Evita Investments Inc. and Evita Pay Inc. U.S. Privacy Notice

Last updated August 2, 2024

The following Evita Privacy Notice, and GLBA Notice and Disclosure applies to you ifyou are an individual who resides in the United States and US Territories, and uses the services or websites of Evita Investments Inc. and/or Evita Pay Inc. (Evita).

Important information about procedures: To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

Whatthis meansfor you:When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents

Introduction
As part of our daily business operations, we collect personal information from our clients and prospective clients in order to provide them with our products, related support and services (collectively, “Services”), and to ensure that we can meet their needs when providing these products and services, as well as when providing them with any respective information. When you visit our website, social media pages, or other online properties (collectively “Sites”), we may also collect and use certain information about you.

Your privacy is of utmostimportance to us, and it is our policy tosafeguard and respect the confidentiality of information and the privacy of individuals. This Privacy Notice explainshow Evita collects, uses, and manages the personal information we receive from you, or via a third party, in connection with our provision of services to you or which we collectfrom your use of our services and/or our website. The Privacy Notice also informsyou of your rights with respect to the processing of your personal information and the choices you can make about what information you share.

The Privacy Notice applies to all products and services offered or provided by Evita to U.S. clients, potential U.S. clients, and U.S. website visitors (including any services, terms, or communications that reference, display, or link to this Privacy Notice), except where a particular product, service, or jurisdiction has a separate privacy notice. The personal information we collect, use, and disclose will vary based on how you interact with Evita, our products,and our websites. We have done our utmost to makethis notice comprehensive and understandable, but appreciate that it is complex, so pleasecontact admin@evita.one if you have questions.

Certain individuals may be provided with additional privacy notices as described below:

• Evita Clients – When you signup for an account with us, we may collect and use your information to facilitate the provision of services pursuant to our GLBA Notice,as applicable. Federal law requires us to provide notice to certain customers to explain what personal information we collect, how we disclose it, and how consumers may limit information sharing. These privacy practices are subject to our GLBA Notice, which we strongly suggest you review.
• Notice to California Residents – If you are a resident of California, please see our California Consumer Privacy Statement for additional relevant information.
• You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we disclose information about you. Please see our State Specific Privacy Statement for more information on whether you have additional rights or protections under other state privacy laws.

Key Terms Used Throughout This Notice
The following terms are defined as follows:

“EvitaAccount” meansa user-accessible account offered via Evita Pay Inc. and/or Evita Investments Inc.

“We”, “Our”, and “Us” refers to Evita Pay Inc. and/or Evita Investments Inc. dba Evita.

“Personalinformation” or “personaldata” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural, or social identity of you as a natural person.

“User” and “You” refers to our clients, prospective clients, and individuals who visit our Site or use our Services.

"Biometric data" means data generated by automatic measurements of an individual's biological characteristics, such as a facial geometry or other unique biological patterns or characteristics that are used to identify a specific individual.

"Identified or identifiable natural person" means a personwho can be readily identified, directly or indirectly.

Information we may collect aboutyou

Categories Of Personal Data Evita May Collect About You
●      Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, uniquepseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Securitynumber, driver’s license number, passport number,and other similar identifiers;
●      Customer and Payment Information: Signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, on-chain transactions, and other financial information;
●      Protected Classifications: characteristics of protected classifications under State or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status;
●      Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
●      Biometric Data;●      Online Activity: Internet and other electronic network activity information, including, but not limited to information regarding your interaction with websites, applications, or advertisements;
●      Geolocation Data;●      Sensory Information: audio, visual, and similar information;
●      Employment Information: professional or employment-related information;
●      Inferences: inferences drawn from any of the information identified above to create a profileabout you reflecting your preferences, characteristics, behavior, and attitudes.

Purposes For Processing Personal Data●      To comply with laws and regulations that Evita maybe subject to;
●      Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
●      Auditing related to a currentinteraction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifyingpositioning and quality of ad impressions, and auditing compliance;
●      Short-term, transient use,including, but not limited to, the contextual customization of ads shown as part of the same interaction;
●      Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
●      Debugging to identify and repair errors that impair existing intended functionality;
●      Undertaking internal research for technological development and demonstration; and/or
●      Undertaking activities to verify or maintain the quality or safety of a serviceor device that is owned, manufactured, manufactured for, or controlled by us, and to improve,upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We may also, from time-to-time, use personal information provided by you through your use of the services and/or through client surveys to help us improve our products and services. It is our legitimate interest to use your personal information in this way to try toensure the highest standards when providing you with our products and services and to continueto be a market leader within the cryptocurrency financial service industry.

