September 2024

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Pando RWA Inc. Privacy Notice

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 Introduction 

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This Privacy Policy describes how Pando, for itself or on behalf of any of its service partners collectively known as (“Pando”, “We”, or “Us”), collects and uses the personal information you provide or that is generated on our websites or mobile applications (the “Site”) or in connection with our services (the “Services”). It also describes options that may be available to you regarding the use of, your access to, and updating or correcting your personal information. Note that this Privacy Policy does not apply to any third-party websites or services, including those you reach through links we have provided on the Site. We encourage you to request and review the privacy policies of any third party prior to disclosing information to such a party.

 

In connection with the Site, Pando may collect and process personal information that you provide to us or one of our affiliated partners that pertains to your use of the Site (“Site User Information”). Pando, whose principal office location is 2952 Technology Blvd Suite 202, Bozeman MT 59718 USA is the “Data Controller” of “Site User Information” for purposes of European or other applicable law. Separate from the “Site User Information”, Pando collects and otherwise processes personal information in the course of providing services to users (“Service User Information”), but such processing is performed under the direction of its users.

 

In the normal course of the Services, we transfer “Site User Information” and “Service User Information” to individuals as directed by users of the Service, and to third parties that help or are necessary for us to provide our service. Transfers to such third parties are further addressed in the service agreements with our clients.

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The type of Personal Information we collect and use

 

Site User Information:

In connection with the operation of the site or providing services, we may collect and use the following Site User Information about you:

 

Information You Provide
 

We may ask you to provide us with certain Personally Identifiable Information (PII) and Non-Public Personal Information (NPPI) by using our site or by corresponding with us by phone or e-mail concerning the Site or by using interactive features that we may include on the Site for the purpose of receiving and responding to your comments, inquiries, or expressions of interest in our products and services, or providing services.
 

Personally Identifiable Information (PII) and Non-Public Personal Information (NPPI) includes, but is not limited to: 

 

Full Name, Facial Biometrics, Date of Birth, Social Security Number, Tax ID, Nationality, Passport, National Identity Card, Driver License, Gender, Marital Status, Signature, Name of Employer, Address of Employer, Business Nature of Employer, Occupation, Residential Address, Residential Phone Number, Personal Mobile Phone Number, Personal E-mail Address, Business Address, Business Mobile Phone Number, Business Phone Number, Business E-mail Address, Legal Representative / Authorized Signatory, Business Scope, Financial Situation, Certificate of Incorporation, Certificate of Incumbency, Memorandum and Articles of Incorporation, Bank Account Information, Source of Fund, Source of Wealth, Annual Income, Private Investment Holdings.

 

Information About Your Use of the Site (Site Usage Information)
 

Like most websites, we use cookies and similar technology, and we maintain log files to record usage information about the Site. We use this information for purposes of security and improving our Site, and where appropriate or required, with your consent. Additional information about our use of cookies and similar technology appears below. Note that we may also, from time to time, collect and use personal information (as Site User Information) in other ways – such as for surveys or promotional offers – as to which we provide specific notice at the time of collection.
 

Service website utilization information includes but not limited to: 

 

Internet Protocol address (e.g., IP Address), Browser Type, Browser Version, Website Pages Visited, Date of Visit, Time Spent on Pages, Utilization of Various Functionalities, Unique Device Identifiers, Other Diagnostic Data.
 

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Service User Information:

 

Where you use our Services, we may process, either directly or through one of our third-party partners, the following Service User Information on behalf of you:

1. Transaction History

2. Anticipated Transaction Volume

3. Positions

4. Account Statements

5. Information received as part of the AML Screening process:

• Criminal Background

• Politically Exposed Person (PEP) Status

• Global Sanctions (OFAC, UN, HMT, EU, and DFAT)

• Adverse Media

• Watchlist (Interpol, Federal and State Government Agencies)

 

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Cookies and Similar Technologies

 

When you visit our Site, we and our third-party partners, including analytics providers, collect information by automated means, such as the use of cookies, web beacons, and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Site and emails. We may process this information to determine how many users have visited particular web pages, viewed particular videos, or opened messages or alerts, and we may also use such information to improve the performance of the Site and to prevent fraud. In some cases, our third-party partners may process information collected by such cookies. 

 

As indicated above, we, like many other website operators, may use select service providers (“Site Service Providers") to collect and process certain Site usage data through our own direct agreement or indirectly through an affiliated service partner.  

 

Google may assert the right to collect and combine information collected on the Site using its Google Analytics cookie with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps use or share data with the same partners. You may be able to change a web browser’s settings to block and delete cookies when you access the Site through that web browser. However, if you do that, the Site may not work properly; also, we will still receive basic information (such as the last URL visited) when you navigate to the Site.

 

We do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Site with other people or unaffiliated companies for their direct marketing purposes.

 

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Cookies we use

 

We use the following cookies on this Site through direct agreement or through affiliated service partners:

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Google

Report on the usage analytics of this Site.

https://policies.google.com/technologies/partner-sites

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Segment

Track visitor usage, and events, target marketing, and to measure application performance and stability.

https://www.twilio.com/legal/privacy

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Fullstory

To get full visibility into how users interact with our website, with actionable insights to enrich our tech-stack, boost customer satisfaction, and accelerate innovation.

https://www.fullstory.com/legal/privacy-policy

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PropelAuth

To aide in user login and permissions

https://www.propelauth.com/privacy

 

Use of your Personal Information

 

Under select laws, if and where applicable, the legal basis for the processing of your personal information is:

1. To provide and maintain our Services, including the monitoring of the usage of our Services.

2. To manage your Account: The Personal Data you provide can give you access to different functionalities of the Services that are available to you as a registered user.

