Privacy Policy

This Privacy Policy explains what personal data is collected when our customers (“you” or “your”) use the services, how such personal data is processed, and applies to the Pivex family of websites or any website that links to or refers to this Privacy Policy.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENTS

• 1. Personal Data Controller & How to contact us
• 2. Categories of Personal Data We Collect
• 3. How do we process your personal data?
• 4. How do we store personal data and how are they secured?
• 5. Data Retention
• 6. How you can exercise your privacy rights
• 7. Final Provisions
• 1. Personal Data Controller & How to contact us

ALTEXX DIGITAL CORP., a company registered under the laws of the United States of America with its registered office at 3500 S. Dupont Hwy., Dover, Kent, 19901 Delaware will be the controller of your personal data.

If you have any questions relating to the processing of your personal data, including cookies in connection with the operation of the Website, and to exercise your rights, you can contact us at privacy@pivex.com

2. Categories of Personal Data We Collect

In this section we explain how and what types of personal data we acquire from you. Personal data includes any information that can be used to directly or indirectly identify you.

We collect personal data that you provide directly (for example when you register on the website, enter information into your user account or when you communicate with us through customer support), data collected automatically during your use of our services, and data received from third parties. This includes, in particular:

A) Data you give us

You provide us with identification and contact data when you register for and/or use the service. Specifically the name, surname, telephone number, e‑mail address, postal address, date of birth or tax identification number (e.g. Social Security Number), user name and password; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.

Depending on the services you access we may also process the following information about you:

Documents and information gathered during the Know Your Customer (KYC) procedures such as date of birth, results of automated checks including sanctions screening and liveness check.

Tax information necessary for reporting to local tax authorities if you became eligible for the performance rewards on the Pivex trader stage (e.g., W-9 or W-8 forms).

The above information may be collected from various sources. Most often, it will be provided directly by you or generated by your use of the services. However, we may also collect information related to you from third parties, such as during KYC processes where we perform various checks, or from payment service providers.

B) Data we collect automatically:

Data about how you found us. We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).

Device and Location data. We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, browser used, device settings, connection provider, operating system and its version.

Website usage data. We record how you interact with our service. For example, we log the date, time and duration of visit, a country from which you visit the website, website browsing history, the login and logout information, your account settings, the value of your fictitious capital, your account currency, and business strategy.

Transaction data. When you make payments through the service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

3. How do we process your personal data?

We process your personal data for the following purposes:

Purpose of processing*

Description & examples

Categories of Personal Data

Legal Ground

Account Registration and Management

To set up and maintain your user account we process your personal data.

Identification and contact data; we may also process your data related to the settings of your user account

Performance of the contract with you, as we cannot register your account without them

Provision of services & exercise contractual rights and responsibilities

We use your data to give you access to our platform, tools, support, and to carry out simulated trades

Identification and contact data, payment data (in the case of paid services), data on the use of the services, data on the simulated trades

Performance of contract with you and our legitimate interest — including securing our rights post-service, After we stop providing you with services, we may continue to process your personal information for a limited period of time. We do this to fulfill our contract with you and to protect our legal rights.

Marketing and Communication

We may send you updates about our services, promotions, or events, especially if you’re a current or past user. You can opt out anytime via an unsubscribe link.

Identification and contact data

Our legitimate interest (customer engagement) or your explicit consent

Ad Personalization

We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time.

Onboarding information, Device and Geolocation data, Advertising IDs (for example, we may use it for preventing or fixing technical issues);

Cookies and similar tracking technologies

Consent or Legitimate interest* (unless it requires consent, for example, when covered under certain e-Privacy regulations)

Customer Support and Feedback

When you contact our customer support, we process your personal data to respond and assist.

Identification data, contact data, other data and data from social networks, if you contact us through social networks.

Legitimate interest — ensuring effective customer support and satisfaction

Service Improvement

When you use our services, we may process your personal data to develop, test and enhance the services and improve their security.

Identification and contact data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

Legitimate interest — enhancing platform performance and safety

Analytics

We evaluate how users interact with our platform to better understand preferences and optimize user experience.

Identification data, contact data, payment data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

Legitimate interest — tracking user behavior to understand how customers use our services and to identify their preferences.

4. How do we store personal data and how are they secured?

We process your personal data in an encrypted database on computers and other devices. In order to ensure protection against unauthorised access, disclosure or destruction of the data that we collect and process, we have adopted organisational and technical measures to secure them, which we strictly adhere to.

5. Data Retention

Personal data are processed only to the extent necessary to fulfill the purposes outlined above and are retained for the duration required to achieve those purposes or as expressly mandated by law. Once this period has elapsed, the data will be either deleted or anonymized. The specific retention periods are as follows:

For contract performance and the exercise of rights and obligations related to the contract, including complaint resolution, damage claims, or legal proceedings, personal data are retained as necessary, but for no longer than 10 years after the termination of the most recent contract.

