Bitrabo Limited (hereinafter referred to as "we", "us", "our", "Website", "App", "Bitrabo" or "Bitrabo Limited") respects the privacy of every individual who visits our website or uses our services. This Privacy Policy (“Policy”) governs your use of the website located at www.bitrabo.com and any services or products offered by Bitrabo (collectively, the “Services”).

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This Policy describes our practices regarding the collection, use, storage, and disclosure of information that identifies, relates to, or could reasonably be associated with you, your household, or your device (“Personal Data”). Personal Data does not include publicly available information from government records, deidentified or aggregated data, or information excluded from the scope of applicable data privacy laws, such as the General Data Protection Regulation (GDPR) or California Consumer Privacy Act (CCPA). By accessing or using the Services, you consent to our collection, use, and disclosure of your information as described in this Policy. If you do not agree with this Policy, you should not use the Services.

1. Information We Collect

We collect information to provide, personalize, and improve our Services. The types of information we collect depend on how you interact with our Services. Below are the categories of Personal Data we have collected over the past 12 months:

Category	Examples	Collected?
A. Identifiers	Name, alias, email address, postal address, phone number, account username, IP address, device identifiers, cryptocurrency wallet addresses, or other similar identifiers.	Yes
B. Protected Classifications	Race, sexual orientation, religion, disability, veteran status, or genetic information.	No
C. Commercial Information	Purchase history, subscription details, services considered, or cryptocurrency transaction records.	Yes
D. Biometric Information	Fingerprints, faceprints, voiceprints, iris scans, or health data.	No
E. Internet or Network Activity	Browsing history, search history, interactions with websites, applications, or advertisements.	Yes
F. Geolocation Data	Physical location or movements (e.g., approximate location based on IP address).	Yes
G. Sensory Data	Audio, visual, thermal, or olfactory information.	No
H. Professional or Employment Information	Job history or performance evaluations.	No
I. Non-Public Education Information	Education records under the Family Educational Rights and Privacy Act (FERPA).	No
J. Inferences	Profiles reflecting preferences, behaviors, or interests based on collected data.	Yes

We collect Personal Data in the following ways:

• 1.1. Directly from You: When you provide information voluntarily, such as:

  • Creating or registering an account.

  • Subscribing to newsletters, participating in surveys, contests, or promotions.

  • Providing cryptocurrency wallet addresses for transactions or reward programs.

  • Contacting customer support or submitting inquiries.

  • Posting user-generated content, such as comments, reviews, or forum posts.

• 1.2. Automatically: When you interact with our Services, we collect information such as:

  • IP address, browser type, device type, operating system, and settings.

  • Browsing behavior, such as pages visited, time spent, and links clicked.

  • Approximate geolocation based on IP address for location-based services.

  • Email interaction data (e.g., whether you opened or clicked an email).

  • Data collected via cookies, web beacons, or similar technologies (see Section 4).

• 1.3. From Third Parties: We may receive information from:

  • Service providers, such as analytics, advertising, or payment processors.

  • Social media platforms, if you connect your account to our Services.

  • Business partners offering joint services or promotions.

You may choose not to provide certain information, but this may limit your access to some features of the Services.

2. How We Use Your Information

We use your information to operate, enhance, and personalize our Services. Specific purposes include:

• 2.1. Service Delivery: To manage accounts, process transactions, deliver content, and provide customer support.

• 2.2. Personalization: To tailor content, recommendations, and advertisements based on your interests and usage patterns.

• 2.3. Marketing and Communications: To send newsletters, promotional offers, or updates, with your consent where required.

• 2.4. Analytics and Improvement: To analyze usage trends, diagnose technical issues, and improve the functionality and user experience of our Services.

• 2.5. Security: To detect and prevent fraud, unauthorized access, or other illegal activities.

• 2.6. Legal Compliance: To comply with legal obligations, enforce our Terms and Conditions, or protect the rights, safety, or property of Bitrabo, our users, or third parties.

• 2.7. Reward System: To manage and administer our Reward System, including tracking eligible activities and distributing rewards.

We rely on legal bases such as your consent, our legitimate interests, or contractual necessity to process your Personal Data, as permitted by applicable law.

3. Disclosure of Your Information

We may share your Personal Data with the following parties under strict conditions:

• 3.1. Service Providers: With third-party vendors (e.g., hosting, analytics, payment processors, or email platforms) who process data on our behalf under data processing agreements that ensure confidentiality and compliance with applicable laws.

• 3.2. Affiliates: With our corporate affiliates, who are required to adhere to this Policy.

• 3.3. Advertisers: With advertising partners to deliver targeted ads, measure ad performance, or track conversions. You may opt out of such sharing by emailing [email protected].

• 3.4. Business Partners: With partners offering joint services or promotions, under agreements that protect your data.

• 3.5. Other Users: Information you post publicly (e.g., comments, reviews) may be visible to other users.

• 3.6. Legal Requirements: When required by law, court order, or government authority, or to protect our rights, safety, or property, or that of our users or others.

• 3.7. Business Transfers: In connection with a merger, acquisition, or asset sale, where your data may be transferred to a third party under equivalent privacy protections.

• 3.8. Anonymized Data: We may share aggregated or deidentified data that cannot reasonably identify you for analytics, research, or marketing purposes.

We do not sell your Personal Data for monetary compensation, but certain sharing with advertising partners may be considered a “sale” under laws like the CCPA. You may opt out of such sharing as described in Section 10.

4. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar technologies to enhance your experience and collect usage data.

• 4.1. Types of Cookies:

  • Essential Cookies: Required for core functionality, such as maintaining user sessions or enabling secure transactions.

  • Performance Cookies: Collect data on site performance and user interactions to improve our Services.

