounts.

You hereby agree that you will: 

  • Notify Portfolio.io immediately if you are aware of any unauthorized use of your Portfolio.io account by any person or any other violations to the security rules; 
  • You will strictly observe the security, authentication, dealing, charging, withdrawal mechanism or procedures of the Site/Services; and
  • You will log out from the Site by taking proper steps at the end of every visit.
  • Portfolio.io will not be responsible for any loss or consequences caused by your failure to comply with the above Account Security provision.

Prohibited Conduct

You hereby agree that during your use of the Services on Portfolio.io all your activities:

  • Will comply with the requirements of applicable laws, regulations, as well as the various guidelines of Portfolio.io;
  • Will not be in violation of public interests, public ethics or other’s legitimate interests;
  • Will not constitute evasion of payable taxes or fees; and - 
  • Will not violate this Agreement or relevant rules.

If you violate the aforementioned promises and thereby cause any legal consequence, you shall independently undertake all of the legal liabilities in your own name and indemnify Portfolio.io from all actions, claims or costs arising from such violation.
You will not use any data or information displayed on the site for commercial purposes without the prior written consent of Portfolio.io.

You will use the Site in accordance with these Terms of Service and Privacy Policy, without taking acts of unfair competition nor attempting to intervene with the normal operation of Portfolio.io. Examples of such malicious acts include, but are not limited to:
Using a device, software or subroutine to interfere with the site;
Overloading network equipment with unreasonable data loading requests; and
Executing malicious sales or purchases on the market.

By accessing the Services, you agree that Portfolio.io shall have the right to unilaterally determine whether you have violated any of these Terms of Service and to take actions to apply relevant rules without receiving your consent or giving prior notice to you. 

Examples of such actions include, but are not limited to:

  • Block and close purchase requests;
  • Freezing your account;
  • Reporting the incident to authorities;
  • Publishing the alleged violations and actions that have been taken; and
  • Deleting any information you published that is in violation.

If your alleged violation causes any losses to a third party, you shall solely undertake all the legal liabilities in your own name and hold Portfolio.io harmless from any loss, fine or extra expenses. If, due to any alleged violation Portfolio.io incurs any losses, is claimed by any third party for compensation or suffers any punishment imposed by any administrative authorities, you shall indemnify Portfolio.io against any losses and expense caused thereby, including reasonable attorney’s fee.

Intellectual Property Rights

The Site and its entire contents, features and functionality (including but not limited to all information, software, displays, images, video and audio, and the design, selection and arrangement thereof) (collectively, “Intellectual Property”), are owned by Portfolio.io, its licensors or other providers of such material. You may not create copies of our Intellectual Property in violation of copyright, trademark, or other laws.

Trademarks

The Portfolio and Portfolio.io name, logo and all related names, logos, product and service names, designs and slogans are trademarks of Portfolio.io or its affiliates or licensors. You may not use such marks without the prior written permission of UNITARITY, INC. All other names, logos, product and service names, designs and slogans on this Site are the trademarks of their respective owners.

License Grant

We grant you a worldwide, non-exclusive, non-transferable, non-sublicensable and revocable license to use the Services subject to your eligibility and your continued compliance with these Terms of Service. We are not responsible to ensure, and disclaim any responsibility for, your ability to open, use or view the content on the Site. As between you and us, we retain all right, title and interest in and to the Site, and all related intellectual property rights. We reserve all rights not granted in this Agreement.

Service Fees

Portfolio.io reserves the rights to levy service fees on users who use its Services. It is in the discretion of Portfolio.io to adjust the service fees charged to users using its Services.

Termination of Agreement

You agree that we have the right to immediately suspend your account (and any accounts beneficially owned by related entities or affiliates), freeze or lock the funds in all such accounts, and suspend your access to Portfolio.io if we suspect any such accounts to be in violation of the Terms of Service, Privacy Policy, AML or counter-terrorist financing acts or any applicable laws & regulations. Portfolio.io shall have the right to keep and use the transaction data or other information related to such accounts. We may suspend or terminate your account in any of the following situations:

The account is subject to a governmental proceeding, criminal investigation or other pending litigation;

  • We detect unusual activity in the account;
  • We detect unauthorized access to the account; or
  • We are required to do so by a court order or command by a regulatory/government authority.

