PRIVACY POLICY.

Effective Date: 7 January, 2023. 

Fourbie Exchange (“our”, “us” or “we”) is committed to protecting your privacy.

This privacy policy (this “Privacy Policy”) describes the types of personal information that we collect from you through the website located at https://www.fourbieexchange.com/ (“Site”) and any content, products, or services made available from or through the Site, including any subdomains thereof (together with the Site, the “Services”), how we use your personal information and the circumstances under which we may disclose it to others. 

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. BY USING THE SERVICES, YOU CONSENT TO THE PRIVACY PRACTICES SET FORTH HEREIN. IF YOU DO NOT AGREE WITH THESE PRIVACY PRACTICES, YOU MUST CEASE USING THE SERVICES IMMEDIATELY.

Data Collection 

Personal Information You Provide to Us

We collect the personal information that you choose to provide to us through the Services. This personal information may include your name, e-mail address, phone number and other data that by itself, or in combination with other data, reveals your identity. 

Usage Data We Automatically Collect 

We also automatically collect usage data when you use the Services. “Usage data” is information about your activity on the Services that, by itself, does not identify you as an individual. For example, the operating system that you are using, the date and time stamp of your visit, the referring URL and your internet service provider. We collect usage data through the use of “cookies” and other data collection tools. For more information about these data collection tools, please see the section of this Privacy Policy titled “Cookies and Other Data Collection Tools.”

If we combine any usage data with personal information, we will treat the combined data as personal information in accordance with this Privacy Policy.

Using Your Personal Information 

We may use your personal information as described at the point of collection or as follows: 

  • To operate and improve the Services;
  • To deliver the services that you have requested;
  • To contact you about events, publications and services that we provide;
  • To better understand how you interact with the Services;
  • To tailor the content and information that we provide to you through the Services;
  • For security purposes;
  • To enforce and protect our rights and the rights of others; and
  • For research and analytics purposes.

Sharing Your Personal Information

We may share your personal information as described at the point of collection or as follows: 

  • With third-party service providers whom we engage to provide services on our behalf;
  • In connection with a merger, sale, acquisition or other change of ownership or control by or of us or an affiliated entity;
  • In response to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process;
  • To enforce and protect our rights and the rights of others; and 
  • To support external auditing, compliance and corporate governance functions.

Other than as described above, we do not share or sell your personal information with third parties, including with third parties for their marketing purposes. 

Protecting Your Personal Information

We use commercially reasonable security measures, including technical, physical and administrative practices and procedures, to protect your personal information against unauthorized access, loss, misuse and alteration. Nevertheless, no system is perfect. Therefore, we cannot guarantee the absolute security of your personal information, and we make no representations or warranties with respect to the sufficiency of those security measures nor will we be responsible for any direct or indirect damages that you may incur as a result of a security breach or technical malfunction.     

Third-Party Websites

We may include links on the Services to third-party websites that we do not operate or control (“Third-Party Websites”). We are not responsible for the collection, use or disclosure of personal information collected through the Third-Party Websites, and we expressly disclaim any and all liability related to such collection, use and disclosure. Therefore, before interacting with the Third-Party Websites, you should consult the privacy policies of those websites to learn more about their privacy practices.

Children’s Privacy

We do not knowingly collect, store, or sell personal information of minors under 16 years of age and no parts of the Services are directed towards or designed to attract anyone under that age. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to legal@fourbieexchange.com. 

Cookies and Other Data Collection Tools

What is a cookie? 

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website again, the cookie allows that website or online service to recognize your browser. Cookies may store unique identifiers, user preferences and other data. 

Why do we use them? 

Cookies help us improve the Services by providing us with data about which parts of the Services are most popular, enabling us to analyze technical and navigational data about the Services and helping us to detect and prevent fraud. We also use cookies and other data collection tools to help improve your experience with the Services. 

How do I control cookies? 

Web browsers allow some control of most cookies through the browser settings. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although you are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some parts of the pp. To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org.

Do Not Track

The Services do not support Do Not Track (DNT). DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your online activities collected. For more information about DNT, please visit www.donottrack.us.

Additional Information for EU Visitors

With respect to “personal data” as defined by Regulation (EU) 2016/679 that you may provide to us through the Services, we serve as the “controller”. 

We provide the Services from servers located in the United States. If you are accessing the Services from the European Union, we will only transfer your personal data to the United States through the use of appropriate safeguards. We process your personal data to pursue our legitimate business interest to operate the Services and as described in the section of this Privacy Policy titled “Using Your Personal Data”. To learn more about with whom we may share your personal data, please refer to the section of this Privacy Policy titled “Sharing Your Personal Information”. 

We retain your personal data for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations. Copies of information that you have updated, modified or deleted will remain in our systems if applicable law requires us to retain it.

You have the right to access your personal data, rectify inaccuracies in it, request the erasure of it and request that we restrict the processing of it in certain circumstances. If you wish to access your personal data, please contact us at legal@fourbieexchange.com, and allow reasonable time for your personal data to be collected. 

You also have the right to lodge a complaint with a supervisory authority.

Modifications to this Privacy Policy

We reserve the right, in our sole discretion, to modify this Privacy Policy at any time without notice to you. We will post all modifications to this Privacy Policy on the Site and they will become effective immediately upon being posted to the Site. Your continued use of the Services following the posting of modifications to this Privacy Policy constitutes your acceptance of those modifications. Therefore, you should check the Effective Date of this Privacy Policy each time that you visit the Site, review the “Notification of Material Modifications” section of this Privacy Policy and review any modifications made since the last time that you visited it.  Notwithstanding the foregoing, to the extent required by law, we will seek your consent to any material changes to this Privacy Policy.

