Privacy Policy

Thank you for visiting GoTrow.com. The relevant GoTrow entity acting as the data controller provides this Privacy Policy statement to describe our practices with respect to the collection, storage, use, disclosure and other processing of personal data (as defined below). By accessing or using GoTrow.com and the related application interface or mobile application ("GoTrow Platform"), you (a) acknowledge that you have the right, ability and authorization to accept this Privacy Policy Statement ("Privacy Policy"); (b) acknowledge that you have read and understood this Privacy Policy; and (c) agree to the policies and practices described in this Privacy Policy. So please read carefully to understand our work.

This Privacy Policy explains what data we collect, why we collect it, how we use and store it, how we share it, what rights you may have and how to contact us about our privacy practices. If you do not want your Personal Data (as defined below) to be used in the manner described in this Privacy Policy, you may not use the GoTrow Platform, the technologies, products and/or features provided by the GoTrow Platform (collectively, the "Services").

Data Protection Officer: refers to the relevant GoTrow Data Protection Officer responsible for data protection.

Digital Assets: a computer network-based encryption protocol that can be centralized or decentralized, closed or open source, digital assets (also known as "virtual financial assets," "convertible virtual currencies," "cryptocurrencies," "virtual currencies," "digital currencies," "digital commodities," or "digital payment tokens") that can be used as a medium of exchange and/or a store of value, such as Bitcoin or Ether.

Personal Data: means any information relating to an identified natural person ("data subject"), or any information that can identify the individual directly or indirectly by means of linking data, using an identifier (e.g. name, voice, picture, identification number, online identifier, geographical location or one or more special features indicating the physical, psychological, economic, cultural or social identity of the individual). It does not include de-identified data (anonymized data). This includes sensitive information.

Sensitive Information: means any data that directly or indirectly reveals a natural person's family, ethnic origin, political or philosophical views, religious beliefs, criminal record, biometric data or any data relating to that person's health, such as his/her physical, mental, spiritual, genetic or sexual status, including information relating to the provision of health care services that may reveal his/her health status.

GoTrow collects, processes and stores personal data through your use of the Services or with your consent. This personal data may include contact details, copies of identification documents you provide or obtained from publicly accessible databases, your government identification number, and information related to your device or internet service (such as IP address and MAC number).

To learn how GoTrow protects the data it collects from its users, see section 13 below ("Information Security").

We collect information that you provide during the GoTrow Platform login process, which may be completed, not completed, or abandoned. We also collect personal data when you communicate with us through customer support, subscribe to marketing newsletters, communicate with us by phone, email or other communication channels, or when you conduct transactions on the GoTrow Platform. We may proactively or automatically collect, use, store or transfer your personal data, which may include, but is not limited to, the following:

Personally identifiable information, such as name, email, telephone number, nationality, date of birth, address and government identification information;

Organization details, such as company legal name, company registration information, government ID number, proof of identity and legal presence, address, business description and beneficial owner information;

Business information such as data related to transactions conducted on the GoTrow Platform;

Financial information, such as credit/debit card numbers and bank account information;

Communications, such as communications with our customer support team and responses to user surveys;

Information required by regulatory bodies such as state and federal licensing agencies and consumer protection agencies;

Other identifiers, such as device fingerprint data, IP address and geolocation information.

We may also collect personal data about you from third parties, such as e-verification services, referees, marketing agencies or liquidity providers. If so, we will take reasonable steps to ensure that they are aware of applicable privacy laws. We may also use third parties to analyze traffic to our website, which may involve the use of cookies (see Section 12 below for more information on the use of cookies). The information collected through such analysis is not anonymous.

We do not collect sensitive information about you without your consent, unless an exemption or exception applies. These exemptions or exceptions include collection required or authorized by law, or necessary to take appropriate action against suspected illegal activity or serious misconduct.

If you do not provide the personal data we have requested, we may not be able to provide you with our services or meet your needs appropriately. Therefore, we do not offer you the option of dealing with us anonymously or under an assumed name.

In addition, we conduct business in accordance with data protection laws and collect personal data from individuals and entities located in different jurisdictions. Where applicable, we need to protect personal data processed in such jurisdictions in accordance with applicable data protection laws. To learn more about how we protect data collected from individuals and entities in such jurisdictions, please see relevant local laws.

We may proactively receive personal data about you. We will destroy or de-identify all unsolicited personal data we receive unless it is relevant to the purposes for which personal data was collected as described in this Privacy Policy. If additional information we receive about you is combined with other information we need or have the right to collect, we may retain that information. If we do so, we will retain this information just as we would any other personal data about you.

The personal data we may collect and hold includes, but is not limited to, personal data about users, potential users, service providers or vendors of the GoTrow Platform or our services, potential employees, employees and contractors, and other third parties with whom we engage.

