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Your Privacy Rights

Effective Date: May 11, 2021

This Privacy Policy describes the types of information gathered by EquityRT, Inc. (“EquityRT”, “us” or “we”) in the process of providing this website, https://equityrt.com/equityrt/, (the “Site”), computing application (the “Application”), and the data, services, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service. It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information.

By using the Service, you consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.

This Privacy Policy is subject to change. If this Privacy Policy changes, we will let you know by posting the revised Privacy Policy on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy (or other method of legal acceptance) means you accept such changes. Please refer to the Effective Date above to see when this Privacy Policy was last updated.

Your personal information may identify you as a person, and thus may be referred to as Personally Identifiable Information (“PII”).

1. Who Collects Your Information On Our Service?

We do. We collect information from you on the Service, and we are responsible for protection of your information.

2. What Information Does EquityRT Collect?

Requested Information. During onboarding as a customer of the Service, we may request specific PII about you in order to add you as a customer, add you to our email list, facilitate your payments for Service, or fulfill your requests for information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Service or receive customer service. We only collect basic personal data about you that does not include any special types of information (e.g., healthrelated). The types of personal information we collect and save include:

Contact and customer account information such as name, email address, physical address, phone number, and business name (if applicable);

Financial information provided by the Account holder, such as investment account assets and transaction history; noting, however, that we do not collect this information automatically from any third parties; and Technical information collected in our logs. Such information may include third-party cookies, and standard web log entries that contain your IP address, browser history, page url, and timestamp.

You may provide us with information when you interact with us through email, or through other use of the Service. We may retain such information in order to provide you with Services. We may send email and text messages using third party service providers.

Non-personal Information. Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, when and how you use the Service, applications downloaded, search terms entered, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. The Service may identify your location through your IP address. Further, the Service may utilize web beacons, pixel tags, third-party cookies, embedded links, and other commonly used information-gathering tools.

If non-personal information is paired to any of your PII, we will treat the non-personal information as if it were also PII.

Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider.

Payment Information. Although it may appear that we collect payment information from you on the Service, it is actually collected and processed through a third party service provider (“Payment Processor”) to process payments for the Service. The Payment Processor may collect payment information such as banking information or credit card number, name, CVV code or date of expiration, from you on the Service. We do not hold your payment information.

3. Why Is My Information Being Collected?

We need to collect your personal information so that we can provide the Service, respond to your requests for information or to be added to our email lists, send you news and alerts, tips for new features of the Service, and to process your payment for the Service.

We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.

4. How Do We Use the Information We Collect?

We use the personal information you provide for the purposes for which you have submitted it including:

Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information, including requests for customer service.

Internal Uses. We may use your PII to track usage trends, conduct usage experiments, develop and improve the Service and other offerings, and perform research and analytics.

Creating and Maintaining Your Customer Account. We use your PII to create and maintain an account for you to allow you o purchase and use the Service.

Paying For the Service. We use your PII to process your payment for the Service.

Communicating With You About Our Services. We may use your PII to send you information about new services and other items that may be of interest to you.

Sending Administrative Emails. We may use your PII to send you emails to: (a) confirm your account registration, account information, and your other PII; (b) process your transactions to purchase our Service; (c) provide you with information regarding the Service; or (d) inform you of changes to this Privacy Policy, our Terms of Service, our Disclaimers, or our other terms, conditions, or policies.

Sending Promotional Emails. We may also use your PII to send you emails to provide you with information on other services and products, or promotions related to the Service or other services and products which may be of interest to you.

We send these types of messages only if you opt in to receive them; please follow the prompts in the messages if you later wish to opt out.

We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our site is used, as well as to offer you programs or services.

The Service may send you push notifications, serve you with advertisements, and may access the internet or use your data plan.

5. Do We Share Your Personal Information?

We will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to carry out internal operations or business activities. With your knowledge and consent, we may share your personal information with our business partners.

In addition, we may transfer your information, including any and all PII that we have collected, to a successor in interest, which may include but may not be limited to a third-party in connection with, or as the result of, an acquisition, sale, asset sale, merger, reorganization, or bankruptcy. We may also share aggregate information with others, including affiliated and non-affiliated organizations.

6. How Can You Access And Control Your Information?

After becoming a customer of the Service, you may revise or edit your customer information by sending an email to legal@equityrt.com. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to legal@equityrt.com. We will also promptly stop sending you advertisements, using your information, and remove it from our servers and database at any time upon your e-mail request to legal@equityrt.com or as we

may otherwise instruct in a communication to you. In addition, you can opt-out of our sharing your PII with third parties, using your PII for reasons other than you provided it, including your PII in an online directory, and using it to send you promotional emails from the Site by emailing us at legal@equityrt.com. If you gave us consent, or otherwise opt-in, for certain uses of your PII, you may revoke that consent at any time by emailing us at legal@equityrt.com. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.

7. How We Store and Protect Your Information

After receiving your personal information, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.

If you are visiting the Site, or accessing the Service, from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.

We store your personal information until you request us to remove it from our servers. We store our logs and other technical records indefinitely but may delete such logs and other technical records at any time in our discretion.

8. How Do We Use Cookies And Other Network Technologies?

To enhance your online experience with us, our web pages may presently or in the future use “cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of the Services may not function properly without the aid of cookies.

Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”).

Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link:

https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by

downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

EquityRT or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some EquityRT Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the EquityRT Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.

As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the EquityRT Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our site.

Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals.

9. Collection of Information by Others

We provide links to certain third-party websites that you may click on our Site. These are provided solely or your convenience. This Privacy Policy does not extend or apply to such third-party websites. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.

10. Geographic Scope and Information for Customers Outside the United States

EquityRT is based in the United States and primarily offers Services to customers in the United States and Canada. If you are located in any other country, please be aware that information collected by us, including PII, may be transferred to our U.S. offices or servers to permit us to conduct our business, comply with our legal and contractual obligations, and to provide information and services to prospective and current clients. We may also provide information, including PII, to third-party service providers in the United States and elsewhere, as may be necessary to support our business activities and provide and support our Services. PII may be transferred to and stored on servers located in the United States and in other countries, which may be different from the country in which that information was initially collected. Similarly, PII we collect may be accessed by our affiliates and our third-party service providers and business partners from countries other than the ones in which the information is stored.

By opting to use our Services and providing your PII in regions of the world with laws governing data collection and use that differ from U.S. law (which include the European Union), you are consenting to the transfer of your information (including PII) outside of those regions to the United States for storage and data processing in accordance with this Policy.

11. Children and Young People’s Information

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the GDPR, USA Children’s Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from our servers, please contact us at legal@equityrt.com. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at legal@equityrt.com.

12. California Privacy Rights

California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at legal@equityrt.com with “Request for Privacy Information” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the


13. Our Contact Information

If you have any questions or concerns about this Privacy Policy you may e-mail us at legal@equityrt.com. Copyright © EquityRT, Inc. All rights reserved. The Service is the property of EquityRT, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.

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