OTC Trade, LLC (together with its corporate parents, subsidiaries and affiliates, individually and/or collectively, as the context may require, “OTC”, “we”, or “us”) is committed to your privacy and ensuring that your personal information is protected. This online privacy policy (together with any amendments or modifications hereof, collectively, this “Policy”) shall apply to all data and information related or pertaining to the use of our websites, specifically, Otctrade.com, Otctrade.net, Otctrade.org, OtcCrypto.com or any analog, derivative, or variation thereof (together with any and all mobile applications related thereto, individually and/or collectively, as the context may require, the “Website”), as well as to the sale, purchase, exchange, or trade of any form of currency (including cryptocurrency and other currency equivalents) on or in connection with the Website. This Policy explains the types of personal information we collect, why we collect it, how we may use, how we disclose and protect it, and how Users (as defined herein) can update, manage, export, and delete their information. We will also provide Users with additional information that should help protect their security while using the “Service”, as defined in the OTC Website Terms and Conditions (the “Terms and Conditions”). Initially capitalized terms used but not otherwise defined in this Policy have the respective meanings ascribed to them in the Terms and Conditions.

Please read this Policy carefully before accessing or using the Website or the Service. OTC owns and operates the Website, and offers the Service to you, the user (together with any person who views, browses, or uses the Website as a browser, merchant, trader, or contributor of content, individually and/or collectively, as the context may require, the “User”, all “Users”, or “You”), conditioned upon your acceptance of this Policy. This Policy applies to all Users, and all of your personal data that is provided, posted, uploaded, or shared on the Website, or given to OTC in any manner, is subject to this Policy.

Your use of the Website and the Service are subject to the Terms and Conditions. The provisions of the Terms and Conditions are incorporated by reference in their entirety into this Policy, with the same force and effect as if the same were fully set forth herein. For more information, see the entire Terms and Conditions at: https://www.otctrade.com/terms

By visiting, using, or continuing to use any part of the Website or the Service, or by giving us your personal information, You acknowledge, accept, and consent to the practices described in this Policy. If You do not agree to accept this Policy, You may not access the Website, use any part of the Service, or give us any personal information.

We may collect the following types of information in order to provide the Service:

• personal information, such as user IDs, passwords, names, email addresses, telephone numbers, dates of birth, and payment information that is collected and stored upon registration for the Service. (Note: We strongly recommend that You keep passwords unique from other identifiers such as user IDs and member names to help protect your privacy.);
• confirmation notices detailing whether You responded to emails transmitted by the Service for various reasons described in this Policy and in the Terms and Conditions. These notices ensure that You have been properly notified, and record whether You have responded to the email via the included hyperlinks. These notices may be stored in our database;
• usage data of various nature from the Website regarding both registered Users and non-registered Users. For example, we may collect information based on the links visited on the Website or the frequency of visits to enhance features of interest. We may also collect dynamic IP addresses to help track the links of OTC or our partners or affiliates that You may choose during a session. This type of automatically collected information may include, without limitation, such information as the page served, time, source of the request, type of browser making the request, preceding page view, and other such information; and
• personal information received from other sources, which may be stored along with your User profile.

We may collect the information described in the previous section through various methods, including, but not limited to:

• the User account registration process. To register as an authorized User of the Service, You must provide relevant personal information, create a user ID, and create a password. This information, which includes payment and billing information, helps identify your capabilities within the Service;
• Service emails. We collect confirmation-of-receipt messages related to email communications transmitted to Users via the Service; and
• Website navigation. Navigating the Website via links allows us to identify and log your IP address. We may collect IP addresses for purposes of system administration and to report aggregate information to our partners or affiliates.

Your Internet browser includes a feature known as “cookies”, which stores small amounts of data on your computer or mobile device about your visit to the Website. Your browser’s cookie function need not be activated in order to visit the Website, although active participation in certain areas of the Website and/or the Service may require You to activate cookies. Cookies alone tell us nothing about who You are unless You specifically provide us with personally identifiable information, in which case we may use the information to enhance the Service in the ways described below. (Note: by adjusting the settings in your browser, You may elect to prevent the collection of cookies.) OTC also uses technologies, including electronic images known as “Web bugs”—sometimes also referred to as “transparent GIFs”, “clear GIFs”, or “beacons”—that allow us to track general User online traffic patterns. [NOTE TO DRAFT: CLIENT TO CONFIRM USE OF WEB BUGS] We also automatically receive and record information from our servers and from your browser, including your IP address, the time of your visit to pages on the Website, and information about pages You visited. Unless You have registered for a specific portion of the Service, the information we gather through the use of tracking technologies cannot be matched with any of your personally identifiable information.

OTC collects personal information for, without limitation, the following purposes:

• your convenience. For ease of use, we save your password so You don’t have to re-enter it each time You visit the Website;
• to take the pulse of the Users. To determine the popularity of various Service features among Users; and
• to provide relevant advertising. To provide targeted advertisements in which You may be interested. [NOTE TO DRAFT: CLIENT TO CONFIRM ADVERTISING ON WEBSITE]

Collected data and information may be used by OTC for, without limitation, the following purposes:

• contacting You regarding updates or changes to your User account;
• contacting You about updates or changes to the Service;
• updating our database;
• confirming new User registration;
• counting return visits to the Website or our advertisers’ or partners’ websites;
• tracking referrals;
• accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on Website and advertisement usage;
• monitoring the use of the Service to protect other Users and ensure compliance with the Terms and Conditions; and
• sending You information You agreed to receive about topics we think will be of interest to You, including promotional offers from certain marketing partners. (Note: we will not share your contact information with these partners but may send promotional offers on their behalf.)

