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ROTHCARD Terms of Privacy

Preamble and Reminder

STREAMLINE LLC (hereinafter referred to as “the Company”), a company incorporated under the laws of the United Arab Emirates with registered address: Shams Business Center, Sharjah Media City free Zone, Al Messaned, Sharjah, UAE, operates the ROTHCARD. (hereinafter referred to as “this Platform” or “the Platform”), which is a Platform that is exclusively used by users to trade digital assets and provides them with relevant Services (hereinafter referred to as “the Services”). For the convenience of wording in this Agreement, the Company and the Website are collectively referred to as “We” or other appropriate forms of the first-person pronouns. Any natural person or entity that logs into the Platform shall be a user thereof and are hereinafter referred to as “You” or any other applicable forms of the second-person pronouns. Hereinafter You and us are collectively referred to as “both parties”, and individually as “a party”.

We fully understand and respect the importance of Your personal information to You, and We will adopt corresponding appropriate safety protection measures to protect Your personal information in accordance with the requirements of the applicable laws and regulations. In view of this, this Privacy Policy (hereinafter referred to as “this Policy/this Privacy Policy”) is formulated and the following reminder is provided to You:

This Policy applies to all products and services We provide. If another privacy policy is specifically applicable to any product or service We provide to You, such privacy policy shall prevail; otherwise, this Privacy Policy shall prevail.

In particular, this Policy does not apply to services provided to You by any third party, and such services shall be subject to a privacy policy that is otherwise specified to You.

Before using our products or services, please read carefully and thoroughly understand this Policy, and pay special attention to the clauses that are in bold type or underlined and in bold type, make sure that You fully understand and agree to them before You start using our products or services. If You have any question, comment or suggestion in connection with any content of this Policy, You can contact us through any of the contact methods officially provided by us. If You do not agree with any term or condition in this Policy, You should promptly stop accessing this Platform.

Part I Definition

Personal information: various kinds of information recorded electronically or otherwise, which, alone or in combination with any other information, can identify the identity of a specific natural person or reflect the activities of a specific natural person.

Personal sensitive information: personal information, including Identity Card number, personal biometric information, bank account numbers, property information, tracks of whereabouts, transaction information, and information of children who are not older than fourteen(14) years old, inter alia. (We will prominently identify specific personal sensitive information inbold type in this Privacy Policy).

Deletion of personal information: the act of removing personal information from the systems involved in daily business functions to keep it in a state that cannot be retrieved or accessed.

Children: minors under the age of fourteen(14).

I. How We collect and use Your information

When You use our products and/or services, We need/may need to collect and use Your personal information, including the following two types of information:

  • To provide You with the services/products We supply, You must authorize us to collect and use Your information when necessary. If You choose not to provide this information, You may not be able to use our services normally.
  • To make use of certain auxiliary functions of our services/products, You may choose whether to authorize us to collect Your information. Not providing it may prevent the use of these functions but will not affect the basic functionality of our services.

You must be informed that we may update our products and services hence require new personal information. We will inform You of any new data collection through updates to this policy, interactive pop-ups, or other notifications. We will request Your consent before using this new information.

II. How We Use Cookies

When You visit our Platform, we may use cookies to enhance user experience, analyze site performance, and track the effectiveness of our advertisements. Cookies are small data files stored on Your computer’s hard drive. We do not use cookies to collect personally identifiable information without Your permission, and You can manage cookie preferences through Your browser settings.

III. How We Share, Transfer, and Publicly Disclose Your Information

We respect the privacy of Your personal information and will not share it with third parties without Your consent, except in cases where it may be necessary for legal compliance or within the scope of the services provided to You. This includes sharing information with our authorized partners and during any business transfers due to mergers or acquisitions. Any public disclosure of Your personal data would require explicit consent from You unless otherwise required by law.

