Privacy Policy

Effective Date: June 14, 2024

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We respect your privacy. We are committed to safeguarding the privacy of our website visitors. https://alfatrade.us website administration (hereinafter– «Website») is obliged to maintain your privacy on the Internet. Please read this document carefully as it sets out our «Privacy Policy» which informs you what we do with your Personal Data, whether we are providing you with news alerts or using your Personal Data as part of the research that we conduct for or statistical purposes. We pay great attention to securing the Data you provided to us. The purposes, for which we collect your Personal Data are: improvement of our service, communication with visitors to this site, newsletters, presenting the information requested by the user, and for other actions listed below.

This Privacy Policy applies to the Personal Data of visitors anywhere in the world who access or use this Website.

By accessing or using our Website, you signify that you have read, understood, and agree to our collection, storage, use and disclosure of your personal information, as applicable, as described in this Privacy Policy.

The company responsible for your Personal Data is: ALFATRADE DISTRIBUTION LLC, 20725 NE 16th Ave a44 Miami, FL33179, USA (hereinafter – «us», «the Company»).

Personal Data storage and processing

We collect and process your Personal Data only with your willing consent. Depending on the relevant circumstances and the laws and obligations that apply in your location, we may collect some or all of the information below:

• Name and surname;

• Contact details (such as your e-mail address or mobile number);

• Country of residence;

• Category to which you belong (consumer, supplier / company, or other);

• Date of birth;

• Additional information that you provide us voluntarily;

• Technical Data (e.g. the IP address, device information, log information, location information).

• We may also collect any communications between you and the Company and any other information you provide to us. We use this information to operate, maintain, and provide to you the features and functionality of the Website, as well as to communicate directly with you, such as to send you email messages. We may also send you service-related emails or messages (e.g., account verification, change or updates to features of the Website, technical and security notices).

Access to ourWebsite is limited to age verified users.

How do we collect your Personal Data?

We collect your Personal Data largely in three ways:

1) Personal Data that you provide us with. You can share your Personal Data with us in multiple ways, such as:

• By proactively contacting us, usually by phone, email, through our contact form or through social media; and / or

• Because we contact you, either by phone or by e-mail.

• By collecting information through the intervention of the (your) our representative.

We usually receive Personal Data such as your contact details, your name, the country of residence, your date of birth, etc.

2) Personal Data that we obtain from other sources. We may use other sources to obtain additional information about you, e.g. from third parties. An example of this is the information we via the Google Analytics tool. For example, Google Analytics Opt-out Browser Add-on can be found here. Usually, we so receive Personal Data such as information via a unique identifier (e.g.information about your activity on the Website).

3) Personal Data that we collect automatically. When you visit our Website, we collect technical Data by means of cookies such as the IP address your computer uses to connect to the internet, the type and version of your browser, your time zone setting, types and version of browser plugins, operating system and platform, including the type of mobile device you use, a unique device identifier, traffic Data, we blogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website.

Why do we collect your Personal Data?

We collect, use and disclose your Personal Data for a number of reasons, including:

• to ensure that we can respond to any queries and contact you if you request us to do so;

• for storing your details (and updating them when necessary) on our database, so that we can contact you in relation to email news alerts or respond to any query you have asked us to answer;

• as part of the research that we conduct for statistical purposes;

• to administer our Website for internal operations, including troubleshooting, Data analysis, testing, research, statistical and survey purposes;

• to ensure the effective operation of software and IT services procured by us (including disaster recovery);

• for other reasons with your consent.

The Company's Sharing of Personal Data

We will share your Personal Data primarily to ensure we provide you with the most relevant and up to date news, content and events, or to ensure we can respond to any query quickly and expeditiously. The Company may share Personal Data with affiliated companies, service providers who act on our behalf, or others at your direction.

• Service Providers. The Company may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing Data, including Personal Data, in connection with your use of our services and delivering products to customers (including external consultants, investor relations service providers and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems). The Company service providers are obligated to handle Personal Data consistent with this Privacy Policy and according to our instructions.

• Tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this Data (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of the Company or its subsidiaries; or protect the personal safety of the Company employees, third party agents or members of the public.

• If the Company entity merges with or is acquired by another business or company in the future, we may share your Personal Data with the new owners of the business or company (and provide you with notice of this disclosure); and

• Circumstances may arise where, whether for strategic or other business reasons, the Company decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your Personal Data to prospective or actual purchasers, or the receipt of it from sellers. It is the Company’s practice to seek appropriate protection for personal information in these types of transactions

We do not share, rent or trade your information with third parties for marketing or promotional purposes.

• Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to exercise, investigate, or protect the rights, property, or personal safety of the Company, our visitors, or others. Please note: The products placed on our Website are highly regulated by various governing agencies. It may become necessary to share the information that we collect with such agencies to comply with laws, a judicial proceeding, court order, or other legal requests.

