We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the 21st.capital website (“Website”), and any of related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and 21st Capital, (“21st Capital”, “we”, “us” or “our”). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Policy, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this Policy, you must not accept this Policy and may not access and use the Services. By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. 

When you open the Website, our servers automatically record information that your browser or device sends. This data may include information such as your device’s IP address and location, browser and device name and version, operating system type and version, language preferences, the webpage you were visiting before you came to the Services, pages of the Services that you visit, the time spent on those pages, the information you search for on the Services, access times and dates, and other statistics.

• Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system. 

You can access and use the Services without revealing who you are or revealing any information by which someone could identify you as a specific, identifiable individual. However, if you wish to use some of the features on the Services, you may be asked to provide certain Personal Information (for example, your name and e-mail address).

We receive and store any information you knowingly provide to us when you create an account, make a purchase, or fill any forms on the Services. When required, this information may include the following:

• Account details (such as user name, unique user ID, password, etc)
• Contact information (such as email address, phone number, etc)
• Basic personal information (such as name, country of residence, etc)
• Payment information (such as credit card details, bank details, etc)
• Geolocation data of your device (such as latitude and longitude)
• Any other materials you willingly submit to us (such as articles, images, feedback, etc)

Some of the information we collect is directly from you via the Services. However, we may also collect Personal Information about you from other sources such as social media platforms, public databases, joint marketing partners, third-party data providers, and other sources. Information we collect from other sources may include demographic data (age, gender), device information (IP addresses), location (city, state), and online behavioral data (social media usage, page view information, search results, links).

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Services. Users who are uncertain about what information is mandatory are welcome to contact us.

We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.

We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you submit Personal Information through the Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.

We may use the information we collect from you to:

• Create and manage user accounts
• Fulfill and manage orders
• Deliver products or services
• Improve products and services
• Send administrative information
• Send marketing and promotional communications
• Send product and service updates
• Respond to inquiries and offer support
• Request user feedback
• Improve user experience
• Post customer testimonials
• Deliver targeted advertising
• Administer prize draws and competitions
• Enforce terms and conditions and policies
• Protect from abuse and malicious users
• Respond to legal requests and prevent harm
• Run and operate the Services

Processing your Personal Information depends on how you interact with the Services, where you are located in the world and if one of the following applies: (a) you have given your consent for one or more specific purposes; (b) provision of information is necessary for the performance of this Policy with you and/or for any pre-contractual obligations thereof; (c) processing is necessary for compliance with a legal obligation to which you are subject; (d) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (e) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Services.

We may process your Personal Information for the following purposes:

• User's consent
• Performance of a contract
• Employment or social security obligations
• Compliance with the law and legal obligations
• Legal claims and proceedings
• Personal Information is already publicly available

Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors ("Payment Processors") to assist us in processing your payment information securely.

Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors' use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

You can delete certain Personal Information we have about you. The Personal Information you can delete may change as the Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Services or by contacting us.

Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with our trusted subsidiaries and affiliated companies, joint venture partners, contracted companies, and service providers we rely upon to assist in the operation of the Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information (collectively, "Service Providers").

We will not share any information with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.

We will share and disclose your information only with the following categories of Service Providers:

• Affiliate programs
• Communication and collaboration services
• Data analytics services
• Data storage services
• Financial services
• Government agencies
• Order fulfillment services
• Payment processors
• Performance monitoring services
• User authentication services
• Website hosting service providers

We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and Personal Information will likely be among the assets transferred.

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including USA. The transfer of your Personal Information to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest.

You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section. Note that we are dedicated to ensuring the security of your personal data, adhering strictly to the guidelines outlined in our privacy notice and conforming to the applicable legal requirements.

Out of respect for your privacy, we have implemented additional measures to comply with the obligations and rights associated with the collection of Personal Information as dictated by the laws governing the regions of our users.

If you are a resident of the European Union ("EU") or the European Economic Area ("EEA"), you have certain rights in relation to your Personal Information based on the GDPR that we comply with as part of our commitment to your privacy. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the GDPR.

