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1. Introduction

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1.1 This Privacy Policy describes how Driftwood Group (the “Company“) collects, uses, processes, discloses, shares, transfers, and protects the information you provide on the Driftwood Group website. This Privacy Policy constitutes a part of the Terms and Conditions of the Company (“T&Cs“). The terms used in this Privacy Policy shall share the same definition as those stipulated in the T&Cs except for others indicated herein.

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1.2 The Company respects and values your privacy as well as the integrity of the information you have provided and/or permitted the Company to collect. The Company will endeavor to follow industry standards to ensure the security and confidentiality of your Personal Information when you use the Company Services or access the Company’s Platform.

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1.3 When accessing, registering, downloading, using, clicking, or engaging in any Services provided on the Company’s Platform, you are strongly advised to carefully read, acknowledge, understand, and accept all terms stipulated in this Privacy Policy. The Company will not use your information, in any shape or form, for any other purpose that has not been indicated in this Privacy Policy or the T&Cs without providing you prior notification or obtaining consent from you.

 

1.4 This Privacy Policy provisions from the Data Protection Act, 2021 (“DPA”) of the British Virgin Islands. It has also incorporated other relevant provisions of from the General Data Protection Regulation (“GDPR“), specifically following its Personal Information Processing rules within the European Economic Area (EEA). 

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This Privacy Policy shall inform you about the following among several other matters:

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• Acceptance of the Privacy Policy

• Personal Information collected by the Company

• How the Company collects Personal Information

• How the Company uses Personal Information

• How the Company stores Personal Information

• How long the Company retains Personal Information

• Cookies

• Sharing your Personal Information

• Third-Party Collection of Personal Information

• Your Legal Rights

• Rights of the residents of the European Economic Area (EEA)

• Limitations

• Updates or amendments to the Privacy Policy

• How to contact the Company

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2. Acceptance of the Privacy Policy

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By accessing, using, or engaging in the Company’s Services, you indicate and confirm that you have agreed to the terms of this Privacy Policy. The Company shall not use your Personal Information for any other purpose that has not covered in this Privacy Policy or the T&Cs without providing you prior notification or obtaining your consent.

If you do not agree, either partially or wholly, to this Privacy Policy, you must immediately discontinue accessing, using, or engaging in the Company’s Services and Platform.

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3. Personal Information Collected

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For the purposes of this Privacy Policy, Personal Information is information that can be used to identify, describe, relate, or associate with a particular individual. The following are the types of information the Company collects and stores when you use the Company’s Services:

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3.1. Information collected by the Company for Compliance and Anti-Money Laundering Purposes

To allow the Company to comply with domestic and international industry standards, government rules and regulations, particularly Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) rules, and Counter-Terrorist Financing (CTF) regulations, the Company is required to collect your Personal Information from identification documents such as your passport, national identification card, driver’s license, tax identification, and visa. Other documents the Company may use include, but are not limited to, your proof of the address, source of fund declaration, purpose and source of wealth etc.

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3.2. Information collected by the Company during use the Company’s Services

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(a) Usage Information: When you engage or use the Company’s Services, the Company will monitor and track your information in relation to your usage of the Company’s Services such as your IP address, phone number, the type of device you use to access the Company’s Platform, device information, operating system and hardware settings, browser type, and network operator. This information shall either be directly obtained by the Company or through third-party service providers.  The Company collects this type of information to ensure that its interface and/or Platform is seamlessly accessible for all users around the world.

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(b) Communication Information: You hereby agree that the Company is entitled to collect and use the Personal Information you have provided on the Company’s Platform or generated through your usage of the Company’s Services for the purpose of being able to communicate with you through messages, requests, emails, telephone conversions, voicemails, live chats, file attachments in connection with your transactions on the Company’s website or online platforms, or any other information related to your contact with the Company.

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(c) Financial Information: You hereby agree that, for the purposes stipulated in this Privacy Policy, the Company is entitled to collect and use the information contained in or related to your financial information when you use the Company’s Services. This includes, without limitation, your transaction history such as your initial deposit amount, your withdrawal requests, your digital wallet address (es), your investment details etc. The Company collects this financial information to monitor suspicious financial activities to protect users from fraud, resolution of legal cases, as well as any other purposes disclosed in this Privacy Policy.

