1. GENERAL

This Privacy Policy provides a comprehensive description of how Bric America LLC (“Bric”), with a registered office at 16192 Coastal High way Lewes, Delaware 19958, Sussex County, collects, uses, and shares information about you as well as your rights and choices regarding such information in relation to your use of Bric’s services (the “Services”). Depending on the context, “Bric'' may also refer to the website, digital platform, mobile application, content, or other materials provided by Bric.

The Privacy Policy applies to the information collected by Bric through its websites, digital platform, or mobile application (the “Sites”). The purpose of the Privacy Policy is to give you a clear explanation of how Bric collects and processes your personal information. Bric reserves the right, at any time, to modify or replace this Privacy Policy. The most recent version of the Privacy Policy will be available on the Sites.

By using the Services, you agree to Bric’s Terms and Conditions and to its collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Services.

If you have any questions or wish to exercise your rights and choices, please contact Bric as set out in the “Contact Us” section.



2. PERSONAL DATA DEFINITION

Personal data (the “Personal Data”) is information related to a living individual who can be directly or indirectly identified from that data. The identification can be performed with the help of the information alone or in conjunction with any other information in Bric’s possession or likely to come into such possession. 



3. INFORMATION COLLECTION

Bric automatically collects and receives certain information from your computer or mobile device, including the activities you perform on the Sites, your location, demographic data, behaviour, interests, the type of hardware and software you are using (for example, your operating system or browser). Bric collects personal information that you provide to us when you:

(a) Create an account on our Sites;

(b) Complete online forms, such as registration or contact forms;

(c) Sign up for our newsletter or other communications;

(d) Use our Services;

(e) Submit information in response to emails, requests for information or other outreach to Bric; and

(f) Participate in surveys, contests, or promotions.


3.1 Why Bric Collects Personal Data from You

Bric is required by law to collect data in relation to anti-fraud, anti-money laundering, counter financing of terrorism and know your customer obligations. You can decide if you want to share certain personal information with Bric. However, if you choose not to share some details, Bric may not be able to offer you the Services. 

3.2 Data Collection From Registration

When creating an account to access the Services, Bric collects the following type of data:
 
Personal identification information (your name, email address, phone number, home and work address);
Demographic characteristics (your country of citizenship, date of birth, and marital status);
Profile related information (your password and username required for accessing the Services);
Official identification documents (which could include information like a copy of your passport, national identification number, and relevant identification photographs);
Information about your investment experience, such as objectives, liquidity needs, and risk tolerance;
Occupation information, like your job title, or relationship to other companies, such as whether you are a beneficial owner or authorized signatory of a legal entity using the Services; and
Financial information, such as your income, sources of income, net worth, occupation, related documents like financial statements, details about bank accounts used for investments, and cryptocurrency wallet addresses.

Finally, Bric can utilize public databases and ID verification partners to confirm your identity. Bric’s ID verification partners may employ government records and publicly accessible data to validate your identity, along with details like your name, address, job position, public employment profile, credit history, and status on public sanctions lists.  This information is used by Bric to enable it to meet its legal obligations, especially in terms of meeting its anti-terrorism and anti-money laundering requirements, laws and regulations. Occasionally, Bric will process additional data to prevent fraudulent or illicit use of the Services.

3.3 Data Collection When Visiting the Sites

When you visit the Sites, Bric records each access instance in a log file, storing the following data:

Information about your computer or mobile device;
The website from which our domain is accessed and usage details;
The country from which the Sites is accessed;
The operating system of your computer;
The name of your internet provider;
The name and URL of the accessed data;
IP address of the accessing computer; and 
Date and time of access.

These data are typically anonymized and are solely used to establish a connection with the Sites, maintain ongoing system security and stability, and for statistical purposes. They are not associated or stored with Personal Data. The IP addresses of accessing computers are analyzed only in the case of a network infrastructure attack, suspicion of unauthorized website use, or for defense purposes in criminal proceedings for identification and civil proceedings against the user involved. The IP address is also used to restrict geographical zones from accessing Bric’s services.

Bric also collaborates with Microsoft Clarity and may collaborate with Microsoft Advertising to capture your interactions with the Sites through behavioral metrics, heatmaps, and session replay, aiming to enhance and market products/services. Sites usage data is collected using first and third-party cookies and other tracking technologies for product/service popularity assessment, online activity analysis, site optimization, fraud/security prevention, and advertising. 



