Last Updated: March 27th, 2024

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The VOLAG website located here https://www.volag.io (the “Site”), mobile application (the “App”) and its related services, software, and content (“Platform”) are owned and operated by Round 14 Technologies LLC (“VOLAG”, “our”, “us”, “we”), a Delaware limited liability company. VOLAG has adopted this Privacy Policy (“Privacy Policy”) to inform Business Users and Registered Users (sometimes collectively referred to herein as “you” or “your” or “you’re”) that it collects Personal Information when you use the Platform and to explain how this information is used. You should contact VOLAG directly with any questions or concerns.  

This policy describes: 

• The types of information we may collect or that you may provide when you install, register with, access, or use our Platform.
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

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VOLAG MAY CHANGE, MODIFY, AMEND, SUSPEND, TERMINATE, OR REPLACE THIS PRIVACY POLICY FROM TIME TO TIME AND WITHIN ITS SOLE AND ABSOLUTE DISCRETION. IN THE EVENT VOLAG CHANGES, MODIFIES, AMENDS, OR REPLACES THIS PRIVACY POLICY, THE LAST UPDATED DATE, LOCATED ABOVE, WILL CHANGE.  YOUR CONTINUED USE OF THE PLATFORM AFTER A CHANGE IN THE LAST UPDATED DATE OF THIS PRIVACY POLICY CONSTITUTES YOUR MANIFESTATION OF ASSENT TO THE CHANGE, MODIFICATION, AMENDMENT, OR REPLACEMENT CONTAINED WITHIN.
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Definitions.

• Account means a Registered User’s account with the Platform.   
• Business User(s) means Registered Users who register and are approved by VOLAG through the Site to access the services offered by VOLAG through the Platform. Business Users include sole proprietorships and registered legal entities. 
• California Consumer Privacy Act (“CCPA”) means the California statute intended to enhance privacy rights and consumer protection for residents of California, United States. 
• General Data Protection Regulation (“GDPR”) means the European Union (“EU”) law on data protection and privacy applicable to individuals within the EU.
• Individual User(s) means Registered Users who register for an Account through the VOLAG App and are not a Business Users.
• Personal Data means any information relating to an identified or identifiable natural person, an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Personal Information under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  For purposes of this Privacy Policy, “Personal Data” is included within this definition. 
• Registered User(s) means Users who have created an account to use and access the Platform.
• User(s) means any individual that visits and accesses the Platform, including Registered Users. 
• You / Your / You’re refers to all Users.  

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Types of Personal Information We Collect.

VOLAG may collect the following Personal Information from all Registered Users who use the Platform:

• First name;
• Last name;
• Email address;
• Wallet address;
• Any other information that you upload or submit to the Platform directly or indirectly.

VOLAG may collect the following Personal Information from certain Business Users, as applicable: 

• First name;
• Last name;
• Date of birth;
• Country of registration;
• Email address;
• Phone number;
• Address;
• Business entity information, 
• Government issued identification document or driver’s license;
• Entity registration number;
• Information required to verify your identity (known as “Know Your Customer” checks); and,
• Any other information that you upload or submit to the Platform directly or indirectly.

In addition, VOLAG collects the following Personal Information from all Users:

• Your geolocation;
• Your IP address;
• Your browser and search engine information;
• Your device information;
• Your visitor history;
• Business record information, including records of your transactions through the Platform;
• Your usage of the Platform, including, without limitation, any links or items clicked or pages viewed and statistics;
• Information stored in cookies, pixel tags, or web beacons; 
• Analytical data from Google Analytics and/or Google AdSense; and
• Any other additional analytic data that you voluntarily submit to the Platform.

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Sources of Personal Information Collection.

VOLAG may collect this Personal Information from you through various channels, including, but not limited to, through your voluntary submission of information to the Platform, through requests initiated by you through the Platform, through the collection and analysis of information concerning your computer and browsing activities, through the use of cookies, web beacons, pixel tags, Google Analytics, Google AdSense, and through other sources permitted by law. 

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Cookies & Similar Technologies.

The Platform also utilizes Cookies.  Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the Cookie. We use Cookies and similar technologies to enable our systems to recognize your browser and to provide certain features.  We also use “web beacons” to help deliver Cookies and gather usage and performance data. The Platform may also include Cookies, web beacons, and other similar technologies from third-party service providers.

You have a variety of tools available to control the data collected by Cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use Cookies and to withdraw your consent by clearing or blocking Cookies. You can also stop VOLAG from placing Cookies (other than those required for the Platform to function) on your device by referencing the instructions below or opting out using the Cookie notification opt-out on your initial visit to the Platform.

The table below sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

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Lawful Basis for Processing Your Personal Information

The lawful basis for us processing your Personal Information for the uses described above will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; and/or the processing is in our legitimate interest of providing a technology service for the creation and administration of a tokenized loyalty and reward promotional program between business users and their customers. 

