Introduction

Passiv Inc (the “Company,” “we,” or “us”) provides financial infrastructure to deliver read, write and transfer capabilities (“Services”) to Partner Applications (“Partners”) and their End Users.

Whether you interact with us as a representative of a Partner or as a website visitor, we want you to be familiar with how we collect, use and disclose (collectively also referred to as “process”) information, including information that identifies you as an individual or relates to an identifiable individual. We call this “Personal Information”. 

Partners

If you are a representative of our Partners, we will process your Personal Information such as:

• Name;
• Contact details;
• Name of employer;
• Job title and function;

We process this Personal Information to enter into and manage our contractual relationship with our Partners and for other legitimate business purposes. This includes:

• The provision of our Services;
• Arranging access to your developer account and API keys;
• Providing customer service and responding to other inquiries and requests;
• Communicating with you about our Services and our contract with you;
• Completing transactions, verifying your information, sending you invoices and processing payments from you.

You can request to view your information or update it by sending an email to support@snaptrade.com

If you disclose any Personal Information relating to other people to us, such as your teammates or colleagues, you represent that you have the authority to do so and to permit us to use the information.

‍Website Visitor

If you visit our website at www.snaptrade.com, we will process information such as log information, IP address, approximate location, and other information collected through our use of cookies or other similar technologies.

We process this information for the following purposes:

• Analyzing Personal Information for business reporting and providing personalized services.
  
  - To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our Service is used, so we can improve our Services and website.
  
  - To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

For more information about our use of cookies or similar technologies, please see the cookie section of this policy.

‍Newsletters, Marketing and Third Party Advertising

We may process your Personal Information, including marketing data (e.g., your preferences for receiving our marketing communications and details about your engagement with them), for promotional purposes. This includes the following:

• Providing you with our newsletter and/or other marketing materials.
  
  - To send you marketing related emails, with information about our Services, new products and other news about our Company.
  
  - To facilitate social sharing functionality that you choose to use.
• Analyzing Personal Information for business reporting and providing personalized services.
  
  -to analyze, predict  and/or create usage trends and report on how our API is used, so we can improve our Services.

We may disclose your Personal Information:

• To retail brokerages and other institutions who may choose to have direct business relationships and/or contact with you.

We give you choices regarding our use and disclosure of your Personal Information for promotional purposes. You may opt out from receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the “Unsubscribe” link.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Other Purposes for Processing Personal Information

We may also process Personal Information for the general purposes below. Where we do so, we will make attempts to process only de-identified or pseudonymized Personal Information, where possible.  

• Aggregating and/or anonymizing Personal Information.
  - We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. 
• Accomplishing our business purposes.
  - For data analysis, for example, to improve the efficiency of our Services and website;
  - For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  - For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  - For developing new products and services;
  - For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  - For identifying usage trends, for example, understanding which parts of our Services are of most interest to Partners;
  - For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our Partners; and
  - For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our Partners so we can focus our energies on meeting their interests.  
• To comply with applicable law and regulations.
  - This may include laws outside your country of residence. 
• To cooperate with public and government authorities.
  - To respond to a request or to provide information we believe is necessary or appropriate.
  - These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  - For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
  - To enforce our terms and conditions; and
  - To protect our rights, privacy, safety or property, and/or that of our business partners, you or others. 
• In connection with a sale or business transaction.
  - We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

Disclosure of Personal Information 

We disclose Personal Information to our third party service providers, to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.

Cookies and Similar Technologies

The cookies and/or other similar technologies on our website may also collect information. These include information collected through:  

• Your browser or device. 
  - Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version.  We use this information to ensure that the website functions properly.  
• Cookies. 
  - Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the website, pages visited, language preferences, and other traffic data.  We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the website in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the website.  
• Pixel tags and other similar technologies. 
  - Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of our services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of our services and response rates. 
  - Analytics. We use analytics providers, including Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the website and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. 

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  

The criteria used to determine our retention periods include:  

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); 
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or 
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).  

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the website does not imply endorsement of the linked site or service by us. 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Partners, Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.

Use of Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18. 

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services or otherwise interacting with us you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

Third Party Payment Service

The Company uses third-party payment services. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

End-User

This Privacy Policy does not apply to our processing of Personal Information of end-users of our Partners’ products or services (“End-User”). If you are an End-User, we will only process your Personal Information on behalf of our Partner where required to provide our Services (e.g., to facilitate a transaction). The Partner is responsible for the processing of your Personal Information and we act as a service provider in this context. This means that we will only process your Personal Information based on our Partner’s instructions. 

Please consult the relevant Partner’s privacy policy for information about how they process your Personal Information. If you have questions or want to exercise rights in relation to your Personal Information, please contact the relevant Partner.

Updates to this Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the website. 

Contacting Us

If you have any questions about this Privacy Policy, please contact us at support@snaptrade.com.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.