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), 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 Information (as defined below) you decide to share or provide through use of the Services (as defined below). 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.

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 (“Services”). “Personal information” refers to any information about an individual who can be identified from that data or from that data and other information to which we have access. For example, when you provide us with certain personal information, it may include your name, your identification number, your email address, 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 such as information regarding 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 (collectively, “Usage Information”).

How We Collect Information

Directly from You. We collect Personal Information from you when you voluntarily provide Personal Information to us by, for example, by completing various forms, or requests for information. By providing Personal Information to us, you consent to our collection and use of your Personal Information for the purposes of us providing the Services to you and for the purposes stated in this Privacy Policy.

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, 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

We process your Personal Information to carry out the purposes for which you provided your Personal Information to us and the purposes described below. By providing us with your Personal Information, you consent to our collection and use of your Personal Information for these purposes.

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 are not authorized to use it for other purposes.

At your request: If you request that we disclose or transfer your Personal Information to a third party organization in accordance with our procedures and any procedures that may be required by law, we will disclose or transfer your Personal Information at your request according to applicable law.

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 Personal 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 Personal 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 Personal Information as part of the transaction. If the surviving entity is not EFH, your Personal Information may be used pursuant to the surviving entity’s privacy policies which may be different from this Privacy Policy but for purposes for which you have consented to under this Privacy Policy.

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

We may also collect and use your Personal Information in situations and for purposes where we are required to do so by law or where the law permits us to do so without your consent.

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 Personal 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.

Retention of Personal Information

We only retain Personal Information for as long as the retention is required for the purposes for which we collected the Personal Information, the purposes described in this Policy and for our business and legal purposes.

How to contact us

If you have any questions or comments about this Policy and our policies and practices on our collection, use, disclosure or retention of Personal Information, you may contact our Data Protection Officer:

10 West Market Street, Suite 3050,

Indianapolis, IN 46204,

United States

privacy@equitiesfirst.com

+1 317 429 3500

If you:

(i) wish to update or correct your Personal Information;

(ii) wish to request for information on what Personal Information of yours we have and how we have used and shared your Personal Information during the last one year before the date of your request;

(iii) wish to withdraw your consent to our use, collection, sharing or processing of your Personal Information; or

(iv) have any concerns, feedback or complaints about the use and/or sharing of your Personal Information,

please contact our Data Protection Officer in writing at the above contact information.

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. 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 Personal Information from a child under the age of 13 without the consent of the child’s parent or legal guardian, we will delete the information as soon as reasonably practicable.

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

UK Privacy Policy