3. To contact you: through emails, telephone calls, SMS, or other equivalent forms of electronic communication, we provide you with updates related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

4. To protect you: we rely on the use of Personal Data to protect our Services against cybersecurity issues such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.

5. To protect us: we are required to comply with all applicable legal and regulatory requirements relevant to our provision of Services.

6. To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

7. To manage your requests: we attend to and manage your requests to us on an ongoing basis.

8. We may use the information you provide to contact you regarding products, services, and company or business partner news that we believe may be of interest to you, and, if and where applicable, we do so based on our legitimate interests in marketing and subject to your right to contact us and opt-out of such marketing.

9. For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services and your experience.

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How we share your Personal Information

 

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We may share personal information with third parties who perform services for us or on our behalf, and we may share Site User Information and Service User Information with third-party distributors and other business partners to enable them to provide you with Pando Services. These third parties are not authorized by Pando to use or disclose your personal information except as necessary to perform services to or on behalf of Pando or comply with legal requirements, and they are subject to confidentiality and non-disclosure obligations in our agreements with them to protect your personal information.

 

Except where disclosure of your personal information is required by law or requested by you, we will generally require any third party which receives, or has access to, your personal information to protect it and to use it only to carry out the services they are performing for you or for us unless otherwise required or permitted by law.

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Where we store your Personal Information, how we may transfer your Personal Information

 

This Site is operated from, and Site User Information and Service User Information is stored in the United States of America (USA). We store Site User Information and Service User Information in our and our affiliated partners’ Google and AWS Cloud infrastructure located in the United States of America (USA).

 

Your information, including Personal Information, is processed at Pando’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of the jurisdiction where you are residing. Further, the data protection laws by which Pando complies may differ from those in your residing jurisdiction.

 

Your consent to this Privacy Policy followed by your submission of such Personal Data represents your agreement to that transfer.

 

We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of Personal Information.

 

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Retention of your Personal Information

 

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our regulatory and legal obligations (for example, if we are required to retain your personal information to comply with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing Regulations), resolve disputes, and enforce our legal agreements and policies.

 

We will also retain Site Usage Information for internal analysis purposes. Site Usage Information is generally retained for a shorter period of time, except when this information is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this information for longer time periods.

 

We maintain Site User Information and Service User Information for as long as needed for the business purposes for which such information is collected, and in keeping with our record retention policies. In general, the Personal Information relating to you is held for at least a period of five years as required by the regulators after we cease providing you with our Services.

 

How your Personal Information is protected

 

Pando maintains administrative, technical, and physical safeguards (including technical and organizational measures) designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.

 

We require that our service providers implement and maintain appropriate security practices and procedures. Nevertheless, please be aware that Internet transmissions are never completely private or secure. If you have any questions about the security of your personal information, you can contact us at info@pandoalts.com.

 

Access, accuracy, and correction of your Personal Information

 

Certain jurisdictions impose specific legal requirements and data subject rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete the personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. When you make a request, we may require that you provide information and follow procedures so that we can validate a request you make before responding to it. We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event. As permitted by applicable law, we may charge a reasonable fee to help cover the cost of responding to your request, and we will inform you of the fee before completing your request. Specific provisions for some jurisdictions are set forth below.

 

For California Residents

 

If you are a California resident, you may have certain rights in relation to our processing of Site User Information as to which we are a “business” under the California Consumer Privacy Act (“CCPA”). Note that we do not “sell” personal information as that term is defined by the CCPA. Under the CCPA, California residents have, with respect to Site User Information:

1. The right to request more information about our data collection and sales practices in connection with your personal information.

2. The right to request a copy of the specific personal information collected about you during the 12 months before your request (together with the above, a “personal information request”). You may only make a personal information request twice in a 12-month period, and we will respond within 45 days of receiving a personal information request.

3. The right to request that personal information be deleted (with exceptions).

4. The right to request that your personal information not be sold to third parties.

5. The right not to be discriminated against because you exercise any of these rights.

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Children's Privacy

 

This Site and all Services are intended for adults. Accordingly, we do not knowingly collect information from any person under the age of eighteen.

 

Contact Us

 

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices as it or they relate to the platform, please contact us at info@pandoalts.com. If you would like to request that we update or correct any information that you have provided to us or have a complaint about how your personal information has been used, please contact us in the first instance. If we cannot resolve your complaint to your satisfaction, you may complain to the competent authority who may investigate your complaint further.

 

Privacy Policy Updates

 

We may update this Privacy Policy from time to time and without prior notice at our sole and absolute discretion of us. We will notify you of any changes by email. You are advised to review the updated Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted. We encourage you to review this Privacy Policy periodically, especially if you don’t visit the Site regularly.

 

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "Last updated" date at the bottom of this Privacy Policy.

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Links to other Websites

 

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

 

Last updated: September 23, 2024