Privacy Policy

1. What We Collect

We may collect the following categories of information:

A) Information you provide

• Identifiers and contact details (e.g., legal name, email, phone)
• Billing address
• Account credentials (e.g., password) [or authentication tokens]
• Investor profile responses (e.g., preferences, time horizon, risk tolerance)
• Communications you send us (support requests, emails, messages)
• Payment-related information (e.g., confirmation of ACH/wire, transaction references).

Note: We generally recommend collecting full bank account details only when needed and using secure methods.

B) Information collected automatically

• Device and usage data (IP address, browser type, pages viewed, timestamps)
• Cookies and similar technologies (see “Cookies” below)

C) Information from third parties (if applicable)

• Service providers (e.g., analytics, email/SMS platforms)
• Identity verification/KYC providers (if you later add KYC)
• Payment processors (if you later add card/processor options)

2. How We Use Information

We may use personal information to:

• Provide and operate the Services (account access, portal functionality)
• Communicate with you (service announcements, deal updates you opt into)
• Improve and secure the Services (fraud prevention, monitoring, debugging)
• Comply with legal obligations and enforce our Terms
• Perform analytics and understand usage trends

3. How We Share Information

We may share information:

• With service providers who help us operate (hosting, analytics, email/SMS)
• For legal compliance (subpoenas, court orders, lawful requests)
• In connection with a business transfer (merger, acquisition, asset sale)
• With your consent or at your direction

We do not publicly post your personal information.

4. Cookies and Analytics

We may use cookies and similar technologies to:

• Keep you logged in (if applicable)
• Remember preferences
• Analyze traffic and performance

You can control cookies through your browser settings. Some features may not function properly if cookies are disabled.

5. Data Retention

We retain personal information as long as needed to:

• Provide the Services,
• Maintain records for legitimate business purposes,
• Comply with legal obligations,
• Resolve disputes and enforce agreements.

6. Security

We use reasonable administrative, technical, and physical safeguards to protect personal information. However, no method of transmission or storage is 100% secure.

7. Your Choices

• Update your account information in the portal (where available)
• Opt out of non-essential communications (marketing, if applicable)
• Control cookies via browser settings

8. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have rights such as:

• Right to know/access the personal information we collect and how we use it
• Right to delete personal information (subject to exceptions)
• Right to correct inaccurate personal information
• Right to opt out of “sale” or “sharing” of personal information (if applicable)
• Right to limit use/disclosure of sensitive personal information (if applicable)
• Right to non-discrimination for exercising your rights

A) Notice at Collection (California)

At or before collecting personal information, we provide a notice describing:

• The categories of personal information collected, and
• The purposes for which they are used.

B) How to Submit a Request

You (or an authorized agent) may submit a request by:

• Email: privacy@xautogroup.com
• Web form: [link]

We will verify your request using information associated with your account and may request additional details for verification.

C) “Do Not Sell or Share”

We do not sell personal information as that term is commonly understood. If our practices change and we engage in “sale” or “sharing” as defined by California law, we will provide a “Do Not Sell or Share My Personal Information” mechanism.

9. Children’s Privacy

The Services are not intended for children under 16, and we do not knowingly collect personal information from children under 16.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date will reflect changes.

11. Contact

Cygnus It Services LLC
privacy@privatedeal.club