For the purpose of sending business communications without your explicit consent, personal data are processed for a maximum of 5 years after the expiration of the last contract, or until you object or unsubscribe from such communications, whichever occurs first.

For service improvement purposes, personal data are typically retained for no more than 6 months.

To comply with legal obligations, we retain personal data for the duration specified by applicable legal requirements (e.g., under tax laws, for 10 years from the issuance of documents related to your order).

If you have provided consent, personal data will be processed for the duration specified in that consent.

With whom we share your personal data

We may share your personal data with the following trusted partners or our affiliates who assist us in providing our services:

Trading platform provider – to enable you to carry out simulated trades.

Other third parties that help us run our website and provide our services, cloud and hosting services, payment processors, financial institutions, customer support providers, IT and system administrators, marketing and communications agencies, consultants, and postal or delivery services.

We may also share your data with:

Parties you have given us permission to share your information with.

Authorities or others when we’re legally required to do so, such as by law, court order, or another binding decision. The recipients of your personal data are contractually required to keep your information secure in accordance with applicable laws and to use it only in line with our instructions in accordance with the terms of their contract with us.

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions.

Some third parties may collect and use your personal data for their own purposes. In these cases, they act as independent data controllers, and their own privacy policies will apply.

6. How you can exercise your privacy rights

Subject to applicable U.S. legislation, you may have the following rights with respect to your personal information. Depending on the state in which you reside, additional rights may apply. Please refer to the laws applicable in your state for further details.

To exercise any of your rights, you can send a request to privacy@pivex.com or use the contact details listed in Section 1 of this Privacy Policy. As a user, you have the following rights when it comes to personal data:

Right of access to personal data

You can ask us at any time to send you a confirmation as to whether or not your personal data are being processed. If we process your data, we will provide you with further details on the processing. If you request it, we will also provide you with a copy of the personal data processed. Please note that the first copy is free of charge, but later copies will be provided for a small fee.

Right to rectification of personal data

If we process your personal data inaccurately, you can notify us of this fact, and we will rectify the inaccurate personal data without undue delay. If you register on the Website, you will be able to rectify and amend your personal data yourself by editing your user account.

Right to Deletion

You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:

If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them;

If you withdraw your consent to their processing and, at the same time, there will be no other legal ground for their processing (this only applies in the cases where we process personal data on the basis of your consent);

If you object and there are no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or

If your personal data are processed unlawfully.

We will not be able to act on the request for the erasure of personal data if their processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defence of our legal claims, or for other reasons provided for by law.

Right to restriction of processing

Request restriction of processing in specific situations, such as contesting accuracy or pending an objection.

Right to data portability and to the provision of data in a machine-readable format

In the case of automated processing based on your consent or performance of the contract, you have the right to receive the data in a structured, commonly used and machine-readable format and to have them transmitted by us to another personal data controller.

Right to object

If we process personal data on the basis of our legitimate interest, you have the right to object to such processing. If you file such an objection, we will not be able to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or for the establishment, exercise or defence of our legal claims.

In case we process your personal data for marketing purposes about our products and services, we will terminate the processing without undue delay upon receipt of the objection. In such a case, we will no longer be able to send you offers of our products and services.

Right to withdraw consent

If processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before its withdrawal.

Right not to be the subject of automated decision-making

Except where processing is necessary for entering into, or performance of, a contract, where this is permitted by applicable law, or based on your express consent, you have the right not to be the subject of any decision which is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent.

Right to lodge a complaint: You may have the right to lodge a complaint with a supervisory authority if you believe your data is being processed unlawfully.

Right to opt-out of sale or sharing: We do not sell your personal data. We may share certain information about you with our partners for purposes of targeted advertising or data analytics, which under certain US state (for example, California, Colorado, Connecticut and Virginia) privacy laws could be characterized as “selling,” “sharing,” or “targeted advertising”. You can control this sharing and exercise your right to opt-out by sending a request to privacy@pivex.com.

Right of Non-Discrimination

We will not discriminate against you for exercising any of the rights described in this section. We will not deny you goods or services, charge different prices, provide a different level or quality of services, or suggest that you will receive a different price or level of service because you exercised your privacy rights.

Right to limit use and disclosure of sensitive personal information: We do not process sensitive personal information (such as identifiers, geolocation, or financial credentials) for purposes beyond providing our essential services without your explicit consent.

7. Age Limitation

Our Services are not directed to individuals under the age of 18 and we do not knowingly collect personal data from children. If you learn that anyone younger than 18 has provided us with personal data, please contact us through privacy@pivex.com.

8. Final Provisions

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our service and will have an opportunity to review the revised Privacy Policy. You can find the latest version of this policy on our Website.