• We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Data storage, alteration, and removal

The user, who has provided to the Company with their Personal Data, has the right for their alteration and removal, as well as the right to recall the agreement to Data processing. Time, during which your Personal Data will be stored is: time the Personal Data is used that is necessary for the Website’s main activity. We will not keep your Personal Data for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation). After finishing with the processing of your Personal Data, the Website’s administration will permanently delete it. To access your Personal Data, you can contact the administration on: info@alfatrade.us. We will be able to pass your Data to a third party only with your willing consent. If the Data was transferred to a third party, which is not associated with our organization, we cannot perform any changes to that Data.

Processing of visiting technical Data

We and our third-party partners, automatically collect certain types of usage information when you visit our Website, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technologies. For example, we may collect information such as IP address, time of visit, browser settings, operational system, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting), traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website.

We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Website and to understand more about the demographics of our users. You may set your browser to not accept cookies; however, some features of the Website may not function properly without the use of cookies.

This Data is necessary for the correct display of the Website’s content and help us to better understand user behaviour. It is impossible to identify the person ofthe visitor using this Data.

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Children’s personal information

If you are a parent or a legal guardian of an underage child, and you know that the child has provided us with their Personal Data, please contact us on: info@alfatrade.us. It is forbidden to enter Personal Data of underage users.

Marketing

We may collect your preferences to receive marketing information directly from us by email or SMS in the following ways:

• if you register for an account on the Website, we will ask you if you would like to opt in to receive marketing information directly from us;

• if you click on the link on our Website to sign up to our newsletter.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

You have the right to opt-out of our use of your Personal Data to provide marketing to you in any of the ways mentioned above at any time. Please see Your rights below for further details on how you can do this.

Cookies processing

We use cookie files for the correct display of the Website’s content and for the convenience of browsing Website. They are small files, that are stored on your device. They help the Website to remember information about you, such as in which language you use the Website and which pages have you already opened. This information will be useful in the next visit. Thanks to cookie files, the Website’s browsing becomes much more convenient. You can set up cookies reception and blocking in your browser yourself. Inability to receive cookie files may limit the functionality of the Website.

Alternatively, you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone, you will need to refer to your handset manual or network operator for advice.

What are the different types of cookies?

• Strictly Necessary.

These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. They allow you to navigate back and forth between pages without losing your previous actions from the same session. Since these cookies are necessary for the functionality of our Website, we do not need to ask for your consent to use them.

• Functional.

These cookies allow a Website to remember your site preferences and choices you make on the site including username, region, and language. This allows the Website to provide personalized features like local news stories and weather if you share your location and boost your overall user experience on our Website. The Data collected via these cookies is anonymous and these cookies do not track browsing activity across other websites. Similarly, to strictly necessary cookies, we do not need to ask for your consent to use these cookies.

• Performance.

Performance cookies are cookies used specifically for gathering Data on how visitors use our Website, which pages of our Website are visited most often and whether the users get error messages on web pages. These cookies monitor only the performance of the Website as the user interacts with it. These cookies do not collect identifiable information on visitors, which means all the Data collected is anonymous and only used to improve the functionality of our Website. We also use these cookies to gather statistical Data on how our Website is performing in order to make improvements. Despite the anonymity of the Data collected we will seek your consent to the use of these cookies. .

• Persistent cookies.

These cookies remain on your device when you close your Internet browser, and they are reactivated each time you visit the Website that originally generated this type of cookie.

• Session cookies.

These cookies are not permanently stored on your device. They are used to enhance your browsing experience on a Website, for example by enabling you to switch between websites without needing to log back in. Closing your Internet browser deletes all session cookies from your computer.

• Flash cookies.

These cookies are installed by websites that feature multimedia content; this requires Adobe Flash to be displayed. These speeds up the rate at which you can download content and save information.

Most browsers accept and maintain Cookies by default. Check the «Help» or «Setting» menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website, but this may limit your ability to access certain areas of the Website.

Cookies List

Links to other websites

Our Website may contain links to other websites, which are not under our control. We are not responsible for the content of these websites. We recommend you familiarize yourself with the privacy policy of every website that you visit, if such policy exists.

If you decide to access the linked third-party websites, you do so at your own risk. We do not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the contents of another website to which you may link from the Website

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Your California Privacy Rights

A. California Privacy Rights Act («CPRA»)

Verified California residents have the following rights:

1. Access rights (Requests may be made up to twice in a 12-month period)

• To request and receive disclosure of our Personal Data collection practices during the prior 12 months (or at their option since January 1,2023), including the categories of Personal Data we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;

• To request and receive a copy of the Personal Data we have collected about you during the prior 12 months (or at their option since January 1, 2023);

• To request and receive disclosure of our information disclosure practices during the prior 12 months (or at their option since January 1, 2023).

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2. Correction rights

• To request that we correct inaccurate information that we hold about you. We will require that you provide information about yourself so that we can verify your identity before we can make any changes to the information we hold about you and we will use commercially reasonable efforts to make the requested corrections.