4. SOURCES OF DATA AND DATA COLLECTION METHODS

When you visit the Sites, Bric automatically collects certain information using tracking technologies. This data may include:
Service use data, which encompasses information about the features you utilize, the pages you visit, emails and advertisements you check, products and services you view and purchase, the time of day you browse, and the pages you enter and exit;
Device data, like details about the type of device or browser you use, the operating software of your device, your internet service provider, your device's regional and language settings, and identifiers such as IP address and Ad Id; and
Location data, such as information derived from an IP address or data indicating a city or postal code level.
The types of tracking technologies Bric may use to automatically collect information include:
Log files, which record events during your use of the Services;
Cookies, which are small data files on your device, with session cookies expiring when you close your browser and persistent cookies aiding personalization, preferences, security, and advertising. Persistent cookies can be controlled through browser settings;
Pixels (Web Beacons), which are code embedded in a website, video, email, or ad transmitting usage information to a server. Pixels, combined with cookies, track browser activity. Pixels may be used from entities like Facebook for tracking conversions, advertising on and off the Service, and additional functionality;
Device fingerprinting for analyzing data elements from your device's browser to create a unique device "fingerprint" for identification;
App technologies, such as non-browser technologies, like SDKs, sending information to a server (e.g., Facebook SDK). These technologies help track conversions, deliver advertising on and off the Service, and provide extra functionality; and
Location-identifying technologies, like GPS, WiFi, and Bluetooth used to collect your location data with your consent. This data is used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

4.1 Information from Other Sources.

Bric also collects information from other sources. The categories of sources from which Bric may collect information includes, without limitation: 

ID verification and compliance partners; 
Data brokers from which Bric purchases data to supplement the data Bric collects;
Social networks with which you interact;
Partners that offer co-branded services, sell or distribute Bric’s products, or engage  joint marketing activities; and 
Publicly-available sources, including data in the public domain.
 


5. HOW BRIC USES YOUR INFORMATION

Bric collects and uses information for legal, regulatory, business and commercial purposes in accordance with the practices described in this Privacy Policy. The purpose for collecting information includes: 

Operating and managing the Services, and ensuring quality control;
Maintaining legal and regulatory compliance including but not limited to ensuring compliance with anti-terrorism and anti-money laundering laws and regulation;
Performing services requested by you, such as responding to comments, questions, and requests, and providing customer services;
Sending technical notices, updates, security alerts, information regarding changes to Bric’s policies, and support and administrative messages;
Preventing and addressing fraud, breach of policies or terms, and threats or harm;
Monitoring and analysing trends, usage, and activities;
Conducting research, including focus groups and surveys;
Improving the Services and other Bric websites, apps, marketing efforts, products and services;
Developing and sending advertising, direct marketing, and communications about products, offers, promotions, rewards, events, and services;
Facilitating corporate restructurings. 
Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries; and
Fulfilling any other purpose at your direction.
Bric may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how Bric uses information about you, please see the “Your Rights and Choices” section below.



6. NON-PERSONAL INFORMATION

Bric may use non-personal information for system administration, assisting in diagnosing problems with Bric servers, monitoring Bric’s system performance and traffic on the Sites, and gathering broad demographic information about visitors on the Sites.



7. LEGAL BASIS FOR DATA COLLECTION

Bric serves as the data controller for your Personal Data, in that it determines the means and purposes of processing your data. Bric collects and processes Personal Data for various purposes and is committed to ensuring that its data processing activities are lawful and transparent. The legal basis for Bric’s data collection may vary depending on the specific purpose for which it collects the data. Below, the primary legal bases relied on includes:

Consent, which you can withdraw anytime;
Contractual necessity, through processing data necessary to fulfilling contracts with you;
Compliance with applicable laws and regulations;
Data processing for Bric’s legitimate interests; and
Data processing for the public interest.

You are entitled to request that any incomplete or inaccurate Personal Data Bric holds about you is corrected or updated. Please contact Bric for assistance in making the necessary changes. See the “Contact Us” section.



8. SPECIFIC RIGHTS IN RELATION TO YOUR DATA

Unless subject to an exemption under the applicable regulation, you have the following rights for your Personal Data. To:

Request a copy of your personal information in Bric’s possession;
Request that Bric corrects any personal information if it is found to be inaccurate or out of date;
Receive a copy of your Personal Data in a structured, machine-readable format and to request the transfer of this data to another data controller;
Request that your personal information is erased where it is no longer necessary and there is no compelling reason for its continued processing;
Withdraw your consent to the processing of your personal information at any time;
Where there is a dispute about the accuracy or processing of your personal information, to request a restriction is placed on further processing; 
Contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered; and
Object to the processing of your personal information.

To exercise your data protection rights or make inquiries about your personal data, see the “Contact Us” section below. 

You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.



9. HOW AND FOR HOW LONG BRIC PROCESSES YOUR PERSONAL DATA

Bric is committed to retaining your Personal Data only for as long as necessary to fulfill the purposes for which it was collected. Bric may retain different categories of your data for varying periods based on the following criteria:

Account information is retained while your account is active and for a reasonable period afterwards in case you decide to reactivate your account;
Data related to transactions, such as purchases or orders, is retained for the duration necessary to fulfill the transaction and any legal obligations; 
Data related to customer support interactions, including inquiries, feedback, or issues, is retained for as long as needed to address your specific request and to improve services; and
Sometimes, Bric may be required to retain your data for a longer period due to legal, regulatory, or compliance obligations.

