Privacy Policy

This Privacy Policy, together with our Terms of Service and any other documents referred to on it, for UNITARITY PTY LTD, (located in Queensland, Australia), and its affiliates (collectively, “Portfolio” or the “Company”), explains how Portfolio collects, uses, shares and stores the information that you provide when you visit our website, located at https://portfolio.io (the “Site”). Please read this Privacy Policy in its entirety before using Portfolio or visiting the Site. Portfolio is committed to protecting and respecting your privacy. This Privacy Policy explains what you can expect from us and what we need from you in relation to your Personal Information. This Privacy Policy applies to any Services offered by Portfolio. We may amend this Privacy Policy at any time by posting the amended version on this Site and noting the last revised date of the amended version. We may announce material changes to this Privacy Policy via email. By visiting the Site you are accepting and consenting to the practices described in this Privacy Policy.

Definitions
As used herein, the following terms are defined as follows:
“Digital Asset” is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital commodity”), such as Bitcoin, Ripple or Ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value. “ Portfolio Account” means a user-accessible account offered via Portfolio. “Portfolio” means Portfolio-branded websites, applications, services, or tools operated by the Company. “Non-Personal Data” means anonymous data that does not identify you specifically, including data collected automatically when you enter our Site. This may include cookies, pixel tags, web beacons, browser analysis tools, web server logs, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Our server logs may also record the IP addresses of the devices you use to interact with the Site. We may also collect information about a website you were visiting before you came to our Site and any website you visit after you leave our Site, if this information is supplied to us by your browser. “Personal Information” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person. 

Safeguarding Your Personal Information
Portfolio is responsible for the collection, use, disclosure, retention and protection of your Personal Information in accordance with our global privacy standards, this Privacy Policy, as well as any applicable national laws. Portfolio uses encryption to protect your information. Data controllers process and retain your personal information on our servers where our data centers are located, including the European Union, Japan, Singapore, the United States of America and elsewhere in the world. We are serious about guarding the privacy of your Personal Information and work hard to protect it from unauthorized access, or unauthorized alteration, disclosure, or destruction. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Information from unauthorized access, including encryption with SSL, the availability of two-factor authentication, and periodic review of our Personal Information collection, storage, and processing practices. We restrict access of your Personal Information only to those Portfolio employees, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. Unfortunately, despite best practices and technical safeguards, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information during transmission, and any acts of transmission are at your own risk.

Personal Information We Collect
When using Portfolio, we may collect and use the following Personal Information about you: Full legal name;Home address, including country of residence;Email address;Mobile phone number;Date of birth;Proof of identity (e.g., driver’s license, passport, or government-issued identity card);An identification number issued by a government;Other Personal Information or commercial and/or identification information; andWhatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (“AML”) obligations, such as under the European Union’s 4th AML Directive and the U.S. Bank Secrecy Act (“BSA”).

During our practice of collecting Personal Information, you maintain the following rights: Right of Rectification– You have the right to correct any Personal Information we hold on you that is inaccurate, incorrect, or out of date.Right of Erasure – You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Portfolio is subject to.Portability – You may have the right to transfer certain of your Personal Information between data controllers, for example, to move your account details from one online platform to another.Non-Personal Data Collection Practices

Our Site may aggregate and collect anonymous data that does not identify you specifically, including data collected automatically when you enter our Site, including the following: Location Information – Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform; Log Information – Information that is generated by your use of Portfolio that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our Site (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;Account Information – Information that is generated by your Portfolio account activity including, but not limited to, instructions regarding funding and disbursement, orders, trades, and account balances; andCorrespondence – Information that you provide to us in written or oral correspondence, including opening a Portfolio account, and with respect to ongoing customer support; and logging of phone numbers used to contact us.Portfolio also utilizes tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (hereinafter, “Cookies”) on your computer or other devices used to visit Portfolio. We use both session and persistent Cookies. Session Cookies expire when you log out of your account or close your browser. Persistent Cookies remain on your computer or mobile device until deleted or otherwise expire. Most web browsers are set to accept Cookies by default. You are free to decline most of our session Cookies if your browser or browser add-on permits but choosing to remove or disable our Cookies may interfere with your use and functionality of Portfolio. We use Cookies to (i) help us recognize you as a customer, collect information about your use of Portfolio to better customize our services and content for you, and to collect information about your computer or other access devices as part to ensure our compliance with our BSA and AML obligations and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities.

To disable automatic data collection techniques you may do any of the following:
Email Communications – Subject to applicable laws and regulations, we may from time to time send communications promoting services, products, facilities, or activities to you using information collected from you. When you create a Portfolio account you are agreeing to opt-in to all communications from us. We will provide you with an opportunity to opt-out of newsletter communications. We will never provide your Personal Information to third parties for direct marketing or other unrelated purposes without your written consent. Unfortunately, we are unable to allow you to opt-out of the emails we send you for certain legal or administrative purposes.Cookies – You may decline session cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of Portfolio. Location Information – You may be able to stop the collection of location information through your device settings or by following the standard uninstall process to remove our applications from your device; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of Portfolio.