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4. Methods of Collection of Personal Information

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4.1. Information automatically collected by the Company:  The Company will collect and process Personal Information automatically provided by you under the following situations:

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(a) when you register an account, log in, or visit the Company’s Website;

(b) when you subscribe to the Company’s newsletter;

(b) when you voluntarily complete any user survey or provide feedback to the Company via emails or any other electronic channels;

(c) when you use browser cookies or any other relevant software upon visiting the Company’s Website; and

(d) other situations where the Company may automatically collect your information as described in this Privacy Policy or the Company’s T&Cs.

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4.2. Information collected by third-parties: The Company shall collect your Personal Information from third parties as required or permitted to the extent of applicable laws. Information from the third-party sources may include, but may not be limited to, public databases, credit bureaus, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.

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4.3. Anonymized & Aggregated Data: The Company will also collect other Information in the form of anonymized and aggregated information where all information shall be combined and then removed of personally identifiable information, making it unusable for the identification of specific individuals. The Company may use anonymized or aggregate users’ information for the purposes stipulated in this Privacy Policy at any time, including gaining better understanding of users’ needs and behaviors, conducting business intelligence and marketing initiatives, and detecting security threats. The Company reserves the right to implement innovative technologies as they become available to be used for strategic planning and operational processes.

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5. How the Company may use Personal Information

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Your Personal Information shall be made available to the Company, affiliates of the company, and/or within the Company’s group of companies. This will include, but not be limited to, the employees and/or any persons or third parties working for the Company who are responsible for using and protecting your Personal Information. The Company may use and process your Personal Information for the following purposes or in the following ways:

 

5.1. To provide the Company’s Services: The Company uses Personal information, either collected or delivered, in order to maintain and provide efficient Services (including, but not limited to, processing transactions), to improve the efficiency of day-to-day Services, and to verify your identity. The Company uses IP addresses and unique identifiers stored in your device’s cookies to help the Company authenticate your identity and activities and provide the Company’s Services.

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5.2. To protect users: The Company uses the information collected to protect on the Company’s Platforms, Users’ accounts, and archives. The Company also uses IP addresses and cookies to detect suspicious activities and to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (“DDoS”) attacks.

 

5.3. To comply with regulations and compliance for the Company’s legitimate interests: The Company shall use the information in compliance with the Company’s legal obligations, global and local industry standards, government requests, and the Company’s AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e. to protect the vital interests of the users or other natural persons, to fulfil the purpose of public interest, or to pursue the Company’s reasonable interests), the Company may use and process your Personal Information without obtaining your consent.

 

5.4. For measurement, research and development purposes: The Company actively measures and analyzes your information to understand the way you use and interact with the Company’s Services. This review is continuously conducted by the Company’s operation teams to continuously improve the Company’s Platforms’ performance and to resolve issues with user experience. In addition, the Company uses such information to customize, measure, and improve the Company’s Services, administration, content and Website layout, and to develop new services for you.

 

5.5. For communication purposes: The Company uses your Personal Information, collected or derived from your communication devices or your email address, to interact with you directly, to provide you with necessary support, and/or to keep you informed of logins, transactions, account security details, as well as other aspects. All direct communications shall be appropriately maintained at by the Company, or the Company’s service providers, to be reviewed for accuracy, retained as evidence, or used to perform other statutory requirements or other obligations as stipulated in this Privacy Policy and the T&Cs.

 

5.6. To enforce T&Cs: Personal Information is also used to continuously and actively enforce the Company’s T&Cs among the Company’s users. Activities in this regard include, but are not limited to, reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties accordingly. In light of this, the Company reserves the right to suspend or terminate any of the Company’s Services to any Users found to be engaged in any activities that violate the Company’s T&Cs.

 

5.7. For marketing and advertising: The Company will share your Personal Information with marketing partners for the purposes of targeting, modelling, and/or identifying analytics as well as marketing and advertising.

