Privacy Policy

Effective Date: December 1, 2020

EFH Privacy Policy

Welcome to EquitiesFirst.com, operated by EQUITIES FIRST HOLDINGS (“EFH,” “we,” “us,” “our”). This Privacy Policy covers our website (EquitiesFirst.com) as well as any other affiliated sites, content, software products, mobile applications, mobile and web-based services, or any other EFH materials or services that refer to this policy (collectively, the “Site”). This Privacy Policy is intended to help you understand how we collect and use the personal and confidential information you decide to share or provide through use of the Services. This Privacy Policy sets forth our privacy practices and the possible uses of the information that we gather via the Site. This Privacy Policy applies to the Site, regardless of the medium in which it is accessed (e.g., mobile browser, computer browser, etc.).

The site and access to all content on the site are intended only for persons of the legal age based on your location where the site and its services are being accessed or viewed.

Consent to Privacy Policy

By using the Site, you fully understand and are agreeing to the practices described in this Privacy Policy and you expressly agree to provide all personal information to us through the Site, including by email, blog post, or social media, as well as to processing by automated or non-automated means, for the purposes indicated in this Privacy Policy and subject to the Terms of Use that apply to the Site.

If you do not agree to abide by this or any future privacy policy or terms of use, do not conclude or accept this agreement, and do not view, download, or otherwise use or access (or continue to use or access) the site or any services made available via the site.

Scope

This Privacy Policy applies to your use of the Site, regardless of the medium by which the Site is accessed by you.

The Information We Collect

When you visit the Site and use any of the services provided via the Site, we may collect information as disclosed below.

Personal Information: We collect personal information to provide the information or services requested by an individual. “Personal information” refers to any information relating to an identified or identifiable individual who is the subject of the information. For example, when you provide us with certain personal information, it may include your first and last name, your email address, your age, your date of birth, your gender, your PRC ID Card/passport number, your telephone number, your address, and any other personal or preference information that you provide to us.

Usage Information. When you use and navigate the Site, we may collect additional information from you that may not by itself reasonably identify you as the source (collectively, “Usage Information”). Usage Information may include but not limited to the information regarding your mobile telephone, your computer, your IP address, the type of Internet browser you are using, the location from which you are visiting the Site, or the areas of the Site you visited and the actions you performed on the Site.

How We Collect Information

Directly from You. We collect Personal Information from you when you agree to voluntarily provide Personal Information to us, for example, by completing various forms, or requests for information.

Through Your Use of the Site. We record Usage Information that your browser transmits when you visit our Site. We also collect Usage Information about how you access and interact with the Site through the use of automated tracking technology, such as “cookies” and “web beacons.” A cookie is a small data file that is transferred to a web browser, which enables our Site to remember and customize your subsequent visit. Most Internet browsers automatically accept cookies. You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept cookies from our Site. Please refer to your Internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Site may be limited, and you may not be able to participate in several of the Site’ features. Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Site that allow us to gather information about your browsing activities on the Site.

Other Technologies: When you use the Site, or when you contact us, you agree that we may also collect other information about you as disclosed below. This information may be gathered for all Site users.

    – We may collect certain information from your activity using other tracking technologies like tags, pixels, clear pixels, gifs, bugs, beacons, and other similar technologies, some of which may enable EFH or our service providers to identify you and collect information about you across devices and Site.

    – We may collect information about your interactions with our customer service, such as the date, time and reason for contacting us, feedback you share with us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.

How We Use Information

You confirm and agree that we process your Personal Information to carry out the purposes below and otherwise where we can rely on a legal ground for such processing. Provision of the Site: The Site is a medium for interaction between you and us. We use and share the information we collect from you for the purposes described below. If you use our Site, we use your information to process and respond to your applications, requests, comments, inquiries, and other forms you submit through the Site.

Improving our Site: We use your information to enhance our understanding of our users’ preferences and improve our Site accordingly

Service Providers: We may employ third party service providers to perform functions on our behalf. They may have access to personal information needed to perform their functions but may not use it for other purposes.

Legal Obligations: From time to time, we may be required to share personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or related to an alleged unlawful activity.