In case of any of the following events, Portfolio.io shall have the right to directly terminate this Agreement by canceling your account, and shall have the right to permanently freeze (cancel) the authorizations of your account on Portfolio.io and withdraw the corresponding Portfolio.io account thereof:

  • Portfolio.io terminates Services to you;
  • You register or allegedly register in any other person’s name other than your own as a Portfolio.io user, directly or indirectly;
  • The information that you have provided is untruthful, inaccurate, outdated or incomplete;
  • When this agreement (including the rules) is amended, you expressly state and notify Portfolio.io of your unwillingness to accept the amended service agreement; and
  • Any other circumstances where Portfolio.io deems it should terminate the Services.

Should the account be terminated, the account & transactional information required for meeting data retention standards will be securely stored for five years. In addition, if a transaction is unfinished during the account termination process, Portfolio.io shall have the right to notify your counterparty of the situation at that time.

Funds After Termination

In the case of no fault by either you or Portfolio.io, once the account is closed/withdrawn, all remaining balance (which includes charges and liabilities owed to Portfolio.io) on the account will be payable at once to Portfolio.io. Upon payment of all outstanding charges to Portfolio.io (if any), you will have 5 working days to withdraw all funds from the account.

In the case of fraud, violation of anti-money laundering laws, or any violation of the Terms of Service or Privacy Policy, Portfolio.io maintains full custody of the funds and Personal Information, which may be turned over to the authorities in event of account suspension/closure arising from fraud investigations, AML investigations or violation of Portfolio.io Terms of Service (e.g., trading on Portfolio.io from a sanctioned country).

Limitation of Liability

You acknowledge and agree, Portfolio.io shall not be liable for any of your losses caused by any of the following events, including but not limited to:

  • Loss of profits, goodwill, usage or data or any other intangible losses;
  • Unforeseen circumstances, including, but not limited to, any act of God, malicious targeted hacking, or terrorist attacks;
  • Use or failure to use the Services;
  • Unauthorized use of your account or unauthorized alteration of your data by third parties;
  • Your misunderstanding of the Services; and
  • Any other losses related to the Services which are not directly attributable to Portfolio.io.

In no event shall Portfolio.io be liable for any failure or delay of Service resulting from regular network maintenance or external factors such as power failure, natural disaster, service provider-side problems or governmental acts.

Portfolio.io strives to maintain the data integrity on its Site but does not guarantee the information and Services provided in its platform. Portfolio.io will not be liable for errors arising from the use of its Services.

Indemnification

You agree to indemnify and hold harmless Portfolio.io, its affiliates, contractors, licensors, and their respective directors, officers, employees and agents from and against any claims and damages (including attorneys’ fees, fines or penalties imposed by any regulatory authority) arising out of your breach or our enforcement of this Agreement. This shall also apply to your violation of any applicable law, regulation, or rights of any third party during your use of the Services.

You agree to indemnify Portfolio.io and its affiliates and hold them harmless from and against all third-party claims except from Portfolio.io’s breach of these Terms of Service.

Compliance with Local Laws

It is your responsibility to abide by local laws in relation to the legal usage of Portfolio.io in your local jurisdiction. You must also factor, to the extent of their local law all aspects of taxation, the withholding, collection, reporting and remittance to their appropriate tax authorities. You acknowledge and declare that the source of your funds come from a legitimate manner and are not derived from illegal activities. Portfolio.io maintains a stance of cooperation with law enforcement authorities globally and will not hesitate to seize, freeze, terminate your account and funds that are flagged out or investigated by legal mandate.

Anti-Money Laundering

Portfolio.io (and/or its delegate) may request such evidence as is necessary to verify your identity and source of funds. Portfolio.io shall not accept or repay any amount until all information required for verification purposes has been provided.