OTC may disclose your personal data if required to do so by law or, if in OTC’s commercially reasonable judgment, such legal disclosure is necessary to comply with legal processes or to respond to any claims (e.g., financial audits).

OTC also may disclose your personal data if we believe that your actions violate applicable laws, the Terms and Conditions, or any usage guidelines for specific parts of the Service, or threaten the rights, property, or safety of OTC, Users, or any other person or entity.

We will make your personally identifiable information available to other persons or entities only when:

• You have elected to allow us to share such information at the time that You registered on the Website or provided us with such information, or through a subsequent affirmative election via the Website;
• You volunteer information or create a public profile in the course of your use of the Service;
• You use co-branded services (i.e., third-party websites or services that we offer to You in connection with our partners, who or which are identified on the Website). When You use a co-branded portion of the Service, You grant us permission to transmit your registration information to such partners, whose use of your information is subject to their respective applicable privacy policies; [NOTE TO DRAFT: CLIENT TO CONFIRM]
• we hire third-party vendors to provide specialized services, such as customer support; email message deployment; suppression, merge and de-duplication services; data processing; and special products or services that You have requested. These vendors are permitted to use the information only in order to help us provide the Service to You; [NOTE TO DRAFT: CLIENT TO CONFIRM]
• You unsubscribe for a mailing that we send to You on behalf of a third party. We may share your removal instruction with the third party so that it may be added to its list of people to whom they may not send emails; or
• You are the winner of a contest or a sweepstakes that is co-sponsored with a third party and that third party needs your information in order to manage the prize fulfillment process.

We aggregate personally identifiable information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing, promotional, and other purposes. We do not disclose to these parties any information that could be used to identify You personally.

Data related to funds transferred in connection with transactions conducted on or through the Website or the Service is never stored by OTC for any period of time. Funds are transferred directly from one transaction participant to the other(s), or as otherwise agreed upon by the parties to the transaction, without OTC’s oversight or approval. OTC is not responsible for facilitating the legal and proper transfer of funds or transaction data from a buyer to a seller or from one trade participant to another. Legal and proper transfer of such funds or data is the sole responsibility of the individual parties to a transaction.

While using the Service, You may choose to click on links that direct You to the websites of our partners, affiliates, or advertisers (collectively, “Third-Party Links”). If You choose to open a Third-Party Link, OTC may no longer have control of cookies or other solicitations for information on those websites. You should review the privacy policy of any website that You visit through a Third-Party Link before You continue using that website, including, but not limited to, disclosing your personal information. Please refer to the “Third-Party Sites and Content” section of the Terms and Conditions for additional information.

Your dealings with any third party that is connected in any way to the Website and/or the Service are solely between You and any such third party and are subject to any terms, conditions, policies, warranties, and/or representations associated with such dealings.

OTC offers no guarantees or warranties of quality, trustworthiness, or reliability of any third-party website, and OTC makes no representations or warranties regarding anything that may transpire when You visit a third-party website. Users shall visit such websites entirely at their own discretion, by their own accord, and at their own risk. Your use of a third-party website is without warranty or legal liability of any kind on the part of OTC.

We strongly recommend that Users do not share any personal information when using the Service. Please be aware that OTC does not guarantee the security of any personal information made public through the Service, should You choose to do so. OTC cannot control the use of any personal information provided by Users to third parties who or which have access to the Website or the Service and therefore cannot ensure that such parties will respect your privacy.

• Users who prefer not to provide any of the information requested during our account registration process do not need to register on the Website. You may be able to use certain parts of the Service and to view portions of the Content without registering; [NOTE TO DRAFT: CLIENT TO CONFIRM]
• Users interested in registering may opt not to provide certain personal information when registering on the Website; provided, however, that they may be unable to use some portions of the Service without providing certain information; and
• Users have the option to not receive our electronic newsletters or those of third parties when registering. Users who opt-in to our electronic newsletter or third party advertising may remove themselves from mailing lists at any time through the subscription-management pages on the Website or by following the instructions at the end of any email received from OTC.

You have the right to access, free of charge, all personal information we collect for the purposes of correcting it (if inaccurate), erasing it (opting out), or reusing it. To access your personal information, please choose one of the following options:

• log onto your OTC account on the Website using your username and password, and then click on “edit your personal information”; or
• click on our “Contact Us” link on the Website and fill out the online form.

Upon the termination of your OTC account, OTC will delete all personally identifiable account information regarding You and will not maintain any permanent records of your personal information, except and to the extent required by applicable law. Additionally, the termination of your OTC account may not result in the termination of any related accounts maintained with our partners or affiliates. OTC is not responsible for the continued use of personal information by third-party websites not under OTC’s direct control.

OTC does not knowingly solicit or collect personal data from children or individuals who are not of legal age. If we discover that we have accidentally collected personal information from a child (for which the age of consent varies by jurisdiction), we will remove that child’s personal information from our records as soon as is reasonably practicable.

We are continuously seeking to improve the Website and the Service. In accomplishing this objective, we may buy or sell a company or other business entity, or one or more of the companies or other business entities in our corporate family may merge with or be acquired by another company or other business entity. In any such event, we may transfer some or all of your personal information as part of the transaction in order for the Service to continue or for other business purposes.

This Policy may be updated or modified from time to time without notice to You. Any new features or tools which are added to the Website and/or the Service shall also be subject to this Policy. We reserve the right to update, change, or replace all or any part of this Policy by posting updates and/or changes on the Website. We will notify You of significant changes to this Policy by transmitting a notice to the email address(es) associated with your account’s user ID. You may, however, review the most current version of this Policy at any time on this page, and it is your responsibility to check this page periodically for any modifications, revisions, additions, or deletions to this Policy.