Prometheum, Inc.’s Privacy Policy

Last Updated: October 31, 2017

Welcome to the Prometheum’s website located at www.Prometheum.com (the "Site") owned and operated by Prometheum Inc. ("Prometheum," "we" or "us"). We recognize that your privacy is very important and take it seriously. This Privacy Policy describes Prometheum’s policies and procedures on the collection, use and disclosure of your information when you use the services, websites, and applications offered by Prometheum (collectively, the "Services"). By using the Services, you consent to our use of your information in accordance with this Privacy Policy. We will not use or share your personal information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to personal information we collect by other means (including offline) or from other sources. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service.

Information We Collect and How We Use It

Prometheum collects personal information to provide you with a personalized, useful and efficient experience. The categories of information we collect can include:

Information You Directly Provide to Us

There are many occasions when you provide information that may enable us to identify you personally ("Personally Identifiable Information") while using the Services, such as when you sign up for an account, verify your identity or your status as an Accredited Investor or Qualified Purchaser, provide account information or provide us with access to your profiles on third party. Personally Identifiable Information we collect may include, without limitation, your email address, name, phone number, birthday, age, address, Social Security number and/or taxpayer identification number, investment objectives, investment experience, and your educational or professional history.

We may use your email address to send you newsletters, updates about the Service, and Services-related notices, including any notices required by law, in lieu of communication by postal mail. You can control receipt of certain Services-related messages on your Prometheum Settings page. We may also use your contact information to send you marketing messages from us or our affiliates. If you do not want to receive such messages, you may opt out by following the instructions in the message. (Please note it may take up to one week to process any opt-out requests.) If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

Information from other sources

We may obtain information from other sources, such as our affiliates, our partners who provide a joint service, third-party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, our Privacy Policy governs the handling of the combined personal information.

Information We Collect Automatically through Cookies and Other Tracking Technology

We collect non-personally identifiable information regarding your usage of the Services, including the pages and articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed, and other information that does not identify you ("Non-Personally Identifiable Information" and collectively with the Personally Identifiable Information, the "Data"). Like most online services, we may use cookies, log files, clear GIFs, tracking pixels, web beacons, and other technologies some of which are detailed below.

Cookies: When you visit the Services, we may send one or more "cookies" – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Services to us, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Cookies:Log Files: Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

Cookies:Clear GIFs Information: When you use the Services, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your Prometheum account is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make Prometheum better for our users.

Cookies:Location Data: Depending on your device settings, we may also collect your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device's location by analyzing other information, like an IP address.

Cookies:Third Party Services: We may use third party services such as Google Analytics or Mixpanel to help understand use of the Services. Google Analytics and Mixpanel collect the information sent by your browser as part of a web page request, including cookies and your IP address. Google Analytics and Mixpanel also receive this information and their use of it is governed by their respective privacy policies. Although we do our best to honor the privacy preferences of our users, we may not respond to Do Not Track signals set by your browser at this time.

How We Use Your Information

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive for the following: to deliver and improve our Services; to manage your account and provide you with customer support; to perform research and analysis about your use of the Services; to improve and develop our Services; to communicate with you; to develop, display, and track content and advertising tailored to your interests on the Services and other sites; to diagnose or fix technology problems; to automatically update the Services on your device; to verify your identify and prevent fraud or other unauthorized or illegal activity; to enforce or exercise any rights in our Terms of Service; and to perform functions or services as otherwise described to you at the time of collection.

We will retain your information for as long as your account is active or is needed to provide you the Services and may retain Data after you discontinue use of the Services. We will retain and use your information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

How We Share Your Information

We will share your personal information with third parties in the instances described below.

Partners & Affiliates. We share your personal information with our current and future parents, affiliates, subsidiaries and other companies under common control and ownership and with third party partners with whom we work or who have engaged us to provide the Service to you or to provide a joint service. These partners may use your personal information as permitted in the respective partner's own privacy policy.

Service Providers. We may share your Personally Identifiable Information with third parties for the purpose of providing the Services to you or to help us market our products and services. If we do this, such third parties' use of your information will be bound by this Privacy Policy. We may store personal information in locations outside of our direct control (for instance, on servers or databases co-located with hosting providers). Your Personally Identifiable Information may also be shared subject to the terms of use governing our API. We cannot ensure that your Personally Identifiable Information will be protected, controlled or otherwise managed pursuant to this Privacy Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.

Business Transfers. As we develop our business, we may buy or sell businesses or assets. In the event we sell or transfer all or a portion of our business, assets, or products and services as part of a sale, divestiture, merger, acquisition, bankruptcy, dissolution or similar corporate transaction, your personal information may be transferred as part of the sale.

Your Content. We may share or disclose your information with your consent, such as if you choose to sign on to the Services through a third-party service. We cannot control such third parties' use of your information.

Legal Compliance. Prometheum may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or request of a law enforcement agency or a regulator with jurisdiction over us; to protect the safety of any person; to address fraud, security or technical issues; enforce our Terms of Service, or to protect Prometheum's rights or property.

Anonymized or Aggregated Data. We may share information with third parties in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Third Party Tracking and Online Advertising. We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our website over time so that they may play or display ads that may be relevant to your interests on our website and Service as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests and to track conversions and the success of an ad campaign. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device.

How We Protect Your Information

Prometheum uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Prometheum or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.

Prometheum cannot ensure that your Personally Identifiable Information will be protected, controlled or otherwise managed pursuant to this Privacy Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.

In the event that personal information is compromised as a result of such a breach of security, Prometheum will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

Your Choices About Your Information

You may, of course, decline to submit Personally Identifiable Information through the Services, in which case Prometheum may not be able to provide certain services to you. In addition, you may update or correct your account information and email preferences at any time by logging into your account. If you would like us to remove your Personally Identifiable Information from our database, please send a request to: contact@prometheum.com

Children's Privacy

Protecting the privacy of young children is especially important. Prometheum does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register with the Services. If you are under the age of 13, please do not submit any personal information through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on this Site. If we become aware that we have collected personal information from a child under age 13, we will take steps to remove that information.

We are not responsible for revising or removing your Personally Identifiable Information obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Prometheum. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our Site, is subject to that website's own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy Policy means you consent to such changes.

Where We Store Your Information

The Services are maintained in the United States of America. Although we welcome users from all over the world, by accessing the Services, you consent to and authorize the export of Personally Identifiable Information to the United States and its storage and use as specified in this Privacy Policy. Note the laws of the United States might not be as comprehensive or protective as laws in the country where you live.

For Users in the EU

The following additional terms apply to individuals within the EU.

We may share your personal information with business partners, subcontractors and suppliers which provide services to us in order for us to fulfill our obligations to you. Personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA").

It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, business partners or sub-contractors. Such staff maybe engaged in the processing of your payment details and the provision of support services.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. You have the right to access information held about you. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. If you wish to exercise this right please contact us at contact@prometheum.com.