Portfolio.io prohibits acceptance of funds by any persons or entities that are acting, directly or indirectly: (i) in contravention of any U.S. or international laws and regulations, including anti-money laundering regulations or conventions; (ii) on behalf of terrorists or terrorist organizations, including those persons or entities that are included on the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), as such list may be amended from time to time; (iii) for a senior foreign political figure, any member of a senior foreign political figure’s immediate family or any close associate of a senior foreign political, unless Portfolio.io, after being specifically notified in writing that the individual is such a person, conducts further due diligence, and determines that such acquisition shall be permitted; or (iv) for a foreign shell bank (such persons or entities in (i) – (iv) are collectively referred to as “Prohibited Persons”). The OFAC list may be accessed on the web at http://www.treas.gov/ofac.

Senior foreign political figure means a senior official in the executive, legislative, administrative, military or judicial branches of a foreign government (whether elected or not), a senior official of a major foreign political party, or a senior executive of a foreign government-owned corporation. In addition, a senior foreign political figure includes any corporation, business or other entity that has been formed by, or for the benefit of, a senior foreign political figure. The immediate family of a senior foreign political figure typically includes the political figure’s parents, siblings, spouse, children and in-laws. A close associate of a senior foreign political figure is a person who is widely and publicly known internationally to maintain an unusually close relationship with the senior foreign political figure and includes a person who is in a position to conduct substantial domestic and international financial transactions on behalf of the senior foreign political figure.

Foreign shell bank means a foreign bank without a physical presence in any country but does not include a regulated affiliate. A post office box or electronic address would not be considered a physical presence. A regulated affiliate means a foreign shell bank that: (1) is an affiliate of a depository institution, credit union, or foreign bank that maintains a physical presence in the United States or a foreign country, as applicable; and (2) is subject to supervision by a banking authority in the country regulating such affiliated depository institution, credit union, or foreign bank.

Dispute Resolution

Any and all controversies, disputes, demands, counts, claims, or causes of action (including the interpretation and scope of this clause, and the arbitrability of the controversy, dispute, demand, count, claim, or cause of action) between you and Portfolio.io or their successors or assigns shall exclusively be settled through binding and confidential arbitration.

Governing Law

All matters relating to the Site and the Services and any dispute or claim arising therefrom or related thereto shall be governed by and construed in accordance with the internal laws of the State of Delaware without giving effect to any choice or conflict of law provision or rule.

EACH OF THE PARTIES HEREBY KNOWINGLY, VOLUNTARILY AND INTENTIONALLY WAIVES ANY RIGHT IT MAY HAVE TO A TRIAL BY JURY IN RESPECT OF ANY LITIGATION (INCLUDING BUT NOT LIMITED TO ANY CLAIMS, COUNTERCLAIMS, CROSS-CLAIMS, OR THIRD-PARTY CLAIMS) ARISING OUT OF, UNDER OR IN CONNECTION WITH THIS AGREEMENT. FURTHER, EACH PARTY HERETO CERTIFIES THAT NO REPRESENTATIVE OR AGENT OF EITHER PARTY HAS REPRESENTED, EXPRESSLY OR OTHERWISE, THAT SUCH PARTY WOULD NOT IN THE EVENT OF SUCH LITIGATION, SEEK TO ENFORCE THIS WAIVER OF RIGHT TO JURY TRIAL PROVISION.

Disclaimer of Warranties

You understand that we cannot and do not guarantee or warrant that the Site will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our Site for any reconstruction of any lost data.

WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, MOBILE DEVICE, DATA OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE SITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE SITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE SITE, ITS CONTENT AND ANY SERVICES OBTAINED THROUGH THE SITE IS AT YOUR OWN RISK. THE SITE, ITS CONTENT AND ANY SERVICES OBTAINED THROUGH THE SITE ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE COMPANY NOR ANY PERSON ASSOCIATED WITH THE COMPANY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY OR AVAILABILITY OF THE SITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ANYONE ASSOCIATED WITH THE COMPANY REPRESENTS OR WARRANTS THAT THE SITE OR ITS CONTENT WILL BE ACCURATE, RELIABLE, ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE SITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR PARTICULAR PURPOSE.