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How VOLAG Uses Your Personal Information.

We use your Personal Information based upon the legal basis of Users’ consent to provide you with the Platform, process any requests made by you, communicate with you, identify and fix problems with the Platform, and update you regarding changes to the Platform and the VOLAG and third-party services offered through the Platform.  

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By using the Platform, you further authorize the following specific uses of your Personal Information:

• Enable your use of the Platform and its associated services;
• Improve algorithms;
• Measure service usage;
• Develop new features;
• Contact and communicate with you, whether through email, telephone, text message, and/or messages within the Platform; 
• Customize and/or tailor the Platform and your user experience, which may include targeted selection and display of third-party advertisements within the Platform;
• Aggregate certain information that does not include your personal information and disclose it for analysis, demographic profiling and/or targeted advertising;
• Advertise software, products, and services of VOLAG;
• Transmit and process your information and actions within the Platform;
• Provide statistical information, and include you in the same, where applicable;
• Provide you with technical service and support, including updates;
• Provide you with information concerning VOLAG’s services;
• Store, archive, retrieve, and make copies of your user generated content;
• Understand your needs and requests;
• Communicate promotions or other offers;
• Process payments;
• Prevent and detect illegal activities or violations of our Terms of Service;
• Combine your personal and personally identifiable information with information from other VOLAG applications and/or services; and
• Facilitate your use of the Platform and upgrades/replacements to the Platform.

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Sharing of Your Personal Information.

VOLAG shares your Personal Information with third parties in the following circumstances:

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• Where VOLAG has obtained your consent;
• Where you opt into a service provided by a third party directly from the VOLAG platform;
• Where sharing or disclosure of your Personal Information is necessary to provide you with the Platform, and/or associated services (we may share your personal or personally identifiable information with trusted third-parties who assist us in operating the Platform, providing the associated services, and conducting our business);
• Where sharing or disclosure of your Personal Information is necessary to share personal or personally identifiable information with VOLAG’s parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners;
• Where VOLAG has been purchased by a third party;
• Where sharing or disclosure of your Personal Information is necessary to respond to requests by government authorities;
• Where your Personal Information is demanded by a court order or subpoena;
• Where sharing or disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or owners/shareholders of VOLAG;
• Where sharing or disclosure of your Personal Information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty; and 
• Where VOLAG is otherwise legally obligated to share your personal or personally identifiable information.

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VOLAG Shares Your Personal Information With the Following Third-Parties:

• Google, including Google Analytics (privacy policy here);
• KYCAID - only for Business Users (privacy policy here);
• Anclap - (privacy policy here);
• Transak - only for Business Users (privacy policy here);

This list is not exhaustive as to all the third-parties VOLAG may share your Personal Information with. VOLAG is committed to keep track of which third-parties receive your Personal Information internally. 

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No Liability Third-Party Platform and Third-Party Links.

The third-party service providers affiliated with VOLAG have their own independent privacy policies governing the use of your Personal Information pursuant to the GDPR and CCPA and we encourage you to read those privacy policies carefully.  You understand that even if VOLAG deletes your Personal Information that it may still be available in a third-party service provider’s database.  VOLAG has no responsibility or liability for the Personal Information collection, use, or storage activities of the third-party services providers used by VOLAG to provide you with the services associated with the Platform. 

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VOLAG may outsource or subcontract some of our technical support, tracking and reporting functions, database management functions, and other services to third parties. We may share information from or about you with them so that they can perform their services as long as they comply with this Privacy Policy, the GDPR, and the CCPA. You understand and agree that VOLAG will not be held responsible for any third-party communications sent by entities that VOLAG does not own or control.  You are encouraged to review any third-party privacy policies before utilizing any such third-party service.

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VOLAG may include or offer third-party products or services on the Platform and provide third-party links to the same.  These third-party websites have separate and independent privacy policies.  VOLAG has no responsibility or liability for the content and activities of such third parties or their websites.  We encourage you to read carefully the privacy policies of all such third-party websites.  We seek to protect the integrity of the Platform and therefore welcome any feedback about any such third-party websites.

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Personal Information Transfer and Storage.

Your Personal Information is stored and processed on computers and servers in countries around the world, including but not limited to the United States…. This list may expand and include other countries not listed here. Your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is stored and processed, we apply the same protections described in this policy. Through your use of the Platform, you consent to the processing and storage of your Personal Information and personally identifiable information. You understand that your Personal Information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction.  If you are located outside the countries listed and choose to provide Personal Information to us, please note that we transfer your Personal Information to the countries listed and process it there, and that we may store portions of your Personal Information in said countries. 