Protection of EFH and Others: We may release your information when we believe release is appropriate to comply with the law or any rule, regulation, government or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of EFH, our affiliated companies, our users, or others. However, this does not include selling, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the terms set forth in this Privacy Policy.

Sale or Acquisition: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if EFH is transferred to another company, we may disclose and/or transfer your information as part of the transaction. If the surviving entity is not EFH, your information may be used pursuant to the surviving entity’s privacy policies, which may be different from this Privacy Policy.

Other Legitimate Interests: We will use and disclose your information when necessary for our legitimate interests, as long as such interests are not overridden by our users’ interests, rights, and freedoms with respect to their Personal Information.

EFH is a global company and may collect and process information in countries throughout the world. Therefore, subject to applicable laws, you expressly agree that your personal information may be located and processed in a country where EFH does business, other than your country of residence or the country from which you provided EFH with your personal information. These other countries may not have the same data protection laws as the country in which you reside.

In addition, you expressly agree that we may transfer the personal information we collect about you through the Site to our affiliates, subsidiaries, and service providers in other countries, such as to the United States, for the purposes described above. When we transfer your personal information to another country, we do so in accordance with the applicable law.

Your Rights

You have certain rights regarding the personal information that we maintain about you, which in certain circumstances you will be able to exercise. These rights are as follows:

    • You may request to check and copy your personal information.

    • If your information is incorrect, you may request that we correct, amend, or delete information that is inaccurate.

    • You may request that we restrict the processing of your personal information.

    • You may object to the processing of your personal information in certain circumstances when we process your data for the purposes of our legitimate interests.

    • You may withdraw your consent regarding processing of your personal information.

    • You may at any time tell us not to send you marketing communications by email by clicking on the “unsubscribe” link within the marketing emails you receive from us or by contacting us as indicated below. We will apply your preferences going forward, subject to the applicable law.

In some circumstances, withdrawing your consent to our use or disclosure or processing of your personal information will mean that you will not be able to take advantage of certain EFH products and services.

Security

We take reasonable precautions to protect the information that is either available from or collected by this Site. We have taken steps designed to safeguard the Site’s integrity, its telecommunications, and computing infrastructure, including but not limited to, authentication, monitoring, auditing, and encryption. Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be completely secure. As a result, we cannot ensure or warrant that Personal Information will be completely secure from misappropriation by hackers, nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network.

Links

This Site may contain links to or information about other websites that are outside our control or custody. We are not responsible for the content or privacy practices of other websites and suggest you review their privacy statements to understand how your information is used or shared by those other websites. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within a page of our Site.

Modification

This Privacy Policy was last modified on the date first printed above.

We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in our business practices. If we revise the Privacy Policy, we will notify you by posting the updated Privacy Policy Statement on the Site. Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy on the Site. If we make material changes to this Privacy Policy that increase our rights to use the personal information we have previously collected about you, we will obtain your consent, where required by law, either through your registered email address or by prominent posting on this page. Your continued use of the Site after any change has become effective will constitute your acceptance of any change.

Other Provisions

Additional Terms. This Privacy Policy may be supplemented by other terms and conditions with respect to your personal information. For example, if you reside in a particular country, there may be policies specifically applicable to you (see below). This Privacy Policy will supplement any other privacy statements provided by EFH, or its subsidiaries, affiliates, and the like.

Your California Privacy Rights. California law provides that California residents have a right to request businesses to tell them how their personal information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the contact information listed below.

Do Not Track. Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Site does not respond to “Do Not Track” signals.

Children Under 13. We do not market to and do not knowingly collect any Personal Information from or about a child under the age of 13 without the consent of the child’s parent or legal guardian. If we discover that we have inadvertently collected information from a child under the age of 13, we will delete such information.

Comments and Questions

If you have a comment or question about the Privacy Policy, please contact us at the contact information listed below:

Equities First Holdings

10 West Market Street

Suite 3050

Indianapolis, IN 46204 E-mail: privacy@equitiesfirst.com

Privacy Policies Applicable to Specific Jurisdictions

Your jurisdiction may have specific requirements with respect to how EFH and its subsidiaries treat your personal information. For EFH’s full privacy policies in certain jurisdictions, please use the links below:

Hong Kong Privacy Policy

Singapore Privacy Policy

UK Privacy Policy

AU Privacy Policy