This Privacy Policy describes how vestlygrowth, Inc. and its applicable subsidiaries (collectively, “vestlygrowth”, “we”, “us” or “our”) collects, uses, stores, shares and protects your information in connection with information collected through our websites and other vestlygrowth services or products (“vestlygrowth Services”). This Privacy Policy provides a general overview of our privacy practices regarding your information. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions and which may be applicable to you when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. You can learn more about certain jurisdiction-specific information in the applicable sections at the bottom of this Privacy Policy, including information for individuals residing in Bermuda, the Cayman Islands, the European Economic Area (“EEA”), Hong Kong, Singapore, Switzerland, the United Kingdom, and California. 1. Overview PURPOSE OF THE PRIVACY POLICY We know how important privacy is to our users, which is why this Privacy Policy explains how we collect and use data. 2. The Data we Collect About You Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data over the preceding 12 months about you which we have grouped together as follows: Identity Data includes first name, middle name, maiden name, last name, title, tax ID, marital status, date of birth, gender, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g. your passport or driver’s license). Contact Data includes billing address, residential address, email address, telephone numbers and correspondence records. Financial Data includes bank account details, source of funds, source of wealth and credit history, investment history, financial position and returns. Transaction Data includes details of your vestlygrowth Services activity such as the amount, date, time, recipient for each transaction. Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the vestlygrowth Services. Profile Data includes your username or similar identifier, password, your preferences, feedback and any survey responses. Usage Data includes information about how you use the vestlygrowth Services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Survey and Customer Feedback Data includes information you provide in any survey or feedback forms on vestlygrowth Services. Location Data includes information about your device location. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. We do not collect the following Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, marital or family status, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). Information about criminal convictions When you register for Circle Services, we may receive information about your criminal convictions, proceedings for any offense committed (or alleged to be committed) and/or the disposal of any such proceedings and/or related sentencing when we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations. Processing of sensitive personal data such as criminal convictions will only occur in accordance with applicable law. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e. to provide the vestlygrowth Services to you). In this case, we may have to close your account or limit or restrict your access to other Circle Services, in accordance with the terms of the applicable User Agreement, but we will notify you if this is the case at the time.