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Users understand and agree that if they provide VOLAG with Personal Information that it is stored indefinitely, unless the User contacts VOLAG to have their Personal Information removed from storage.  As specified above, even if VOLAG deletes your Personal Information from its own servers, it may still be available in a third-party service provider’s database.  You should consult with those third-parties in the event you would like Personal Information deleted therefrom.  

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Personal Information Security.

VOLAG uses standard technology to store and help prevent against the unauthorized disclosure of your Personal Information. Though we undertake commercially reasonable efforts to protect your information, no website, software, or online service is completely safe. Accordingly, you provide all such information at your own risk.

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In order to protect your Personal Information, VOLAG uses specific security measures, such as Secure Sockets Layer (SSL) protocol, which encrypts information you input at 128-bit strength. This is denoted in most web browsers by a small padlock appearing on the bottom bar of the window and the address of the window changing from http:// to https://, indicating a secure connection.

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EU Users’ Rights Under the GDPR.

The GDPR provides Users located in the EU under its protection certain rights with respect to their Personal Data collected by us on the Platform.  Accordingly, VOLAG recognizes and will comply with the GDPR and those rights, except as limited by applicable law.  The rights under the GDPR include:

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• Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint. 

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• Right of Rectification: This includes the right to correct inaccurate Personal Data collected and/or stored by us.

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• Right of Erasure (“Right to be Forgotten”): This includes the right to have your Personal Data deleted.  However, if applicable law requires us to comply with your request to delete information, fulfillment of your request may prevent you from using our services and may result in closing your account.

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• Right to Restriction of Processing: This includes the right to request restriction of how and why your Personal Data is used or processed by us.

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• Right to Data Portability: This includes the right to receive your Personal Data in a structure, readable format and the right to have your Personal Data transferred.

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• Right to Object: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.

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• Right to not be Subject to Automated Decision-Making: This includes the right to not be subject to a decision based solely on automated processing, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.

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California Users’ Rights.

Under the CCPA, California Users have the following rights:

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• Right to Know About Personal Information Collected, Disclosed, or Sold: You have the right to request that VOLAG disclose what Personal Information of yours it collects, uses, discloses, and sells over the past 12 months.

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• Right to Have Personal Information Deleted:  You have the right to request that VOLAG delete any of your Personal Information that we collected from you.

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• Right to Opt-Out of the Sale of Personal Information:  VOLAG does not sell Personal Information.  

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• Right to Non-Discrimination:  VOLAG shall not discriminate against California Users for exercising their rights under the CCPA. 

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To exercise your rights under the CCPA – or have an authorized agent exercise your rights under the CCPA on your behalf – you may submit either a “Request to Know Personal Information” or a “Request to Delete Personal Information” to VOLAG by contacting VOLAG at legal@volag.io. VOLAG will verify this request by ensuring that such request is from an email address associated with a Registered User. 

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Under California’s “Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that VOLAG has shared your Personal Information within the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting VOLAG at the address below. 

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Additional State Privacy Rights.

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:

• targeted advertising (excluding Iowa);
• sales; or 
• profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

• Either limit (opt-out of) or require consent to process sensitive personal data. 

The exact scope of these rights may vary by state. To exercise any of these rights please contact us here legal@volag.io 

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address:  legal@volag.io

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Purchase or Sale of the Platform or Other Assets.

VOLAG may purchase other businesses or sell components of its business, including, but not limited to, the Platform. In the event VOLAG purchases another business or sells any component of its business, your Personal Information will continue to be used consistent with the terms of this Privacy Policy.

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How To Stop VOLAG from collecting your Personal Information.

You can stop VOLAG from collecting your Personal Information by contacting VOLAG at legal@volag.io and requesting that VOLAG stop collecting your Personal Information. 

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You must delete or request to delete your Account since its existence requires use of certain Personal Information. 

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Additionally, you can adjust your web browser settings to limit or turn off Cookies or other tracking techniques, or you can cease use of the Platform.  You may contact VOLAG with any requests regarding your Personal Information. VOLAG also honors Do Not Track requests and signals. 

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Your Obligations.

When using the Platform, you are obligated to inform VOLAG of any changes to your Personal Information.

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Children’s Online Privacy Protection Policy.

The Platform is not intended for or directed to users under the age of 18, and VOLAG does not knowingly or intentionally collect Personal Information from children under the age of 13 or other minors. Where appropriate, VOLAG takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Platform or in response to advertisements. If you are concerned that Personal Information may have been inadvertently provided to or collected by VOLAG, please contact us immediately so appropriate steps may be taken to remove such information from VOLAG’s database.

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Contact and Notices.

All questions and concerns regarding this Privacy Policy may be submitted to VOLAG at:

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Round 14 Technologies LLC

legal@volag.io

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