Privacy Policy

OTC EXCHANGE NETWORK, INC. PRIVACY POLICY

EFFECTIVE DATE: MAY 23, 2018.

OTC Exchange Network, Inc. and its affiliates (“OTCXN,” “us,” or “we”) are committed to protecting your personal privacy. The purpose of this Privacy Policy is to explain the type of information we collect on our website at www.otcxn.com (“Website”) and how we use that information. By visiting the Website and/or submitting information through our Website, you agree to the terms of this Privacy Policy. We may change this Privacy Policy from time to time, and, if required by law, we will notify you of material changes by posting a notification on the home page of our Website or sending you a notification by e-mail. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

What information is collected on our Website?

We may collect and store any personal information that you knowingly provide to us, as well as information that we automatically receive from your browser or device. Such personal information may include, for example, your name, home address, physical address, e-mail address, telephone number, IP address, wireless device address, other identifying information you provide to us through the comments or questions sections of our Website (“Personal Information”). In addition to collecting Personal Information, we may also collect Non-Personal Information. “Non-Personal Information” refers to information that may not itself be reasonably associated with, linked to, or used to identify you. For example, non-user specific aggregated data such as information about traffic patterns on the Web Sites. OTCXN does not knowingly collect Personal Information from children under the age of 13. No one under age 13 is authorized to provide any Personal Information or use our public discussion areas, forums and chat rooms.

How We Use Your Information

We may communicate with you if you’ve provided us the means to do so unless you inform us that you do not want to receive communications from us. We do not rent or sell your personal information to anyone. We may share the personally identifiable information you provide us with third parties, but only as necessary to provide this Website and our associated services. In addition, we may share information to third parties on a non-personal or aggregated basis such that any individual would not be able to be identified.

We use both Personal Information and Non-Personal Information for multiple purposes including, without limitation, to:
improve the content of the Website, to customize the content and/or layout of the Website for each individual user;
notify users about updates to the Website or promotional offers or opportunities that we believe will be of interest to you;
respond to your requests and to provide you with our product and service offerings;
communicate with you about, and administer your participation in promotions, surveys and market research;
send you newsletters, promotions and offers about new services, products or events, third-party products or services, including advertisements, by e-mail, text or another medium;
operate, evaluate and improve our business (including developing new products and services);
help diagnose problems with our Website, to administer our Website, and to enhance the Website for optimal user experience;
monitor the usage and performance of our Website and to determine Non-Personal Information about our users; and,
enhance, improve, and analyze our products and services.

Web Cookies

A “Web Cookie” is a string of information that a Website stores on a user’s computer, and that the user’s browser provides to the Website each time the user submits a query to the site. We use Web Cookies to track the pages that users visit during each Site session, both to help us improve users’ experiences and to help us understand how the Site is being used. As with other non-Personal Information gathered from users of the Site, we analyze and disclose in aggregated form information gathered using Web Cookies, so as to help us, our partners and others better understand how the Site is being used. We do not attempt to link information gathered using Web Cookies to Personal Information. USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE SITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE SITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.\

Web Beacons

A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows Website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Website and in emails to count users who have visited particular pages and viewed emails. Web Beacons are not used to access users’ Personal Information. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons; however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.

Service Providers and Third-Party Linked Websites

We may use third parties to help operate our Website and we may share your Personal Information with our affiliates, service providers and other third parties that provide products or services for or through our Website or for our business (such as web site or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, and other similar service providers that use such Personal Information on our behalf). Unless otherwise stated, these companies do not have any right to use the Personal Information we provide to them beyond what is necessary for them to assist us.

When you are on our Website you may have the opportunity to visit or link to other websites not operated by OTCXN, including other websites operated by service vendors or by unaffiliated third parties. These websites may collect Personal Information about you. OTCXN does not control websites that are operated by these entities and is not responsible for the information practices of these websites. The privacy policies of websites operated by third parties are located on those web sites.

Legally Compelled Disclosures

We have the right, at our sole discretion, to disclose Personal Information posted on our Platform and any other information you provide us, to third parties, including law enforcement personnel and in response to a subpoena or other lawful process potentially compelling disclosure of Personal Information without an obligation to provide prior notice to you. Such disclosure may be made, at our sole discretion, when we have reason to believe that someone has committed, or will commit, unlawful acts or acts that endanger the health or safety of another; is causing injury to, or interference with, our rights or property, other users of the Platform, or anyone else that could be harmed by such activities.

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you at our third-party service providers. We restrict access to Personal Information to those OTCXN employees, contractors, and agents who need to know such information in order to transmit, store, or process Personal Information, who are subject to contractual confidentiality obligations consistent with this Privacy Policy, and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with appropriate confidentiality and security measures.

Nevertheless, OTCXN cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your Personal Information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

California Residents

If you are a resident of California, California Civil Code Section 1798.83 may permit you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us by any method listed below in the “Contact Us” section. Additionally, if you are under the age of 18 you may be entitled to request and obtain removal of Personal Information that you post on our Website. If you would like to make such a request, you can contact us by any method listed below in the “Contact Us” section.

Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us at privacy@otcxn.com or send a written letter to:

OTC Exchange Network, Inc.
570 Pacific Avenue, Floor 2
San Francisco, CA 94133
ATTN: Privacy