This may include:

●      To tailor specific communications and promotions according to your preferences;
●      To provide you with access to the services;
●      To serve the functions of the Sites;
●      To manage everyday business needs, such as administering and improving the Sites;
●      To analyze the performance and functioning of the Sites;
●      To analyze how you use the Sites and to perform other market research;
●      For internal operations, including troubleshooting, testing, and analytics; and
●      To assist us in developing new products and improving our Services.

Evita may also use or disclose de-identified information that is not reasonably likely to identifyyou for commercially legitimate business purposes.

Sharing Of Personal Data With Third PartiesWe may share your Personal Data with third parties under the following circumstances:

●      To comply with laws and regulations that Evita maybe subject to;
●      When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connections with an investigation or suspected or actual illegal activity;
●      If necessary to protect the vital interests of a person;
●      If thereis a duty to disclose;
●      If our legitimate business interests require disclosure;
●      To protect our property, services, and legal rights;
●      To enforce our Terms of Service;
●      To prevent fraud against Evita, our affiliates, business partners, or authorized users;
●      To support auditing, compliance, and corporate governance functions; or
●      At your request or with your consent or to those described elsewhere in this notice. .

Evita will make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority. Under such circumstances, Evita will notify the third party regarding the confidential nature of any suchinformation. Evita will not disclose your confidential information to a third party, except:

●      We are required to do so by law or legal process;
●      To the extent that we are required or permitted to do so pursuant to any applicable laws, rules, or regulations;
●      To law enforcement authorities or other government officials, as necessary.

Categories Of Third Parties With Which Data Is SharedAs part of using your personal information for the purposes set out above, Evita may disclose your personal information to the following:

●      Any memberof Evita, which means that any of our affiliates and subsidiaries may receive such information;
●      Any of ourservice providers, specialist advisors, and business partners who need access to perform their services for/with Evita, these services may include but are not limited to administrative, financial, commercial, legal, tax, compliance,

insurance, IT, debt-recovery, marketing, analytics, research, or other advisory services.

If Evita discloses your personal information to service providers and business partners in order to perform the services requested by clients, such providers and partners may store your personal information within their own systems in order to comply with their legal and otherobligations. These third parties are notauthorized by us to use or disclose the information, except asnecessary to perform services on our behalf or comply with legal requirements. These third parties have no independent rights to the data.

Evita requires service providers and business partners who process personal information to acknowledge the confidentiality of this information and undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws.

Selling Or Sharing Of Personal InformationEvita does not sell personal data to any third parties for monetary consideration and has not done so in the preceding 12 months. We do not sell personal information.


Biometrics Policy
By using Evita’s services, accepting our privacy notice, and/or accepting our terms of service, you give your written consent to the collection, processing, usage, and storage of your Biometric Data.

You release in favor of Evita any claims related to collection, processing, usage, and storage your Biometric Data. This includes any past or priorclaims as well as any claims that may arise in the future related to youruse of Evita’s services

Biometric Data CollectionEvita collects, uses, stores, and processes Biometric Data to verify or confirm your identity, both when you initially open or verify your Evita account and at any point thereafter as deemed necessary by Evita or required by law or regulation. This includes

comparing “selfie” photos that you submit to other forms of identification, such as a driver’slicense or passport or similar identification document.

Biometric Data means any data generated from electronic measurements or scans of an individual's biological characteristics, such as facial geometry, or other unique biological patterns or characteristics that can be used to identify a specificindividual.

Retention ScheduleIn circumstances where we retain Biometric Data, we will permanently destroy an individual's Biometric Data once the purpose for collecting or obtaining such Biometric Data is satisfied, as determined by us, but no later than a maximum of three years of collection, unless further retention is required for account security, regulatory compliance or otherwise required by law.

Biometric Data SecurityWe shall use a reasonable standard of care to store, transmit and protect from disclosure any Biometric Data collected.

Biometric Data DisclosuresWe may disclose an individual's Biometric Data to third-party vendors and/or licensors in order to facilitate the provision of our products and services. This includes third-party identity verification services. Those products and services requiring Biometric Data processing shall include future products and services that Evita may choose to provide after the initial collection of Biometric Data.