  • Functional Cookies: Enable personalized features, such as remembering your preferences.

  • Advertising Cookies: Used by third-party advertisers to deliver targeted ads based on your interests.

• 4.2. Consent: We provide a cookie consent tool upon your first visit to our website, allowing you to manage preferences for non-essential cookies. You may also control cookies through your browser settings.

• 4.3. Opting Out: Disable cookies via your browser or opt out of targeted advertising at Google Ads Settings, Network Advertising Initiative, or Your Online Choices (EU). Note that disabling cookies may impact Service functionality.

• 4.4. Flash Cookies: Some features may use Flash cookies, which can be managed at Adobe Flash Player Settings.

For more information about cookies, visit www.aboutcookies.org.

5. Social Media Features and Widgets

Our Services may include social media features, such as “Like” or “Share” buttons for platforms like Facebook, Twitter, or LinkedIn. These features may collect your IP address, page visits, or set cookies to function properly. Your interactions with these features are governed by the privacy policies of the respective platforms. We are not responsible for their practices.

6. Third-Party Links

Our Services may contain links to third-party websites or services. We are not responsible for their privacy practices or content. We encourage you to review their privacy policies before sharing Personal Data.

7. Security of Your Information

We implement industry-standard security measures to protect your Personal Data, including:

• 7.1. Encryption: Secure Socket Layer (SSL) and Transport Layer Security (TLS) for data transmission.

• 7.2. Access Controls: Limiting access to authorized personnel with a need-to-know basis.

• 7.3. Security Audits: Regular assessments to identify and mitigate vulnerabilities.

No method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security, and you use our Services at your own risk.

8. Data Retention and Account Termination

We retain Personal Data only as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, or enforce agreements. Retention periods vary based on the data’s purpose and legal requirements. For example:

• 8.1. Account Data: Retained while your account is active and for a reasonable period thereafter to comply with legal or business needs.

• 8.2. Transaction Data: Retained as required by tax or financial regulations.

• 8.3. Anonymized Data: May be retained indefinitely for analytics purposes.

To close your account, visit the account settings page or contact us at [email protected]. After account closure, we may retain certain data as required by law or for legitimate business purposes. If you revisit our Services, cookies or similar technologies may still collect data unless you adjust your browser settings.

9. Advertising and Analytics Platforms

We use third-party platforms to deliver advertisements and analyze usage.

• 9.1. Google Ads: Used to serve targeted ads, which may track your browsing across sites. Opt out at https://adssettings.google.com/partnerads.

• 9.2. Google Analytics: Collects data on site usage. Opt out using the Google Analytics Opt-out Browser Add-on.

• 9.3. Other Platforms: Additional services may be used, disclosed via our cookie consent tool or this Policy.

Opting out of personalized ads does not eliminate all ads; you may see non-personalized ads. By using our Services, you consent to these technologies as described.

10. Your Data Protection Rights

Depending on your location, you have the following rights regarding your Personal Data:

• 10.1. Right of Access: Request access to your Personal Data.

• 10.2. Right to Rectification: Request correction of inaccurate or incomplete data.

• 10.3. Right to Erasure: Request deletion of your data, subject to legal exceptions.

• 10.4. Right to Restriction of Processing: Limit how we process your data under certain conditions.

• 10.5. Right to Data Portability: Receive your data in a structured, machine-readable format.

• 10.6. Right to Object: Object to processing for purposes like direct marketing.

• 10.7. Right to Withdraw Consent: Withdraw consent where processing is consent-based.

• 10.8. Right to Non-Discrimination: We will not discriminate against you for exercising these rights.

To exercise these rights, contact us at [email protected]. We may verify your identity and respond within legally required timeframes (e.g., 30 days for GDPR). EU residents may lodge complaints with their local data protection authority.

11. California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

• 11.1. Right to Know: Request details about the categories, sources, purposes, and recipients of your Personal Data.

• 11.2. Right to Delete: Request deletion, subject to exceptions.

• 11.3. Right to Opt-Out of Sale: Opt out of the “sale” of your Personal Data (e.g., sharing with advertisers). Email [email protected] to opt out.

• 11.4. Right to Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

To exercise these rights, contact us at [email protected] or https://www.bitrabo.com/contact/. We will verify your identity and respond within 45 days, extendable by 45 days if needed.

12. Children’s Privacy

Our Services are not intended for individuals under 16. We do not knowingly collect Personal Data from children under 16. If we discover such data, we will delete it promptly. Contact us at [email protected] if you believe we have collected such data.

13. International Data Transfers

Your Personal Data may be transferred to, stored, or processed in countries outside your residence, including the United States, where data protection laws may differ. We use safeguards like Standard Contractual Clauses (SCCs) for transfers to non-adequate jurisdictions under GDPR. Our cloud providers (e.g., Amazon Web Services, Google Cloud) have data processing agreements compliant with applicable laws.

14. Do Not Track Signals

Some browsers transmit “Do Not Track” (DNT) signals. Our Services do not currently respond to DNT signals, as there is no industry-standard protocol. You may manage tracking preferences via our cookie consent tool or browser settings.

15. Changes to Our Privacy Policy

We may update this Policy to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated Policy on our website with a revised “Last Updated” date, or via email or other communications as required by law. Your continued use of the Services after such changes constitutes acceptance of the revised Policy.

16. Contact Us

For questions, concerns, or requests regarding this Policy or our data practices, contact us at:

• Email: [email protected]

• Website: https://www.bitrabo.com/contact/

• Mail: Bitrabo Limited, Harrys 1, Royal Pine, Lekki, Nigeria

Our Data Protection Officer can be reached at [email protected] for matters related to privacy and data protection.

By using the Services, you acknowledge that you have read, understood, and agree to be bound by these Privacy Policies.