Bric will not retain your Personal Data when it is no longer necessary for the purposes for which it was collected or when you withdraw your consent, where applicable. Additionally, Bric will delete your data if it is no longer relevant for the purposes for which it was collected, or if you request us to do so, in accordance with your data subject rights.



10. DISCLOSURE OF INFORMATION TO THIRD PARTIES

Collected information is shared in accordance with the practices described in this Privacy Policy. The categories of parties with who Bric may share information with include: 

ID verification and compliance partners who assist in verifying identity and information to ensure compliance with laws and regulations, including but not limited to anti-terrorism and anti-money laundering laws and regulations;
Service providers who assist with tasks such as payment processing, data analytics, marketing, website hosting, and  technical support. They use the information only for the specified services and prohibit them from using it for other purposes;
Vendors and other parties for analytics and advertising purposes. These parties may act as Bric’s service providers or independently decide how to process your information;
Bric affiliates and related entities or individuals, such as -but not limited to- directors, officers, managers, agents, and employees, either as service providers or for their internal purposes;
Information in connection with or during negotiations of mergers, purchases, sales, or other business combinations involving Bric’s assets or business;
Information to comply with the law, legal processes, or lawful requests by public authorities, including those related to national security or law enforcement; 
Information to protect the rights, property, or safety of you, Bric, or a third party; and
Information at your request or direction.

Bric does not sell your personal information and Personal Data to outside parties, and does not transfer, or disclose it except as specified in this Privacy Policy.



11. ANALYTICS AND ADVERTISING

Bric may use analytics services, such as Google Analytics, to help it understand how users access and use the Services. In addition, Bric may work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. 

As part of this process, Bric may incorporate tracking technologies into its own Services (including the Sites and emails) as well as into ads potentially displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you (“Interest-based Advertising”).



12. YOUR RIGHTS AND CHOICES

You may access, update, or remove certain information that you have provided to Bric . To do so, please contact Bric for assistance in taking the necessary action. See the “Contact Us” section.
 
12.1 Tracking Technology Choices.

Cookies and Pixels: most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. 
Do Not Track: your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Bric does not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
App and Location Technologies: you can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Services may not function correctly. 

12.2 Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.  

The companies Bric may work with to provide you with targeted ads normally give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

You may also limit Bric’s use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices). 

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. Bric is not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

12.3 Communications

You can opt-out of receiving promotional emails from Bric at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing Bric at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.

If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.



13. CHILDREN.

Bric does not knowingly collect personal information from any person under the age of 18. 

If a user submitting Personal Data is suspected of being younger than 18 years of age, Bric will require the user to close his or her account. Bric will also take all necessary steps to delete his or her information as soon as possible. 

If you are a parent or guardian and believe Bric has collected personal information in violation of the United States Children’s Privacy Protection Act (“COPPA”), contact Bric – see the “Contact Us” section.  Bric will remove the personal information in accordance with COPPA. Bric  does not knowingly “sell,” as that term is defined under the California Consumer Privacy Act (“CCPA”), the personal information of minors under 16 years old who are California residents.



14. DATA SECURITY.

Bric is committed to safeguarding your information and implements and maintains reasonable administrative, physical, and technical security measures to protect the confidentiality, integrity and availability of information about you. These safeguards are designed to mitigate risks such as loss, theft, misuse and unauthorized access, disclosure, alteration and destruction of your data. Nevertheless, it is important to recognize that no method of transmission over the internet or electronic storage is completely secure. By using Bric’s Services, you acknowledge and accept the inherent risks associated with transmitting information over the internet and Bric cannot guarantee the security of information about you. Bric disclaims any liability for damages or losses resulting from security breaches, unauthorized access, or any other security incidents beyond our reasonable control. Bric encourages you to take precautions to protect your own information, such as using strong, unique passwords, and keeping your login credentials confidential. If you have any concerns about the security of your information or suspect any unauthorized activity, please contact Bric as set out in the “Contact Us” section.



15. INTERNATIONAL TRANSFER.

Bric is based in the United States and stores and processes Personal Data in data centers around the world, wherever Bric premises or service providers are located. The information it collects is governed by United States law. Please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the United States and other jurisdictions as set out in this Privacy Policy. 



16. CONTACT US.

If you have any questions or issues with our compliance, please contact our Data Protection Officer at:

By email: contact@inbric.io 
By post: BRIC AMERICA LLC, 16192 Coastal Highway, Lewes, DE 19958 

Bric may require specific information from you to help us confirm your identity and process your request.