Privacy Policy

Types of Personal Information Collected

Depending on how you interact with the Services, we may collect the following information about or from you:

• Personal Information and contact information, such as your name, e-mail address, your digital-wallet address, and any other information you submit through form(s) available on the Services.
• When you communicate with us, such as through e-mail or text message, we may collect and save a record of your communication and any Personal Information provided during the communication.
• Automatically collected technical information such as traffic data, location data, logs, and other communication data.
• Information concerning blockchain-based and/or digital-asset transactions effected by you in connection with your use of the Services, including, but not limited to, digital-asset wallet address(es), digital assets and/or so-called "smart contracts" transacted in and/or with, the website or other address from which the transaction was initiated, etc.
• Information about your computer and internet connection, including, but not limited to, the type of device you use, the IP address of your device, your operating system, information concerning the desktop and/or mobile application(s) you use (e.g., browser extension identification number(s), etc.), the type of Internet browser you use, unique device identifiers and other diagnostic data.

Sources of Personal Information

We may collect Personal Information from various sources including data directly from you, from third parties and public sources, and from automated systems.

• Direct interactions. You may give us your Personal Information by filling in forms or by corresponding with us by mail, email, social media, or otherwise. This includes data you provide when you: begin using and/or otherwise subscribe to the Services; participate in ways to improve customer satisfaction and customer experience; engage customer support; request marketing to be sent to you; and/or give us feedback or contact us.
• Third parties. We may collect your Personal Information from our affiliates and other third parties, public records, third-party providers of services to us (e.g., fraud detection, identity verification, analytics and security), consumer data resellers, social networks, joint marketing partners and affiliate companies.
• Automated technologies or interactions. As you interact with our Services, we may automatically collect technical data about your equipment, browsing actions and patterns. We may collect this personal data by using log files and other similar technologies.
• Cookie Collection. For information about the cookies and similar technologies we use on our website, the choices available to you, and how to change them, please see our Cookie Policy.

Except to the extent prohibited by law, and subject to this Privacy Policy, we will retain and use your Personal Information for as long as it is needed for the relevant purpose, including to provide you with any of the Services, communications, information you have requested, or access to the Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We, and our authorized third parties, will only process your Personal Information where we have legal grounds to do so. We may use the Personal Information that we collect for various purposes, including:

• To provide and maintain the Services.
• To notify you about changes to the Services.
• To allow you to participate in interactive features of the Services when you choose to do so.
• To provide customer support.
• To gather analysis or valuable information so that we can improve the Services.
• To monitor the usage of the Services.
• To detect, prevent and address technical issues.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. You may not opt out of service-related communications, such as transactional communications and technical or security notices.
• To fulfill or enforce our legal or contractual obligations and requirements, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties.

Your information, including Personal Information, may be transferred to (and maintained on) computers located outside of your state, province, country or other governmental jurisdiction from where it was collected and the applicable data protection laws may differ from those of your jurisdiction. We ensure that appropriate contractual protections are in place with such third parties in line with applicable law, including appropriate European Union / United Kingdom standard contractual clauses where necessary. Please contact us if you would like more details about our safeguards for data transfers.

Personal Information may be shared in the following circumstances:

• Third-party service providers. We may disclose Personal Information to third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, analytics, customer service and/or support providers and other similar service providers.
• Legal Requirements. We may disclose your Personal Information to law enforcement, government officials, or other third parties when we have a good faith belief that such action is necessary to: Comply with a legal obligation, such as a valid court order or subpoena; Protect and defend the rights or property of the Company; Prevent or investigate possible wrongdoing in connection with the Services; Prevent physical or financial loss; Protect the personal safety of users of the Services or the public; and/or Protect against legal liability.
• Business Transfers. We may disclose and/or transfer Personal Information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
• Protect our Rights. We may disclose Personal Information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect the rights, property or safety of River and/or our affiliates, partners, clients, customers and/or others.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We also have procedures to deal with any suspected Personal Information breach, and we will notify you and any applicable regulator when we are legally required to do so.

The Services may contain links to other websites, plug-ins and/or applications that are not operated by us. If you click a third-party link, you will be directed to that third party's site, which may allow third parties to collect or share data about you. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Please note that by virtue of the public nature of the blockchain, the holdings and transactions associated with your cryptocurrency wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address (including, but not limited to, cryptographically secure non-fungible tokens, and other blockchain based tokens), the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user's identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please consider how privacy and transparency on the blockchain works.

The California Consumer Privacy Act of 2018 ("CCPA") requires certain businesses to provide a CCPA Notice to California residents to explain how we collect, use, and share their personal information, and the rights and choices we offer California residents regarding our handling of their information.

• Privacy practices. We do not "sell" personal information as defined under the CCPA.
• Privacy rights. The CCPA gives individuals the right to request information about how we have collected, used, and shared your personal information. It also gives you the right to request a copy of any information we may maintain about you. You may also ask us to delete any personal information that we may have received about you. Please note that the CCPA limits these rights, for example, by prohibiting us from providing certain sensitive information in response to access requests and limiting the circumstances under which we must comply with a deletion request. We will respond to requests for information, access, and deletion only to the extent we are able to associate, with a reasonable effort, the information we maintain with the identifying details you provide in your request. If we deny the request, we will communicate the decision to you. You are entitled to exercise the rights described above free from discrimination.
• Submitting a request. You can submit a request for information, access, or deletion to contact@river.one.
• Identity verification. To protect your information, we may take reasonable steps to verify your identity before responding to certain requests to access or delete personal information.
• Authorized agents. California residents can designate an "authorized agent" to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming their authority.

Persons under the age of 18 are prohibited from using the Services. We do not knowingly collect personally identifiable information from anyone under the age of majority in the jurisdiction they are accessing the Services from. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verifiable parental consent, we will take steps to remove that information from our servers.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page, including updating the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective as of when they are posted on this page.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed as soon as possible if your Personal Information changes or is inaccurate during your relationship with us by using the contact details set out below. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at contact@river.one. We may not be able to modify or delete your information in all circumstances, including where we are required to retain it for customer due diligence, screening, or recordkeeping purposes, or where it has been recorded on a public blockchain.

If you have any questions about this Privacy Policy, please contact us by email at contact@river.one, or by mail at:

River Credit Labs, Inc. c/o Brogan Law PLLC 379 W Broadway, 2nd Floor New York, NY 10012