EU General Data Protection Regulation
As of May 25, 2018, the processing of Personal Information of users located in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). To the extent we process any Personal Information of users located in the EU, you maintain your right to request the information that Portfolio has about you, the right to correct that information, the right to delete your account with Portfolio, and the right to object to Portfolio’s information collection practices. All Personal Information collected is done so for a legitimate purpose in providing our Services to you. If you have any questions or would like to delete your account with us or object to any of our information collection practices, please email us at support@portfolio.io.

Information About You from Third-Parties
We work closely with third parties and may receive information about you from them, including the following:
The banks you use to transfer money to us will provide us with your basic Personal Information, such as your name and address, as well as your financial information such as your bank account details;Business partners may provide us with your name and address, as well as financial information;Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our Site; andCredit reference agencies do not provide us with any personal information about you but may be used to corroborate the information you have provided to us.

General Provisions
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the European Economic Area (“EEA”), this Personal Information will not be retained without your consent. In providing the personal information of any individual (other than yourself) to us during your use of Portfolio, you promise that you have obtained consent from such individual to disclose his/her Personal Information to us, as well his/her consent to our collection, use and disclosure of such Personal Information for the purposes set out in this Privacy Policy.

Use of Personal Information and Non-Personal Data
Set forth below is a description of all the ways we use your Personal Information and Non-Personal Data and why we do so. Please contact us at support@portfolio.io if you would like further information regarding how we collect and use your Personal Information and Non-Personal Data. We may use your Personal Information and Non-Personal Data to do the following:
Provide Portfolio’s Services to you to carry out our contractual obligations relating to you, including the fulfillment of your orders, the operation of your Portfolio account and the provision of our support services;Comply with legal and/or regulatory requirements, including, but not limited to, AML requirements;Verify your identity to protect against fraud, comply with financial crime laws, and to confirm your eligibility to use our Services;Help us better manage your account with Portfolio;Provide you with information about new functionality, features, or services we offer;Make suggestions and recommendations to you and other users of Portfolio;Process applications for Portfolio Accounts services, including making decisions about whether to agree to approve any applications;Improve Portfolio’s functionality;Administer internal operations necessary to Portfolio, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;Notify you about changes to the Terms of Service, Privacy Policy or Services.

Disclosure of your Personal Information
We may share your Personal Information with selected third parties including:
Affiliates, operational and business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;Analytics and search engine providers that assist us in the improvement and optimization of our Site; andOur group entities or subsidiaries.We may disclose your Personal Information to third parties when:
We sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets in order to continue the services for which you have contracted;We are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other applicable agreements; or to protect the rights, property, or safety of Portfolio, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;We conduct or cooperate in investigations of fraud or other illegal activity whenever we believe it is reasonable and appropriate to do so;We seek to prevent and detect fraud and crime;We receive a lawful subpoena, warrant, court order, or as otherwise required by law;We seek to protect Portfolio from financial and insurance risks;We seek to recover debt or in relation to your insolvency; andWe seek information necessary to maintain or develop customer relationships, services and systems.In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.

By using Portfolio, you consent to your Personal Information being transferred to other countries, including countries that have different data protection rules than your country. In all such transfers, we will protect your Personal Information as described in this Privacy Policy. We do not maintain a published list of all of the third parties with whom we share your Personal Information with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your Personal Information with, or to be provided with a list specific to you, you can request this by writing to support@portfolio.io

Where We Store Your Personal Information
Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and process your Personal Information in the European Union, Japan, Singapore, the United States of America, and elsewhere in the world.

Automated Decision Making
We may use Automated Decision Making (“ADM”) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with fast and efficient service, we may use ADM to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.

Privacy When Using Digital Assets and Blockchains
Your financial acquisitions may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to de-anonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks, which are not controlled or operated by Portfolio or its affiliates, we are not able to erase, modify, or alter Personal Information from such networks.

Data Retention
As Portfolio and its affiliates are subject to various legal, compliance and reporting obligations, including BSA or national AML requirements (as defined above), we are required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate.

Access to Information
Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact support@portfolio.io

Changes to this Privacy Policy
Any changes we may make to our Privacy Policy will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Protection of Minors
Portfolio is not directed to persons under the age of 18, hereinafter “Minors”, and we do not knowingly collect Personal Information from Minors. If we learn that we have inadvertently gathered Personal Information from a Minor, we will take legally permissible measures to remove that information from our records. Portfolio will require the user to close his or her account and will not allow the use of PortfolioServices. If you are a parent or guardian of a Minor, and you become aware that a Minor has provided Personal Information to Portfolio, please contact us at support@Portfolio and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

Contact
Any questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@portfolio.io. Where we have a legal obligation to do so, we have appointed data protection officers (“DPOs”) to be responsible for Portfolio’s privacy program for the respective data controllers. If you have any questions about how we protect or use your Personal Information, you can contact our DPOs by email at support@portfolio.io