THE FOREGOING DOES NOT AFFECT ANY WARRANTIES WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

Limitation on Time to File Claims

To the extent allowed by applicable law, you agree that you will bring any claim or cause of action arising from or relating to your access or use of the Site and the Services within one (1) year from the date on which such claim or action arose or accrued or such claim or cause of action will be irrevocably waived.

Entire Agreement

These Terms of Service constitute the entire and exclusive understanding and agreement between Portfolio.io and you regarding the Site and Services, and these Terms of Service supersede and replace any and all prior oral or written understandings or agreements between Portfolio.io and you regarding the Site and the Services.

Severability

If any part of these Terms of Service is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and these Terms of Service shall continue in effect.

Waiver

The failure by Portfolio.io to enforce any right or provision of these Terms of Service will not constitute a waiver of future enforcement of that right or provision. The waiver of any right or provision of these Terms of Service will be effective only if in writing and signed by a duly authorized representative of Portfolio.io. Except as expressly set forth in these Terms of Service, the exercise by either party of any of its remedies under these Terms or Service will be without prejudice to its other remedies under these Terms of Service or otherwise.

Complaints

If you have any complaints, feedback or questions, kindly contact us at support@Portfolio.io.com and we will try to resolve it for you.

_____

PRIVACY POLICY

This Privacy Policy, together with our Terms of Service and any other documents referred to on it, for UNITARITY, INC, (located at 16192 Coastal Highway, Lewes, Sussex, Delaware, U.S.A), and its affiliates (collectively, “Portfolio.io” or the “Company”), explains how Portfolio.io collects, uses, shares and stores the information that you provide when you visit our website, located at https://portfolio.io.com/ (the “Site”). Please read this Privacy Policy in its entirety before using Portfolio.io or visiting the Site.

Portfolio.io is committed to protecting and respecting your privacy. This Privacy Policy explains what you can expect from us and what we need from you in relation to your Personal Information. This Privacy Policy applies to any Services offered by Portfolio.io.

We may amend this Privacy Policy at any time by posting the amended version on this Site and noting the last revised date of the amended version. We may announce material changes to this Privacy Policy via email. By visiting the Site you are accepting and consenting to the practices described in this Privacy Policy.

Definitions

As used herein, the following terms are defined as follows:

  • “Digital Asset” is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital commodity”), such as Bitcoin, Ripple or Ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
  • Portfolio.io Account” means a user-accessible account offered via Portfolio.io.
  • “Portfolio.io” means Portfolio.io-branded websites, applications, services, or tools operated by the Company.
  • “Non-Personal Data” means anonymous data that does not identify you specifically, including data collected automatically when you enter our Site. This may include cookies, pixel tags, web beacons, browser analysis tools, web server logs, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Our server logs may also record the IP addresses of the devices you use to interact with the Site. We may also collect information about a website you were visiting before you came to our Site and any website you visit after you leave our Site, if this information is supplied to us by your browser.
  • “Personal Information” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

Safeguarding Your Personal Information

Portfolio.io is responsible for the collection, use, disclosure, retention and protection of your Personal Information in accordance with our global privacy standards, this Privacy Policy, as well as any applicable national laws. Portfolio.io uses encryption to protect your information. Data controllers process and retain your personal information on our servers where our data centers are located, including the European Union, Japan, Singapore, the United States of America and elsewhere in the world.

We are serious about guarding the privacy of your Personal Information and work hard to protect it from unauthorized access, or unauthorized alteration, disclosure, or destruction. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Information from unauthorized access, including encryption with SSL, the availability of two-factor authentication, and periodic review of our Personal Information collection, storage, and processing practices. We restrict access of your Personal Information only to those Portfolio.io employees, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information.

Unfortunately, despite best practices and technical safeguards, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information during transmission, and any acts of transmission are at your own risk.