GoTrow uses personal data to manage, provide, improve and personalize services for you and to comply with our legal and regulatory obligations. We may also use such data to communicate with you regarding other products or services offered by GoTrow and/or its partners in order to consider any concerns or complaints you may have.

We may use and disclose your personal data for these purposes. We may also use and disclose personal data for secondary purposes related to the primary purposes described in this section or in other circumstances as authorized by law.

Unless you expressly consent, or are exempt by applicable law, sensitive information will be used and disclosed for the purpose for which it was provided (or for a directly related secondary purpose). The following is how we process your personal data:

To provide you with our services. We use your personal data to provide our services to you in accordance with our Terms of Service. For example, we need to know certain financial information in order to transfer money into and out of your account.

Detect and prevent fraud. Your personal data is used to detect and prevent fraud.

Protect the security of our services. We process your personal data, such as information about your devices and activities, to maintain the security of your account and the GoTrow Platform.

User/customer support. When you contact our customer support team to help us resolve your issue, we process your personal data.

Enhance our services. We process your personal data in order to understand how we can use our services to improve our services and develop new services.

Product marketing. We process your personal data in order to identify services that we believe may be of interest to you. We may contact you about these issues. For more information, see section 11 (Communication) below.

Consent. With your consent, we may use your personal data for other purposes.

Other commercial purposes. We may use your personal data for other reasonably anticipated commercial purposes permitted by law or necessary to comply with our legal obligations.

If you have not consented to our processing of your personal data, we may still process your personal data on one of the following grounds:

Public interest. Where necessary to protect the public interest, we will process your personal data without your consent.

Legal action. When it is necessary to initiate or defend legal proceedings or in connection with judicial or security proceedings, we will process your personal data without your consent.

Protect your interests. When it is necessary to protect your interests, we will process your personal data without your consent.

Performance of the contract. We will process your personal data without your consent if it is necessary to fulfill a contract to which you are a party or to take measures at your request prior to entering into such a contract; we provide our services on this basis.

Comply with legal obligations. When we need to comply with our legal obligations, we will process your personal data without your consent.

GoTrow may disclose personal data to:

Members of our group of companies, including our subsidiaries, holding companies and companies under common control, including their respective contractors, affiliates, employees or representatives.

Our service providers and other third parties who assist us in providing services to you, and/or such third parties as are required or permitted by law or professional standards, including, for example, payment processing, customer support, data analytics, information technology, data processing, network infrastructure, storage and tax reporting.

Entities related to corporate transactions involving GoTrow, including any financing, acquisition or dissolution proceedings involving the disclosure of some or all of our business or assets.

Government entities or other parties to legal proceedings, including law enforcement agencies and authorities, officials, regulators, or other third parties, to comply with any law, court order, subpoena, or government request.

Professional advisors, including legal, accounting or other advisory services for auditing or compliance with our legal obligations.

Except as disclosed in this Privacy Policy, GoTrow will not share your personal data with any other third party unless required to do so by law or legal reporting obligations. The GoTrow Platform may contain links to other third party websites which may apply their own privacy policies and GoTrow is not responsible for the privacy policies of such third party websites.

If we disclose your personal data to service providers who carry out business activities for us, they can only use your personal data for the specific purposes for which we provided the data. We will take reasonable steps to ensure that all contractual arrangements with third parties fully comply with applicable privacy laws. In addition, we have implemented standards for the prevention of money laundering, terrorist financing, and circumvention of trade and economic sanctions, which comply with applicable local jurisdictions and require us to conduct due diligence on our users. This may include the use of third-party data and service providers that cross-reference your personal data for identity verification, fraud detection and prevention, transaction monitoring, credit verification, and security threat detection.

We recognize the importance of protecting our users' personal data. We will take steps to ensure that your personal data is not abused, interfered with or lost, as well as unauthorized access, modification or disclosure. Your personal data is generally stored on our or our affiliates' computer databases and/or third-party storage providers. For information stored in our computer databases, we implement data security guidelines to ensure that your personal data is managed securely.

For more information, see section 13 (Information Security) below.

We retain your personal data for as long as is reasonably necessary to provide you with the services, for our legitimate business purposes and to comply with our legal and regulatory obligations. If you close your account on the GoTrow Platform, we will continue to retain your personal data in order to comply with legal and regulatory obligations. For example, we are required to comply with certain anti-money laundering laws, under which we are required to retain records used to fulfill our customer identification and due diligence obligations for an additional period after the end of our business relationship with you.

The GoTrow Group operates globally and personal data may be stored and processed in any country where we operate or in any country where we employ service providers. We may disclose information to third party storage providers or affiliates located outside of your country, or to third party storage providers or affiliates located outside of your country.

