1. PRIVACY POLICY:

By accessing the ICOA Platform or the website https://icoa.tech/ (the “Website”) or using the ICOA Services, you hereby agree to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described below. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access of the ICOA Platform and Website and use of the ICOA Services. All terms used herein and not specifically defined shall have the meaning ascribed to them in the ICOA User Agreement.

2. CHANGES TO THE PRIVACY POLICY:

As used herein, ‘personal information’ shall mean data that can be used to identify you. The ICOA Privacy Policy covers all personal information that you voluntarily submit to ICOA and that we may obtain from our partners or Affiliates. For the avoidance of doubt, Sections 3 through 9 of this Privacy Policy do not apply to non-personally identifiable information or anonymized data as it cannot be used to identify you.

Except as described in this Privacy Policy, ICOA will not give, sell, rent or loan any personal information to any third party.

You do not need to provide personal information in order to access and view the ICOA website (https://icoa.tech/), however, ICOA may not be able to effectively serve you and certain portions of the ICOA Services may not be available to you should you choose not to share certain information with ICOA. ICOA collects personal information in order to facilitate the provision of the ICOA Services. ICOA requires certain personal information from you for various reasons including: (a) ICOA is required by applicable law to collect certain information and (b) it is relevant for specified purposes. Any information you provide to ICOA that is not required is therefore voluntary. Importantly, ICOA may be unable to open your account if requested information is not provided.

ICOA collects personal information which is required under the law to open a ICOA Account, add a payment method, or execute a transaction. ICOA also collects personal information when you use or request information about the ICOA Services, subscribe to marketing communications, request support, complete surveys, or interact with the ICOA Platform and Website in other ways. ICOA may also collect personal information from you offline, such as when you attend a ICOA event, or when you contact customer support. We may use this information in combination with other information we collect about you, as set forth in this Privacy Policy.

By way of example, some of the types of personal information that may be collected and the ways in which ICOA may use such information are outlined below:

Upon ICOA Account opening, ICOA or one of its Affiliates or service vendors may, acting on ICOA’s behalf, collect the following types of information in order to satisfy ICOA’s legal and regulatory obligations.

• Name;
• Date of birth;
• Social security number
• Driver’s license number;
• Personal identification number;
• Phone number
• Email address;
• Bank account details
• Credit card details

In connection with the ICOA Services, you may request access to additional or upgraded services offerings. In these instances, ICOA, its Affiliates, or various service providers may require additional information including but not limited to:

• Date of birth;
• Taxpayer identification number;
• Government identification number;
• Copies of government-issued identification;
• Information from third parties including credit bureaus;
• Other personal information, as necessary.

In addition, when you contact ICOA, request future communications from ICOA, or respond to various ICOA communications, you may provide ICOA with additional personal information pursuant to those interactions and ICOA will use such information in order to provide services.

To the extent that you choose to provide ICOA with access to certain personal information stored by third parties such as social media sites, the information that ICOA may have access to will be dictated by those sites as well as the privacy settings that you choose to authorize.

In addition to the above listed examples, ICOA may also collect personal information that you post to any type of message board service contained within the ICOA Platform or Website, and/or chats, blogs, or other services available to you through the ICOA Platform or Website whereby you post information. Please be advised that any information that you post on the ICOA Platform or Website will become public information and may therefore appear in public ways, such as through search engines or other publicly available platforms.

3. USE OF PERSONAL INFORMATION:

Generally, ICOA will use your personal information in order to create, develop, operate and deliver the ICOA Services and maintain the ICOA Platform and Website. ICOA will use such information:

• To comply with ICOA’s legal and regulatory obligations;
• To prevent potentially prohibited or illegal behavior, including violations of the ICOA User Agreement;
• To process transactions and send confirmations;
• To verify the identity of ICOA account holders;
• To resolve disputes and troubleshoot problems;
• For ICOA Services quality control and ICOA employee training;
• To enhance ICOA Platform and Website security, monitor for security risks and combat fraud;
• To communicate with you about ICOA Services as well as other, third party offerings;
• To deliver target marketing, service update notices, promotional offers and communication preferences;
• To provide or respond to any other service request.

ICOA will not use your personal information for purposes other than those purposes that ICOA will disclose to you either in this Privacy Policy or via the other methods as explained above. From time-to-time ICOA may request permission to allow ICOA to share certain personal information with third parties or Affiliates. You may opt out of having your personal information shared with third parties, or from allowing ICOA to use your personal information for any purpose that is incompatible with the purposes for which we originally collected such information. If you choose to limit ICOA’s use of your personal information, certain features of the ICOA Platform or Website may not be available to you.

4. THIRD PARTY SOURCES:

ICOA may, from time to time, obtain information about you from third party sources as required or permitted by applicable law, rule or regulation. These third-party sources include public databases, credit bureaus, ID verification partners, resellers and other partners, joint marketing partners and social media platforms.

ICOA obtains information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information may include: your name, employment status, public employment profile, credit history, status on any sanctions list maintained by public authorities, and other relevant data. ICOA obtains such information in order to comply with various legal and regulatory obligations, including but not limited to ICOA’s anti-money laundering obligations. In some cases, ICOA may process additional data about you to ensure that the ICOA Services are not being used for fraudulent purposes or other illicit activities.