Personal Information We Collect

When using Portfolio.io, we may collect and use the following Personal Information about you:

  • Full legal name;
  • Home address, including country of residence;
  • Email address;
  • Mobile phone number;
  • Date of birth;
  • Proof of identity (e.g., driver’s license, passport, or government-issued identity card);
  • An identification number issued by a government;
  • Other Personal Information or commercial and/or identification information; and
  • Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (“AML”) obligations, such as under the European Union’s 4th AML Directive and the U.S. Bank Secrecy Act (“BSA”).

During our practice of collecting Personal Information, you maintain the following rights:

  • Right of Rectification– You have the right to correct any Personal Information we hold on you that is inaccurate, incorrect, or out of date.
  • Right of Erasure – You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Portfolio.io is subject to.
  • Portability – You may have the right to transfer certain of your Personal Information between data controllers, for example, to move your account details from one online platform to another.

Non-Personal Data Collection Practices

Our Site may aggregate and collect anonymous data that does not identify you specifically, including data collected automatically when you enter our Site, including the following:

  • Location Information – Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
  • Log Information – Information that is generated by your use of Portfolio.io that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our Site (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
  • Account Information – Information that is generated by your Portfolio.io account activity including, but not limited to, instructions regarding funding and disbursement, orders, trades, and account balances; and
  • Correspondence – Information that you provide to us in written or oral correspondence, including opening a Portfolio.io account, and with respect to ongoing customer support; and logging of phone numbers used to contact us.

Portfolio.io also utilizes tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (hereinafter, “Cookies”) on your computer or other devices used to visit Portfolio.io. We use both session and persistent Cookies. Session Cookies expire when you log out of your account or close your browser. Persistent Cookies remain on your computer or mobile device until deleted or otherwise expire. Most web browsers are set to accept Cookies by default. You are free to decline most of our session Cookies if your browser or browser add-on permits but choosing to remove or disable our Cookies may interfere with your use and functionality of Portfolio.io. We use Cookies to (i) help us recognize you as a customer, collect information about your use of Portfolio.io to better customize our services and content for you, and to collect information about your computer or other access devices as part to ensure our compliance with our BSA and AML obligations and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities.

To disable automatic data collection techniques you may do any of the following:

  • Email Communications – Subject to applicable laws and regulations, we may from time to time send communications promoting services, products, facilities, or activities to you using information collected from you. When you create a Portfolio.io account you are agreeing to opt-in to all communications from us. We will provide you with an opportunity to opt-out of newsletter communications. We will never provide your Personal Information to third parties for direct marketing or other unrelated purposes without your written consent. Unfortunately, we are unable to allow you to opt-out of the emails we send you for certain legal or administrative purposes.
  • Cookies – You may decline session cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of Portfolio.io.
  • Location Information – You may be able to stop the collection of location information through your device settings or by following the standard uninstall process to remove our applications from your device; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of Portfolio.io.

EU General Data Protection Regulation

As of May 25, 2018, the processing of Personal Information of users located in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). To the extent we process any Personal Information of users located in the EU, you maintain your right to request the information that Portfolio.io has about you, the right to correct that information, the right to delete your account with Portfolio.io, and the right to object to Portfolio.io’s information collection practices. All Personal Information collected is done so for a legitimate purpose in providing our Services to you. If you have any questions or would like to delete your account with us or object to any of our information collection practices, please email us at support@portfolio.io.com.

Information About You from Third-Parties

We work closely with third parties and may receive information about you from them, including the following:

  • The banks you use to transfer money to us will provide us with your basic Personal Information, such as your name and address, as well as your financial information such as your bank account details;
  • Business partners may provide us with your name and address, as well as financial information;
  • Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our Site; and
  • Credit reference agencies do not provide us with any personal information about you but may be used to corroborate the information you have provided to us.

General Provisions

Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the European Economic Area (“EEA”), this Personal Information will not be retained without your consent.

In providing the personal information of any individual (other than yourself) to us during your use of Portfolio.io, you promise that you have obtained consent from such individual to disclose his/her Personal Information to us, as well his/her consent to our collection, use and disclosure of such Personal Information for the purposes set out in this Privacy Policy.

Use of Personal Information and Non-Personal Data

Set forth below is a description of all the ways we use your Personal Information and Non-Personal Data and why we do so. Please contact us at support@Portfolio.io.com if you would like further information regarding how we collect and use your Personal Information and Non-Personal Data.