If you are a resident of California or other states with similar laws, you have certain rights regarding your Personal Information. These rights are provided under various state laws, including:

• California Consumer Privacy Act and California Privacy Rights Act (CCPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CDPA)
• Delaware Online Privacy and Protection Act (DOPPA)
• Iowa Consumer Data Protection Act (ICDPA)
• Maryland Personal Information Protection Act (PIPA)
• Utah Consumer Privacy Act (UCPA)
• Virginia Consumer Data Protection Act (VCDPA)

All terms in this section have the same meaning as defined in related state laws.

If you provide Personal Information to obtain Services for personal, family, or household use, you have the right to submit requests related to your Personal Information once a calendar year. There may be circumstances where we cannot comply with your request (e.g., inability to verify identity, conflict with legal obligations). You will be notified if this occurs.

You can exercise your rights by contacting us using the contact details provided in this Policy.

Verification Process: We may require identity verification. Requests must provide sufficient information to verify your identity or that you are an authorized representative. For authorized representatives, evidence of power of attorney or valid written authority may be requested.

Details Required: Sufficient details must be included to understand and respond to your request. Personal Information will not be provided unless identity/authority is verified and the information relates to you.

Our Services use "cookies" to help personalize your online experience. A cookie is a text file placed on your hard disk by a web page server.

Cookies cannot run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

We may use cookies to collect, store, and track information for security and personalization purposes and to operate the Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Services.

We use a consent tool called "Real Cookie Banner" to manage cookies and similar technologies (tracking pixels, web beacons, etc.) and related consents. Details on how it works can be found at https://devowl.io/rcb/data-processing/.

The legal basis for processing personal data in this context is Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. The legitimate interest is the management of cookies and related consents.

Providing personal data is neither contractually required nor necessary for contract conclusion. You are not obliged to provide personal data; if not provided, consents cannot be managed.

We may use third-party analytics tools, including cookies and web beacons, to collect standard internet activity and usage information. This data is used to compile statistical reports on user activity, such as how often users visit the Services, what pages they visit when they do so, and what other sites they used prior to coming to the Services.

We use this information to monitor performance and improve the Services.

We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Services.

If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Services, please contact us, and we will endeavor to delete that information from our databases.

We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission.

You have the right to choose not to have your Personal Information sold or disclosed by contacting us. Once we receive and verify your request, we will stop selling or disclosing your Personal Information. Please note that opting out of data transfers to third parties may affect our ability to provide certain Services.

We reserve the right to reject opt-out requests in situations permitted by the CCPA, such as when the sale of Personal Information is necessary for us or a service provider to perform a business purpose or comply with legal obligations.

Some browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. How browsers communicate the "Do Not Track" signal is not yet uniform. For this reason, and like many websites, our Services are not currently set up to interpret or respond to browser-initiated "Do Not Track" signals.

Note, however, that we limit our use and collection of Personal Information as described in this Policy. For more information about Do Not Track protocols, you can visit internetcookies.com.

We may permit certain third-party companies to serve advertisements and/or collect certain anonymous information when you visit our Services. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Services and other websites in order to provide advertisements about goods and services likely to be of greater interest to you.

These companies typically use a cookie or other tracking mechanism to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit Digital Advertising Alliance and Network Advertising Initiative.

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

We offer push notifications to which you may also voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we use a third-party push notifications provider who relies on a device token unique to your device which is issued by the operating system of your device.

While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us or our third-party push notifications provider. We will maintain the information sent via e-mail in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.

We may engage in affiliate marketing and have affiliate links present on the Services for the purpose of being able to offer you related or additional products and services. If you click on an affiliate link, a cookie will be placed on your browser to track any sales for purposes of commissions.

The Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Services and to read the privacy statements of each and every resource that may collect Personal Information.

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

In the event we become aware that the security of the Services has been compromised or users' Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

We reserve the right to modify this Policy or its terms relating to the Services at any time, effective upon posting of an updated version of this Policy on the Services. When we do, we will revise the updated date at the bottom of this page. Continued use of the Services after any such changes shall constitute your consent to such changes.

However, we will not use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected without your consent.

Policy was created with WebsitePolicies.

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Services and submitting your information, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Services.

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form or send an email to contact@21stcapital.com.

If you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact us using the details provided: contact@21stcapital.com.

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

This document was last updated on September 10th 2024.