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3. Deletion rights

• To request that we delete (and direct our service providers to delete) your Personal Data subject to certain exceptions; and

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4. Opt-out rights

• To request that we not sell Personal Data about you;

• To request that we limit processing of Sensitive Personal Data to only those purposes for which it was originally collected – We only process Sensitive Personal Data for the purposes for which we originally collected it.

For purposes of the CPRA Personal Data means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

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B. Exercising your CPRA rights and our responses

For customers, in order to make a request for Access, Deletion or Correction, California residents may contact us by email: info@alfatrade.us. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected Personal Data) by matching information you provide to information in our records and will use that information only for that purpose. If you request specific information collected about you or deletion of information, we may ask you to sign a declaration under penalty of perjury attesting to your identify. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity and confirm that the Personal Data relates to you.

We will endeavour to respond within 45 days of receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests for a copy of the Personal Data we have collected during the 12 months prior to your request or as extended at your request, we will endeavour to provide the information in a format that is readily useable.

C. Information collected, sources and business purpose for collection

We collect the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The categories of information include information we collect from our Website visitors, employees, vendors, suppliers and any other person that interacts with us either online or offline.

Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.

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*More specifically, the business purposes include but are not limited to:

(1) Auditing relating to transactions, internal research and development:

• To provide for internal business administration and operations, including troubleshooting, Website customization, enhancement or development, testing, research, administration and operation of our Website and data analytics;

• To measure performance of marketing initiatives.

(2) Security detection, protection and enforcement; functionality debugging, error repair:

• As part of our efforts to keep our Website safe and secure;

• To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Website, for example, by requesting verification information in order to reset your account password (if applicable);

• To resolve disputes, to protect the rights, safety and interests of ourselves, our users or others, and to comply with our legal obligations.

(3) Quality control:

• To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures.

I. Disclosing Personal Data

From time to time, we disclose your information as described below. This includes disclosing information to our service providers and, when required by law, to regulators or law enforcement.

II. Disclosure of Personal Data for a business purpose

We may disclose your Personal Data to service providers and others for a business purpose. The business purposes are listed above. When we disclose Personal Data for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we may have disclosed the following categories of Personal Data to service providers (such as marketing partners, shipping partners); affiliated companies; government regulators; law enforcement; or strategically aligned businesses:

• Category A: Identifiers.

• Category B: Protected Personal Data.

• Category C: Protected anti-discrimination classification information.

• Category D: Commercial Information

• Category E: Electronic network activity information

• Category F: Geolocation

• Category G: Inferences

III. Information retention

We will store Personal Data in a form which permits us to identify consumers, for as long as necessary for the purpose for which the Personal Data is processed. We may retain and use such Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CPRA for a period of two years.

Colorado, Connecticut, Virginia, and Utah

Notice to residents of Colorado, Connecticut, Virginia, and Utah: We are not currently subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws, we will update our privacy policy disclosures accordingly.

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Transfer of Personal Data

Your information collected through our Website may be stored and processed in the United States or any other country in which the Company or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which the Company or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Privacy Policy, we will endeavour to provide you notice through the Website or by some other means, such as email. Your continued use of the Website after such notice constitutes your understanding of the changes. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

If your Personal Data, and more specifically, your contact information was entered incorrectly, we will not be able to contact you.

Security Precautions

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your PersonalData.

We are committed to taking all reasonable and appropriate steps to protect the Personal Data that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted over the internet and we do not warrant the security of any information, including Personal Data, which you transmit to us over the internet.

If you suspect any misuse or loss of or unauthorised access to your Personal Data please let us know immediately. Please raise your concern by contacting us using the Contact us section of the Website, in the first instance, and we will investigate the matter and update you as soon as possible on next steps.

Privacy of the underage

Our Website are not intended for individuals under the age of 21. We do not knowingly collect or solicit any information from anyone under the age of 21 on these Website. In the event that we learn that we have inadvertently collected Personal Data from an individual under age 21, we will delete that information as quickly as possible. If you believe that we might have any information from an individual under 21, please contact us at info@alfatrade.us. Protecting the privacy of the underage is very important to us. Thus, if we obtain actual knowledge that a user is under 21, we will take steps to remove that user’s Personal Data from our databases.

Your rights

Modifying or deleting your Personal Data. If you have any questions about reviewing, modifying, correcting, or deleting your Personal Data, you can contact us directly at info@alfatrade.us. We may not be able to modify or delete your information in all circumstances.

How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of product or service-related communications (e.g., account verification, transactional communications, changes/updates to features of the service, technical and security notices).

Feedback and final clauses

You can contact the Website administration regarding any questions related to Privacy Policy on: info@alfatrade.us, or by filling a contact form specified in a corresponding section of this Website. If you do not agree with this Privacy Policy, you cannot use the Website. In this case you should avoid visiting our Website.