We may use your Personal Information and Non-Personal Data to do the following:

  • Provide Portfolio.io’s Services to you to carry out our contractual obligations relating to you, including the fulfillment of your orders, the operation of your Portfolio.io account and the provision of our support services;
  • Comply with legal and/or regulatory requirements, including, but not limited to, AML requirements;
  • Verify your identity to protect against fraud, comply with financial crime laws, and to confirm your eligibility to use our Services;
  • Help us better manage your account with Portfolio.io;
  • Provide you with information about new functionality, features, or services we offer;
  • Make suggestions and recommendations to you and other users of Portfolio.io;
  • Process applications for Portfolio.io Accounts services, including making decisions about whether to agree to approve any applications;
  • Improve Portfolio.io’s functionality;
  • Administer internal operations necessary to Portfolio.io, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
  • Notify you about changes to the Terms of Service, Privacy Policy or Services.

Disclosure of your Personal Information

We may share your Personal Information with selected third parties including:

  • Affiliates, operational and business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;
  • Analytics and search engine providers that assist us in the improvement and optimization of our Site; and
  • Our group entities or subsidiaries.

We may disclose your Personal Information to third parties when:

  • We sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets in order to continue the services for which you have contracted;
  • We are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other applicable agreements; or to protect the rights, property, or safety of Portfolio.io, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
  • We conduct or cooperate in investigations of fraud or other illegal activity whenever we believe it is reasonable and appropriate to do so;
  • We seek to prevent and detect fraud and crime;
  • We receive a lawful subpoena, warrant, court order, or as otherwise required by law;
  • We seek to protect Portfolio.io from financial and insurance risks;
  • We seek to recover debt or in relation to your insolvency; and
  • We seek information necessary to maintain or develop customer relationships, services and systems.

In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.

By using Portfolio.io, you consent to your Personal Information being transferred to other countries, including countries that have different data protection rules than your country. In all such transfers, we will protect your Personal Information as described in this Privacy Policy.

We do not maintain a published list of all of the third parties with whom we share your Personal Information with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your Personal Information with, or to be provided with a list specific to you, you can request this by writing to support@portfolio.io.com.

Where We Store Your Personal Information

Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and process your Personal Information in the European Union, Japan, Singapore, the United States of America, and elsewhere in the world.

Automated Decision Making

We may use Automated Decision Making (“ADM”) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with fast and efficient service, we may use ADM to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.

Privacy When Using Digital Assets and Blockchains

Your financial acquisitions may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.

Because blockchains are decentralized or third-party networks, which are not controlled or operated by Portfolio.io or its affiliates, we are not able to erase, modify, or alter Personal Information from such networks.

Data Retention

As Portfolio.io and its affiliates are subject to various legal, compliance and reporting obligations, including BSA or national AML requirements (as defined above), we are required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate.

Access to Information

Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact support@portfolio.io.com.

Changes to this Privacy Policy

Any changes we may make to our Privacy Policy will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Protection of Minors

Portfolio.io is not directed to persons under the age of 18, hereinafter “Minors”, and we do not knowingly collect Personal Information from Minors. If we learn that we have inadvertently gathered Personal Information from a Minor, we will take legally permissible measures to remove that information from our records. Portfolio.io will require the user to close his or her account and will not allow the use of Portfolio.io Services. If you are a parent or guardian of a Minor, and you become aware that a Minor has provided Personal Information to Portfolio.io, please contact us at support@Portfolio.io.com and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

Contact

Any questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@portfolio.io.com.

Where we have a legal obligation to do so, we have appointed data protection officers (“DPOs”) to be responsible for Portfolio.io’s privacy program for the respective data controllers. If you have any questions about how we protect or use your Personal Information, you can contact our DPOs by email at support@portfolio.io.com.

If you feel that we have not addressed your questions or concerns adequately, you may contact your data controller.

UNITARITY, INC — 16192 Coastal Highway, Lewes, Sussex, Delaware, U.S.A


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