Privacy Notice

Last Updated: January 1, 2025

We respect and are committed to protecting our user’s privacy.

This Privacy Notice covers the privacy practices of Anumatech LLC, d/b/a EbisusBay and any additional subsidiary, affiliate, or branch that we have or may subsequently form (collectively “EbisusBay”, “we”, “our”, or “us”).

Our Privacy Notice is meant to help you understand how we collect, use, and share your personal information, and to assist you in exercising privacy rights available to you by law.

1.  SCOPE AND EFFECTIVE DATE

This Privacy Notice applies to personal information handled or otherwise processed by us in our business, including on our websites, mobile applications, and other online or offline offerings provided by EbisusBay (collectively, the "Services"), and applies to you whether you are accessing the Services for business purposes or if you are using our Services or visiting our website(s) for personal or other reasons.  

Notwithstanding the above, this Privacy Notice does not apply to any third-party websites, services, any public or decentralized blockchain, or applications even if they are accessible through our Services. This Privacy Notice is effective and applicable to all users immediately upon posting to our website. By continuing to use our Services, you are agreeing to this Privacy Notice.

2.  PERSONAL INFORMATION WE COLLECT

The information we collect from you depends on the type of account you set up with us, or the Services you use. We may collect the following types of information:

• Account information. If you create an account, we may collect certain personal information that can be used to identify you, such as your full name, email address, password, and digital wallet address.
  
• Conferences, trade shows, and other events. We may collect personal information concerning individuals from both online and offline sources, such as when we attend conferences, trade shows, and other events or when we host webinars or training programs.
  

• Financial information. In connection with a financial transaction via the Services, or if you enroll in our banking services, our third-party payment service providers may collect your credit or debit card information, digital wallet address, or other financial and payment information. We may directly collect or store payment card or financial information entered through our Services including the last four digits of your payment card or financial information and may receive other information associated with your payment card information (e.g., your billing details). For banking services, including any banking as a service, cash back, or rewards program, we or our third-party service providers may collect your transaction, digital wallet address, and purchase history details. 

• Information you import, share, or upload. As part of the Services, you may also elect to import, share, or upload documents, information, or records including but not limited to financial information.

• Registration for sweepstakes or contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing, and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
  
• Your communications with us. We collect personal information from you such as your full name, email address, phone number, social media identifier, digital wallet address, or mailing address when you request information about our Services, request customer or technical support, including messages you submit through support conversations, apply for a job, or otherwise communicate with us. We may also contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

In addition to the information that you affirmatively provide us, we may also automatically collect personal information when you use our services such as:

• Automatic data collection. We, as well as third parties that provide content, advertising, or other functionality on the Services, may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, media access control address (MAC address), cookie identifiers, mobile carrier, mobile advertising identifier, digital wallet address, and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during, and after using the Services, information about the links you click, digital wallet address, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

• Cookies, pixel tags/web beacons, analytics information, and interest-based advertising technologies.
  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information from your devices through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

Our uses of these Technologies fall into the following general categories:

• Operationally necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity, and improve security or that allow you to make use of our functionality.

• Performance related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services.

• Functionality related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.

• Advertising or targeting related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party sites.
  

3.  HOW WE COLLECT INFORMATION

• Directly from you. We may collect Personal Information that you provide to us, for example, if you choose to create an account with us or contact us.  

• From Third Parties. We may collect Personal Information from third parties including, business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

• Through Online Tracking Technologies. We use cookies and similar technologies to collect Personal Information related to activity on the Services and our website.  For additional information regarding our use of these technologies, see the section above discussing our collection and use.

4.  HOW WE USE INFORMATION

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market products and services that may be of interest to you, whether from EbisusBay or nonaffiliated third parties, as described below.

A.  Provide our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts
• Providing access to certain areas, functionalities, and features of our Services
• Answering requests for customer or technical support
• Communicating with you about your account, activities on our Services, and policy changes
• Processing your financial information and other payment methods for products or Services purchased
• Processing applications for goods or services and completing requested transactions
• Allowing you to register for events
• Furnishing you with customized materials about offers, products, and services that may be of interest, including new content or services from EbisusBay or nonaffiliated third parties
• Providing you the means to perform activities or transact with third party goods or services providers.

B.  Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Measuring interest and engagement in our Services
• Short-term, transient use, such as contextual customization of ads
• Researching and developing products, services, marketing, or security procedures to improve their performance, resilience, reliability, or efficiency
• Improving, upgrading, or enhancing our Services
• Developing new products and Services
• Ensuring internal quality control and safety
• Authenticating and verifying your identities, including requests to exercise your rights under this Privacy Notice
• Debugging to identify and repair errors with our Services
• Auditing relating to interactions, transactions, and other compliance activities
• Enforcing our End User License Agreement and other policies
• Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

C.  Other purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

• Use de-identified and aggregated information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

4.  DISCLOSING YOUR INFORMATION TO THIRD PARTIES

In addition to our internal use of information as described above, we may disclose your information to third parties for a variety of business purposes such as:

• Contractors. We may disclose information to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service that may be of interest to you. We may also share your personal information to business partners with whom we jointly offer products or services.

• Law Enforcement/Governmental Agencies. We may share your personal information if required or appropriate to comply with law enforcement, national security requests, or legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

• Acquiring Parties. If we sell all or substantially all of our assets, or are otherwise acquired, your personal information may be transferred to a third party. We may also transfer or assign personal information to a third party in the event of some other change of control (such as the result of a bankruptcy proceeding).

5.  YOUR PRIVACY CHOICES AND RIGHTS

We provide you with the following privacy choices regarding your personal information as required by applicable law and which are described below.

• Cookies and interest-based advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Depending on your jurisdiction, you may be presented with a cookie banner, which will provide you with the ability to adjust your cookie settings. Additionally, most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for those mobile device providers.

• General. You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.

To the extent required by applicable law, you may have the right to:

• Access to/port information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”).
• Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information, or we may refer you to the controller of your personal information who is able to make the correction.
• Request deletion of your personal information, subject to certain exceptions prescribed by law.
• Request restriction of or object to processing of your personal information.

• Withdraw your consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request.

6.  INTERNATIONAL DATA TRANSFERS

You acknowledge that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.  We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information to countries outside the European Economic Area, United Kingdom, or Switzerland, we will put in place appropriate safeguards as required by applicable law to ensure that this transfer complies with the applicable laws and regulations and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request, please contact us as set forth in “Contact Us” below.

7.  DATA RETENTION

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8.  SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well.  To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Services, by mail, or by sending an e-mail to you.

9. CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), applies solely to individuals, who are residents of the State of California. The CCPA provides consumers (California residents) with specific rights regarding their personal information. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

To make a request related to your personal information rights under the CCPA, please contact us at the address in the “Contact Us” section below.

10. CHILDREN

The Services are not directed to children under 13 (or other age as required by local law), and we do not permit users under age 18 or knowingly collect personal information from children under age 18. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child's account.

11.  CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or if you wish to submit a request to exercise your rights as detailed in this Privacy Notice, please contact us.

legal@ebisusbay.com

ATTN: Jonathan Schmalfeld

7676 Forsyth Boulevard, Suite 800

St. Louis, MO 63105