IV. How We protect Your information

1. We implement proper physical, electronic, management and technical measures to protect and safeguard Your personal data. We will exert our best efforts to ensure that any personal data collected through our Platform are free from any nuisance caused by any third party unrelated to us. The safety measures We adopt include but are not limited to:

  • Physical measures: Records containing Your personal data will be stored in a properly locked place.
  • Electronic measures: Computer data containing Your personal information will be stored in computer systems and storage media that are subject to strict log-in restriction.
  • Management measures: Only authorized staff is allowed to access Your personal information, and they must abide by our internal confidentiality policies.
  • Technical Measures: We may use encryption and other means to safeguard your personal information.
  • Security Measures: Your personal information is protected with security measures such as SSL encryption to ensure the safety of Your data during transmission.

2. If You become aware of any security hole in our Platform, You are requested to contact us promptly so we can take action as quickly as possible.

3. Nevertheless, despite our efforts, please bear in mind no security system is impervious. Therefore, while we strive to use commercially acceptable means to protect Your personal information, We cannot guarantee its absolute security.

V. How You manage Your information

You can access and manage Your information in any of the following ways:

i. Query, correct and delete Your information

You have the right to obtain a copy of Your personal data upon Your request, and to determine whether the information we have about You is accurate and up-to-date. If any of Your personal data is inaccurate, You can request to update Your information. You can also request for the deletion of Your personal data, provided, however, we may reject Your deletion request in some cases, e.g., where such rejection is required by law or for other legal purposes. For data access, correction or deletion requests, please contact us according to the contact information under Article VIII hereof.

ii. Changing the scope of Your authorization

The fulfillment of each business function requires certain basic personal information (see Part I of this Privacy Policy). You can grant or withdraw Your authorization by contacting us through the contact information under Article VIII.

When You withdraw Your consent, We will no longer process the corresponding personal information. However, Your decision to withdraw Your consent will not affect the previous processing of information based on Your authorization.

iii. Cancellation of Your account

You may at any time contact us to cancel Your account. Upon account cancellation, We will cease providing You with our services, and Your personal information will be deleted or anonymized as required by law.

iv. Respond to Your above requests

To ensure security, You might be required to provide a written request to prove Your identity for Your requests to be processed. We will respond to Your requests within fifteen (15) days. If You are not satisfied with our response, You have the right to lodge a complaint using the provided contact information.

We do not generally charge fees for responding to these requests unless Your requests are repetitive or excessive, in which case we reserve the right to charge a reasonable fee.

There are circumstances under which We may not be able to fulfill Your request, such as for reasons of legal compliance or trade secrets. Specific details of these exceptions are outlined under applicable laws and regulations.

VI. How We deal with the information of minors

This Platform values the privacy of minors and does not knowingly collect personal information from children under the age of fourteen (14) without the consent of a parent or guardian. If you are a minor under the jurisdiction where consent of a parent or legal guardian is required, you should use our services only with the involvement and approval of your parent or guardian.

If we learn that we have collected personal information from a child under 14 without parental consent, we will take steps to delete the information as soon as possible. We encourage parents and guardians to observe, participate in, and monitor the online activities of their children.

For minors who are above the age of fourteen (14) but have not reached the age of majority as defined locally, we expect that the services will be used with parental or guardian supervision. We will treat the personal information of minors with the same protection as other users in accordance with applicable laws.

In the event that personal information of minors is collected with parental consent, it will be used or disclosed only where permissible by law, with the express approval of the parent or guardian, or as necessary for protecting the minors' rights or property.

If a parent or guardian has questions or concerns regarding the processing of a minor's information, please contact us at the provided contact details for further assistance.

VII. How this Privacy Policy is updated

We reserve the right to update or change our Privacy Policy at any time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the home page, login screen, or by sending you an email notification.

We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your continued use of the Service after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

VIII. How to Contact Us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

Address: Shams Business Center, Sharjah Media City Free Zone, Al Messaned, Sharjah, UAE