Contact

We welcome questions and comments about this Privacy Policy. Please send your questions and comments to us at legal@fourbieexchange.com.

California Consumer Privacy Act Notice for California Consumers

This California Consumer Privacy Act Notice for California Consumers (“CCPA Privacy Notice”) supplements the Privacy Policy of Fourbie Exchange (“Company,” “we,” or “us”) and applies solely to California consumers.  The California Consumer Privacy Act (“CCPA”) affords California consumers certain rights over their personal information (subject to certain exceptions).  This CCPA Privacy Notice outlines those rights and explains how such rights may be exercised.  This CCPA Privacy Notice also summarizes our data collection and sharing practices, as required by the CCPA. Terms used but not defined shall have the meaning ascribed to them in the CCPA.  For the purpose of this CCPA Privacy Notice, we refer to our websites, applications that run on mobile devices and tablets, and other products and services as “Products,” “Services,” or “Sites.”  

1)      What Information is Covered by this CCPA Privacy Notice?

This CCPA Privacy Notice relates to the Company’s collection, use and disclosure of California consumers’ personal information. “Personal information” generally means information that is reasonably capable of being associated with you or your household.    

2)     What Personal Information Do We Collect and Where Do We Collect Personal Information From?

We collect personal information from information you give us when you use the Services, including when you sign up for an account with us. Such information includes identifying information such as your name, address, and phone number; payment information; your age; your location information; your IP address; and personal description and photographs in your account. We may further collect and analyze the internet protocol (IP) address used to connect your computer to the internet; login, email address, and password; the location of your device or computer; time zone settings.  We may also use device identifiers, cookies, and other technologies on devices, applications, and our web pages to collect browsing, usage, or other technical information. 

3)      How Do We Use Personal Information?

We may use your personal information for a variety of business and commercial purposes.  “Business purpose” generally refers to the use of personal information for our operational purpose.  “Commercial purpose” refers to when we use personal information to advance our commercial or economic interests including, for example, by encouraging others to purchase our Products.   We may use your personal information:

  • To provide products and services;
  • To process and respond to any forms, requests, inquiries, or other information submitted to us; 
  • To provide customer service; 
  • To ensure the security of our Services, websites and information technology systems; 
  • To protect our rights and/or property or the rights and/or property of a third-party;
  • To communicate about our products and/or services; 
  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); 
  • To have third-parties check the validity of the sort code, account number and card number of any credit or debit card that is provided as payment to prevent fraud;
  • In other circumstances in which we believe our services, apps, and/or website are being or have been used in violation of our Terms of Use, applicable law or otherwise in the commission of a crime.
  • When we have a good faith belief that there is an emergency that poses a threat to the safety of any person.
  • In response to requests by government or law enforcement authorities conducting an investigation

4)      Who Do We Share Personal Information With? 

We may share your personal information with the third parties described below.   We do not sell your personal information to any third parties.

Service Providers.  We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, suppliers, agents, attorneys, and representatives (collectively, “Service Providers”).  Service Providers assist us with a variety of functions including, but not limited to, sending marketing communications, assisting with advertising and related analytics, providing management services, conducting research or surveys, sending regular mail and e-mail, maintaining databases, or processing credit card payments.

Business Partners.  We may share your personal information with third-party business partners product suppliers, partners who we conduct joint-marketing activities with, partners who we offer a co-branded service with or provide advertising and related-analytics services to us. 

Disclosures Under Special Circumstances.  We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) when we believe disclosure is necessary to protect or prevent harm, illegal activity, or financial loss; (iii) to detect, investigate and help prevent security, fraud or technical issues; and (iv) to cooperate with law enforcement, government, quasi-governmental and public agency requests or reporting requirement.  

Corporate Transactions.  We may transfer your personal information in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.  For the purpose of this Privacy Policy, third parties who receive personal information in accordance with this section shall be referred to as “Corporate Transaction Recipients.”

At Your Direction:  We may disclose or transfer your information to any third party that you direct or ask us to provide that information to.

5) Your CCPA Rights.

Subject to certain exceptions, the CCPA affords you the following rights:

a) Request to Know.

You have a right to request that the Company disclose what personal information it collects, uses, discloses, and sells. It includes a request for any or all of the following: 

  1. Specific pieces of personal information that the Company has about you;
  2. Categories of personal information the Company has collected about you;
  3. Categories of sources from which your personal information is collected;
  4. Categories of personal information that the Company has sold or disclosed for a business purpose about you; 
  5. Categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
  6. The business or commercial purpose for collecting or selling personal information.

b) Request to Delete.

You have a right to request that the Company delete your personal information that we have collected from you. 

c) No Discrimination.

You have a right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA. 

6)      How to Exercise Your CCPA Rights

a) Submitting a Request to Know or Request to Delete.

You may submit a Request to Know or a Request to Delete by contacting us via email at legal@fourbieexchange.com.

b) Submitting a Request to Opt-Out.

You may exercise your rights by contacting us via email at legal@fourbieexchange.com.

c) Verification Methods. 

Once you submit a request, we will verify that you are the consumer to which the request pertains by matching your name, email address, physical address, telephone number, email address, a security code, or similar information we maintain.  Depending on the type of request you submit, we will attempt to match either two or three of these data points you provided.  If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request.

You may designate an authorized agent to submit a request on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that you verify your identity directly with us. 

7)  Alternate Format of CCPA Privacy Notice.  

If you have a disability that prevents or limits your ability to access this CCPA Privacy Notice, please email us via email at legal@fourbieexchange.com. We will work with you to provide this notice in an alternative format.

8)  Contact for More Information.

If you have any questions or concerns about our privacy policies and practices, please contacts us via email at legal@fourbieexchange.com.