In addition to public databases and ID verification partners, ICOA may also collect information about your publicly available social media profile, interests or preferences and page-view information from third party business partners with which ICOA may operate additional or co-branded services. ICOA collects this information to better understand and/or maintain and improve the accuracy of the records that ICOA holds as well as for purposes of promoting the ICOA Services. In addition, ICOA may use this information in conjunction with your browsing habits (as obtained from third party vendors) as well as your contact details, professional information and ICOA Account transaction history to deliver targeted advertising and marketing to you, where permitted by applicable law and in accordance with any advertising/marketing preferences you may have selected on the ICOA Platform.

Once personal information is obtained from you, ICOA dos not subsequently share it with any other third parties except as described in this Privacy Policy. However, such information may be shared with ICOA Affiliates as necessary.

5. PERSONAL INFORMATION SHARING WITH OTHER PARTIES:

ICOA takes care to protect your personal information and limits access to your personal information to those who need such information in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing such information. Personal information will only be shared in the following instances:

• Personal information is shared with third party identification services in order to prevent fraud. These services help ICOA confirm your identity by comparing the information that you provide us to public records and other third-party databases. These third-party service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
• ICOA shall only share information with Plaid in accordance with this Privacy Policy. Information shared with Plaid is treated by Plaid in accordance with its privacy policy, available at https://plaid.com/legal/. *Kindly double check*
• In addition, ICOA may share your personal information with other service providers in connection with ICOA’s business operations, bill collection, marketing, and technology services. ICOA requires that these service providers only use your information in connection with the services that they perform for ICOA and prohibit such service providers from selling your information to anyone.
• ICOA will also share your information with financial institutions with which ICOA partners in order to process payments and transactions that you authorize.
• ICOA may also utilize your personal information and share such information with law enforcement, government officials, or other third parties when ICOA is compelled to do so by subpoena, court order, or similar legal procedure or when ICOA believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the ICOA User Agreement or any other applicable policies.
• ICOA may share your information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ICOA’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ICOA about you or your ICOA Account is among the assets transferred.
• ICOA may also share your information with directly affiliated firms.

6. HOW ICOA PROTECTS AND STORES PERSONAL INFORMATION:

ICOA maintains (and requires its Affiliates and service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information that you share with ICOA. ICOA may store and process all or part of your personal and transactional information, including payment information, such as your encrypted bank account and/or routing numbers, in the United States and elsewhere in the world. ICOA employs efforts to protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws and regulations.

ICOA uses computer safeguards such as firewalls and data encryption, physical access controls to ICOA buildings and files, and restricts personal information access to authorized personnel only. Credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to ICOA staff

Despite these procedures, ICOA cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. In addition, ICOA notes that you also play a vital role in protecting your own personal information. When opening a ICOA Account and using the ICOA Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties and to immediately notify ICOA if you become aware of any unauthorized access of or use of your ICOA Account.

ICOA cannot ensure or warrant the security or confidentiality of information that you transmit to ICOA or receive from ICOA by internet or wireless connection, including email, phone, or SMS, since ICOA does not have any way of protecting information once it leaves and until it reaches ICOA. If you have a reason to believe that your data is no longer secure, please contact ICOA at the email address or telephone number listed at the end of this Privacy Policy.

7. HOW TO ACCESS OR CHANGE YOUR PERSONAL INFORMATION:

You are entitled to review, correct, or amend your personal information or to delete such information where such information is inaccurate. You may do this at any time by logging into your ICOA Account and clicking the user profile icon. Your right to update and amend personal information shall be limited where the burden or expense of providing you such access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than yourself would be violated.

If you close your ICOA Account, ICOA will mark your account in our internal database as ‘closed.’ However, your ICOA Account information will be maintained in our database. The retention of your personal information is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their ICOA Account and opening a new account. However, if you close your ICOA Account, your personal information will not be used by ICOA for any further purposes, nor will it be sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required la, rule or regulation, or in accordance with the terms of this Privacy Policy.

8. RETENTION OF PERSONAL INFORMATION:

ICOA stores your information securely throughout the life of your ICOA Account. ICOA will retain your personal information for a minimum of five (5) years, or as necessary to comply with ICOA’s legal and regulatory obligations, or as needed in order to resolve any disputes.

9. AUTOMATIC COLLECTION OF INFORMATION:

ICOA stores certain types of information automatically. This includes whenever you interact with your ICOA Account or the ICOA Platform and Website generally. The information that is generated through these interactions does not necessarily reveal your identity directly but may include information about the specific device you are using to access the ICOA Services, such as the hardware model, operating system version, web browser software and your Internet Protocol address.

ICOA automatically receives and records information on its server logs from your browser, including how you came to and used the ICOA Services, your IP address, device type and unique device identification number, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. ICOA may also collect information about how your device has interacted with our website, including pages accessed and links clicked. ICOA may use identifiers to recognize you when you enter the ICOA Platform or Website via an external link, such as a link appearing on a third-party site.

10. CHILDREN’S PERSONAL INFORMATION:

ICOA does not knowingly request or collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, ICOA will require the user to close his or her ICOA Account and will not allow buying or selling of cryptocurrencies. ICOA will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using the ICOA Services so that ICOA may take action to prevent access to the ICOA Services by such individuals.

11. CALIFORNIA PRIVACY RIGHTS:

If you are a California resident, you have the right to request information from ICOA regarding the manner in which ICOA shares certain categories of your personal information with third parties for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to ICOA at ICOA’s designated address and receive the following information:

• The categories of information that ICOA disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year;
• The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
• You are entitled to receive a copy of this information in a standardized format and the information will not be specific you individually. You may make such a request by emailing support@icoa.tech.

12. ICOA CONTACT INFORMATION:

If you have any questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us either by emailing us at support@icoa.tech, via our support selection within the app.