We do not further disclose Biometric Data unless:

●      The individual or the individual's legally authorized representative consents to the disclosure;
●      The disclosure is requiredby applicable law or regulation; or
●      The disclosure is requiredpursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

We do not sell, lease, trade, or otherwise profit from Biometric Data.

Children's Personal Information And Online Privacy(COPPA)The Children's Online Privacy Protection Act (COPPA) is intendedto provide parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowinglycollect information from, children under theage of 13.

Our products and services are not directed to persons under the age of 18, hereinafter “Children” or “Child,” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we willtake legally permissible measures to remove that information from our records. Evita will require the user to close his or her account and will not allow the use of our products and services.

If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us at admin@evita.one and you may request to exerciseyour applicable access, rectification, cancellation, and/or objection rights. If you are under the age of 18, please do not provide any personal information through the Sites or Services.

For additional information on COPPA protections refer to the Federal Trade Commission's website.

GLBA Notice And Disclosure
What Does Evita Do With Your Personal Information?
Financial companies choose how they disclose your personal information. Federal law gives consumers the right to limit some but not all disclosures. Federal law also requires us to tell you how we collect, disclose, and protect your personal information. Please read this notice carefully to understand what we do.

All financial companies need to disclose customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can disclose their customers’ personal information; the reasons Evita chooses to disclose, and whether you can limit this disclosure.

Evita collects your personal information, for example, when you:

●      Interact with support, Evita website or we communicate with you;
●      Apply for any Evita product or service;
●      Open an account;
●      Make deposits or withdrawals from your account;
●      Give us your income information;
●      Provide employment information or your employment history;
●      Give us yourcontact information;
●      Show yourgovernment-issued ID or your driver's license.

We also collect your personal information from third parties, such as credit bureaus, affiliates, or other companies that provide services to Evita (e.g. KYC service providers).

Federal law gives you the right to restrict the sharing of your personal information in the following specific situations:

●      Sharing yourcreditworthiness information with our affiliates for their everyday business purposes.
●      Allowing our affiliates to use your personal information for marketing purposes.
●      Sharing yourpersonal information with non-affiliated companies for their marketing purposes.

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law



California Consumer Privacy Notice
This California Privacy Notice (“California Notice”) is for California residents, and describes how Evita collects, uses, and disclosesyour personal information. The information on this notice provides details on how werespond to and implement processesto uphold California State laws.

Any terms defined in the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (“CCPA”) have the samemeaning when used in this California Notice. The CCPA does not apply to personal information we collect as part of our current or former client relationship with you pursuant to other privacy laws such as the federalGramm-Leach-Bliley and Fair Credit Reporting Acts, and the California

Financial Information Privacy Act. For more information about what information is exempt from disclosure, see the section titled ‘Exemptions’ below.

Definitions“Personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This information may also be referred to in this California Notice as “personal data.”

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list ofall third parties to which we have disclosed certain personal information duringthe preceding year for those third parties’ direct marketing purposes.

“Customers” are defined as individuals who access or use our services.


Sources Of Personal InformationWe gather various types of personal information from our customers from a range of sources, such as:

●      information you give us when you sign up for, or otherwise use, our Services;
●      information we receive from our affiliates and third parties;
●      Information thatis in the public domain;
●      information we collect automatically through cookies and similar technologies.

Purpose For Collection And Disclosure Of Personal InformationWe’ve collected and disclosed the below categories of personal information to create, develop, operate, deliver, and improve our services; to communicate with you; to comply with applicable laws and regulations; to ensure the safety, security and integrity of our Services; and for business and commercial purposes. Evita does not collect, use, or disclose sensitive personal information for purposes other than those specified in this Notice, to provide the Services, or as permitted under applicable law. Evita does not sell personalinformation. For more information about how Evitamay use your personal

information, please refer to other potentially applicable notices, such as the Global Privacy Notice.


Collection and Disclosure of Sensitive Personal InformationIn the past 12 months, we’ve collected and disclosed the following categories of sensitive personal information, with the following categories of third parties:



Selling or Sharing of Personal InformationIn the past 12 months, we may have shared identifiers with third party analytics providers, advertising partners, and ad networks for analytics and advertising purposes. Evita does not sell your personal information.




RightsAs a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Rightto Know
You have a right torequest the following information about ourcollection, use and disclosure of your personal information over the prior 12 months, and ask that we provide you witha copy of the following:

●      Categories of personal information we have collected, sold, or shared about you;
●      Specific piecesof personal information we collected about you;
●      Categories of sources from which we collect personal information;
●      The business or commercial purpose for collecting, selling, or sharing the personal information;
●      Categories of third parties with whom we disclose that personal information;
●      Categories of personal information disclosed about you for a business purpose;
●      Categories of personal information that each recipient received.