We may transfer the personal data we hold about you to recipients in countries other than the country where the personal data was originally collected. The data protection or privacy rules of these other countries may differ from the rules in your country. However, we will take steps to ensure that any such transfer complies with applicable data protection laws and that your personal data is always protected by the standards described in this Privacy Policy. In some cases, courts, law enforcement agencies, regulatory authorities or security authorities in these other countries may have access to your personal data. By communicating electronically with GoTrow, you acknowledge and consent to the processing of your personal data in this way.

Subject to exceptions provided for by law, you have the right, upon request, to obtain a copy of your personal data and to ascertain whether the information we hold about you is accurate and up-to-date. We will provide access within 30 days of your request. If we refuse to provide information, we will provide reasons for the refusal. Before giving you access, we will ask for authentication and explain the required information. If any of your personal data is inaccurate, you can request that your information be updated. Unless you agree otherwise, if we are satisfied that the request to update information is accurate, we will take reasonable steps to correct the information within 30 days. You can also request the deletion of your personal data, but in certain circumstances (such as to comply with the law or for legitimate purposes) we may refuse your deletion request. For requests for data access, correction or deletion, or requests to withdraw the consent you previously provided, please send an email containing your request to the relevant email address with the subject line "Data Query Request".

GoTrow does not knowingly provide services or collect personal data from anyone under the age of 18. If we learn that we have collected personal data from anyone under the age of 18, we will immediately delete it from our systems. If you notice anyone under the age of 18 using our Services, please notify us so that we can take timely steps to prevent them from accessing our Services.

We may use the personal data we collect from you for direct marketing purposes without your consent only if: personal data does not include sensitive information; you reasonably expect us to use or disclose the information for direct marketing purposes; we provide an easy way to opt out of direct marketing and you do not ask to opt out of receiving direct marketing from us.

If we collect your personal data from third parties, we will only use that information for direct marketing purposes where you have given your consent (or where it would be impractical to obtain your consent) and we will provide a simple way for you to easily request not to receive direct marketing communications from us. We will bring to your attention in our direct marketing communications that you can make such a request.

We may convey company news, promotions, and information related to GoTrow products and services. We may share personal data with third parties to help us with marketing and promotional projects, or to send marketing messages.

Users can opt out of these marketing communications at any time by clicking the unsubscribe link in any marketing communications sent to you or by contacting customer service at our Help Center.

For communications related to the Services, such as surveys, policy/terms updates, and operational notices, you will not be able to opt out of receiving such communications.

When you visit our website (i.e., www.GoTrow.com), we may, in accordance with industry practice, place small amounts of data ("Cookies") in your browser. This information may be stored on your computer or other device used to access our website. We use cookies to enhance your experience using our website. This information is used to identify users, remember user preferences, and enable users to complete tasks without having to re-enter information when browsing from one page to another or revisiting our website at a later date. We also use Cookies to collect and analyze website usage data related to user usage and patterns. This data is used to improve our website and enhance the user experience. We may also use the information we collect to ensure compliance with our regulatory and anti-money laundering ("AML") requirements and to ensure that your account security is not compromised by detecting unusual, suspicious or potentially fraudulent account activity.

Through Settings, you can set your browser to block or alert you to these Cookies, but this may affect the functionality of the service or your user experience. Session Cookies are added when the user begins browsing our website or interacting with a particular feature and are removed when the browser is closed. Persistent Cookies are added when a user begins browsing our website or interacting with a particular feature, but may remain on your device until a certain end date is reached.

We have taken appropriate information security measures to prevent accidental loss, unauthorized access, alteration, disclosure, use or destruction of your personal data (or other similar risks). We take various measures to ensure information security, including encrypting communications on the GoTrow Platform; requiring two-factor authentication for all sessions; regularly reviewing our personal data collection, storage and processing practices; and restricting access to your data to our employees and suppliers in accordance with the necessary principles, and our employees and suppliers are subject to strict contractual confidentiality obligations.

If you have any questions about information security or report any security issues, please contact us by sending an email to the relevant email address with the subject line "Information Security Request".

If you have any questions about this Privacy Policy or the use of your personal data, please contact us by sending an email to the relevant email address with the subject line "Privacy Request".

When processing your request to exercise your right to privacy, we check the identity of the requesting party to ensure that he or she is legally entitled to make such a request. While we endeavor to respond to these requests free of charge, we reserve the right to charge you a reasonable fee (if applicable) to comply with your request if your request is repetitive or overly burdensome. In order to exercise your privacy rights, please send an email containing your request to the relevant email address with the subject line "Data Query Request".

We may update this Privacy Policy from time to time and post the revised version on the GoTrow Platform, and indicate the effective date of the revised version; please check this Privacy Policy frequently for updates and changes. Your continued access to or use of the GoTrow Platform and/or Services constitutes your confirmation and acceptance of such changes to this Privacy Policy.