Privacy Policy

This Privacy Policy is incorporated by reference into the Bitrep Terms of Service (the "Terms"). The terms "Bitrep," "we," and "us" include our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined in Section 14 or otherwise herein will have the meanings set forth in the Terms. This Privacy Policy applies to Personal Information that is Processed by Bitrep in the course of our business, including on Bitrep websites (each a "Site"), mobile applications, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Bitrep, the "Services"). All individuals whose responsibilities include the Processing of Personal Information on behalf of Bitrep are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in Singapore, APAC, Europe, United States, and other jurisdictions. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Bitrep and the requirements of applicable law. Some of the ways that Bitrep may collect Personal Information include:

• You may provide Personal Information directly to Bitrep through interacting with the Services, participating in surveys, during events sponsored or held by Bitrep, and requesting Services or information from Bitrep.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it. Bitrep collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively "Individuals").

• Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Bitrep, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
  • Account Creation. We may collect Personal Information from you such as name, email address, phone number or mailing address when you create an Account. We may also collect financial data (i.e., credit card/billing information) along with demographic information, such as age gender, and zip code.
  • Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Bitrep's newsletter that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
  • Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products and/or Services and in any manner consistent with the policies provided herein.]
  • Posting on the Services. Bitrep may offer publicly accessible blogs, private messages, or community forums ("Community Features"). You should be aware that, when you disclose information about yourself through Community Features, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Services, such content will be considered "public" and will not be subject to the privacy protections set forth herein.
  • Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, IMEI, brand ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click, search terms and pages you view within the Services, and other actions taken through use of the Services such as preferences.
• Feedback Submitted Via Services. You agree that Bitrep is free to use the content of any feedback or other communications submitted to Bitrep by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Bitrep will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you connect your Account with or otherwise use a Third-Party application, such as social networking sites like Twitter or Instagram (each, a "Social Network") or an app store, such as the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, "App Stores"), we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or Social Network accounts may include your name, your Social Network user identification number, your Social Network user name, location, sex, birth date, email, profile picture, and your contacts on the Social Network. We may also collect audience demographics data for Social Networks. This supplemental information allows us to verify information that you have provided to Bitrep and to enhance our ability to provide you our Services, products and information about our business.

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

• To Provide Products, Services, or Information Requested. Bitrep may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
  • Generally manage Individual information and Accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of Bitrep's Services;
  • Contact you to answer requests for customer support or technical support;
  • Allow you to register for events.
• Administrative Purposes. Bitrep may use Personal Information about you for its administrative purposes, including to:
  • Measure interest in Bitrep's Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate about Individual Accounts and activities on Bitrep's Services and systems, and, in Bitrep's discretion, changes to any Bitrep policy;
  • Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
  • Process payment for products or services purchased;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms.
• Marketing Bitrep Products and Services. Bitrep may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Bitrep may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
  • To tailor content, advertisements, and offers;
  • To notify you about offers, products, and services that may be of interest to you;
  • To provide Services to you and our partners;
  • For other purposes disclosed at the time that Individuals provide Personal Information; or
  • Otherwise with your consent.
  You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
• Research and Development. Bitrep may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. We may share anonymous Individual and aggregate data for research and analysis purposes.
• Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Bitrep's or our business partners' products and services or upcoming special offers/events we believe may be of interest. We offer the option to opt out of these communications at no cost to the Individual by following the instructions in Section 6 below.
• Anonymous and Aggregated Information Use. Bitrep may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Bitrep's Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Bitrep may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Bitrep and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Sharing Content with Friends or Colleagues. Bitrep's Services may offer various tools and functionalities that permit you to share content, which may include Personal Information. Bitrep will share such Personal Information per your use of the Services.
• Other Uses. Bitrep may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

• Cookies. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Google Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google's collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
• Facebook. We may use certain tools offered by Facebook, Inc. ("Facebook") that enable it to collect or receive information about actions users take on: (a) our Site and elsewhere on the internet through use of Cookies, Web Beacons and other storage technologies; or (b) our mobile application and other mobile applications, in each case, in order to provide measurement services, targeted ads and other services. For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php
Our uses of such Technologies fall into the following general categories:
• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Services. This includes technologies that allow you access to our Services; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Services' content, applications, services, or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Services;
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

The Services, including any emails or advertisements, may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Bitrep does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

The Site and our other Services may also contain links and interactive features with various Social Networks (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online through such Social Networks may be accessible by the providers of such Social Networks and, if posted publicly, may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a Social Network, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes. When you make purchases through the Services, we process your payments through a Third-Party payment processor. The Payment Processor may collect certain financial information from you to process a payment on behalf of Bitrep, including your name, email address, address and other billing information. We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) payment processing; (iii) customer service activities; and (iv) other providers that may be necessary for the provision of the Services.
• Business Partners. Bitrep may share Personal Information with our business partners, and affiliates for our and our affiliates' internal business purposes, as part of the Services we provide to you or at your request.
• Displaying to Other Users. When you post or make information available using the Community Features, that information will be available to other users that can access that post. We are not responsible for privacy practices of the other users who will view and use the posted information.
• Marketing - Interest-Based Advertising and Third Party Marketing. Through our Services, Bitrep may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Bitrep related websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours', ours' or others' rights, property, or safety; (iv) to enforce Bitrep policies or contracts; (v) to collect amounts owed to Bitrep; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
  In addition, from time to time, server logs may be reviewed for security purposes - e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Bitrep will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

You agree that all Personal Information collected via or by Bitrep may be transferred, Processed, and stored anywhere in the world, including but not limited to, Singapore, Asia Pacific, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Bitrep, you explicitly consent to the storage of your Personal Information in these locations. You have the right to object to and opt out of certain uses and disclosures of your Personal Information by deleting your Account. Where you have consented to Bitrep's Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent and delete your Account at any time and opt-out to further Processing by contacting [email protected] through the functionality of the Services. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Services and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Bitrep and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy). Bitrep may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Bitrep may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device. Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners' use of this information for interest-based advertising purposes. You may inquire as to whether Bitrep is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to [email protected] or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Bitrep. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Bitrep makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Bitrep is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If Bitrep determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Bitrep will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. Bitrep retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing. By using the Site, Bitrep will transfer data to the country of Singapore. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Singapore and the adjudication of any disputes arising in connection with Bitrep or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Singapore and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy. The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Bitrep does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child's Account. If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Bitrep by email at [email protected] We will address your concerns and attempt to resolve any privacy issues in a timely manner. This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

• Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.
• Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Bitrep will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
• New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Bitrep will endeavor to comply with the law or contract.

The following capitalized terms shall have the meanings herein as set forth below.

• "Agent" means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Bitrep or to which Bitrep discloses Personal Information for use on its behalf.
• "Personal Information" is any information relating to an identified or identifiable natural person ("Individual").
• "Process" or "Processing" means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• "Sensitive Data" or "Sensitive Personal Information" is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a "Special Category of Personal Data" under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual's sex life; or (8) information relating to the commission of a criminal offense.
• "Third Party" is any company, natural or legal person, public authority, agency, or body other than the Individual, Bitrep or Bitrep's Agents.

Title	Effective Date
Bitrep Privacy Policy	Sept 21, 2018