Twice within a twelve month period, you havethe right to request the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Right to Correct
You have a right to request that we correct inaccurate personal information maintained about you.

Right to Delete
You have a right to request that we delete personal information, subject to certain exceptions.

Right to Opt out of Selling or Sharing
You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so. Evita does not sell personal information.

Right to Non-Discrimination
We will not discriminate against you for exercising any of these rights

Rightto Portability
You have the right to receive this information in a format,where feasible, that is portable, usable, and allows you to transmit the personal information without impediment.

Other Rights That May Be Available in Some Circumstances Rightagainst automated decision making
A prohibition against a business making decisions about a consumer based solely on automated processing.

Private right of action
The right for a consumer to seek civil damages from a business for violations of a statute.

Other California Privacy Rights
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Lightlaw) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

ExemptionsPlease note that certain types of personal information collected or maintained by a coveredbusiness are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases, no obligations, under theCCPA with regard to the followingtypes of personal information:

●      Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and implementing

regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 commencing with Section 4050 of the California Financial Code)
●      Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity orbusiness associate pursuant to the Health Insurance Portability and Accountability Act of 1996.

Please note that the description of the CCPA set forth in this California Notice is a summary of only certain aspects of the CCPA and is not and should not be considered a complete description of the CCPA. In addition to what is described above, the CCPA includesother exemptions that apply to particular types ofpersonal information and particular businesses, as well as additional situations where a coveredbusiness is not required to honor a consumer’s request to delete the consumer’s personal information.


OtherState 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 certain rights, which may include some or all of the following depending on your location:

●      Confirm whether we process their personal information.
●      Access and delete certain personal information.
●      Correct inaccuracies in their personalinformation, 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, please contact admin@evita.one if you have any questions.

Exercising RightsTo exercise your rights described above, please submit a request to us by:

By email, at admin@evita.one

Only you or an agent who is authorized to act on your behalf (and registered with the California Secretary of State, if you are a California resident) may make a Request.

●      You may only make two Requests within a 12-month period.
●      Each Request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
●      We willmake every effort to verify your identity using your email address, but we may request additional information. If an authorized representative is making the requeston your behalf, we require documentation showing that the representative has such authority. Describe your Request with sufficient detail that allows us to properly evaluate and respond to it.
●      We will not respond to your request or provide you with personal information if we are unable to verify your identity, or to verify the authority for theperson making the request as your agent.
●      We will use personal information provided in a verifiable consumer Request to verify your identity or authority to make the Request, and not for any other purpose.

To appeal a decision regarding a consumer rights request, please use the same contact detailsas above.

Verified RequestTo help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your Evita account, one or more recent transactions, and the last four digits of one or more of the cards associated with your account.

If you have never had an account with us and you request access to or deletion of your personal information, there is likely no reasonable method by which we can verify your identity to the level of certainty required.The reason for this is that Evita does not maintaininformation about non-account holders in a way that is linked to named actual persons(and historically has not linked IP addresses, device identifiers or other information collected by automated means to namedactual persons).

In addition, if you askus to provide you with specific pieces ofpersonal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

For questions or concerns about our privacy notices and practices, please contact us as described in the Exercising Rights section above.

Response Timing And FormatWe will respond to a verifiable consumer request within 45days of its receipt. If we requiremore time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account.If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Evita will not charge a fee to process or respond to your verifiable consumer request, but reservesthe right to request a fee if the request is excessive, repetitive, or manifestly unfounded. If we determine that therequest warrants a fee, we will tell you why we
made that decision and provide you with a cost estimate before completing your request.


Changes To The Privacy Notice
You may request a copy ofthis Privacy Notice from us using the contact details set out above. Where changesto this Privacy Notice will have a fundamental impact on the nature of our processing of your personal data or otherwise have a substantial impact on you, we willgive you sufficient advance notice sothat you have the opportunity to exerciseany rights you may have under applicable law (e.g., to object to the
processing).

We reserve the right to make changes to our Privacy Notice at any time consistent with applicable local laws. Such changes, as long as they do not have a fundamental impact on the nature of our processing of your personal data or, otherwise, have a substantial impact on you, will be posted onthis page. We encourage you to review the web site and the Privacy Notice periodically for any updates or changes.