 

5.8. For Rebates: The Company shall share the Personal Information collected from you, including, but not limited to, your Identification Information and Transaction Information, with your referrer for the purposes of rebates and other benefits.

 

5.9. For other purposes: The Company shall not use your Personal Information for purposes other than the purposes stipulated in this Privacy Policy without your prior consent. If the Company needs to process or use your Personal Information for other purposes, the Company shall notify and request for your consent to use such information.

 

6. Storage of Personal Information

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6.1 The Company shall take great care in implementing and maintaining the security of its Services as well as that of your Personal Information. The Company employs procedures and policies that incorporate industry best practices to ensure the integrity of your Personal Information and to prevent instances of unauthorized use. 

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6.2 It is, of course, impossible to fully guarantee the security of your Personal Information and while the Company takes reasonable steps to safeguard your Personal Information, it cannot be held responsible for the acts committed by those who gain unauthorized access or abuse your information and services.  It is therefore recommended that you independently take safety precautions to protect your Personal Information, particularly your credential information such as your username and password. You agree that the Company shall not be liable for any information leakage and other losses not caused by the Company’s intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.

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7. Retention of Personal Information

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The Company is be required by applicable laws and regulatory requirements to retain certain information, including Personal Information of users, users’ profiles, identification verification materials, information relevant to AML/KYC/CTF procedures, account information, account agreements, and other agreements between the Company and third-parties, account statements, and other records.  Such records shall generally be retained as required by law for the minimum amount of time necessary to accomplish the purpose for which it is collected; and thereafter no longer than is permitted under the Company’s information retention policy.  However, even after you deactivate your account, the Company may retain copies of information about you and any transactions or services which you may have participated in for a period of time that is consistent with applicable laws, the applicable statute of limitations or as we believe is reasonably necessary to comply with applicable laws, regulations, legal procedures, or governmental requests in order to detect or prevent fraud, collect fees owed, resolve disputes, address problems with the Company’s Services, assist with investigations, enforce any of the Company’s T&Cs and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable laws.

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8. Cookies

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8.1 The Company shall use cookies and other technologies or methods of web analysis to gather, store, and track certain information related with your access to and activities through the Services, including when you visit the Company’s website.  

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8.2 The term “cookie”, as used herein, shall be deemed to be a small piece of information that a website assigns to your device while you are viewing a website. Cookies are beneficial and may be used for various purposes. including allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. 

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8.3 The Company’s Website shall use the following types of cookies:

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(a) Strictly Necessary Cookies: These cookies are essential to enable you to log in, navigate a website, and use its features or to provide a service requested by you. The Company shall not need to obtain your consent in order to use these cookies.

(b) Functionality Cookies: These cookies allow the Website to remember choices you make (such as your username, language, or the region you reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites.

(c) Performance cookies: These cookies collect information about how you use a website, for example, which pages you go to most often, record difficulties you may experience while using the Website such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the Website.

(d) Targeting Cookies or Advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. It may be the case that targeting or advertising cookies shall be linked to the sites functionality provided by the other organizations.

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8.4 You may remove these cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Company’s Services may not operate properly, and your online experience may be limited.

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9. Sharing Personal Information

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The Company shall not rent, sell, or disclose your Personal Information to any third parties, except to those who require access to the information to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it. The Company may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:

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9.1. to third parties in order to administer or process a transaction, or Services you have authorized or requested, or in the context of facilitating the execution of a transaction;

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9.2. to validate your identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal Information that you provide to us during the account opening process is passed to these services at account opening and on an ongoing basis thereafter;

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9.3. as required by applicable laws and regulatory requirements, to carry out or aid in certain functions, such as, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination;

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9.4. with financial institutions with which we partner to process payments which you have authorized;

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9.5. analyses based on anonymous user information or behavior with the Company’s affiliate companies in order to operate and improve products and services;

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9.6. disclose or transfer information the Company collects to a purchaser of our business;

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9.7. disclose or transfer information the Company collects upon account closing where you have a deficient balance, or upon excessive instances where you do not have sufficient funds in your account;

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9.8. for certain promotions and special offers when the nature of the promotion or special offer requires the Company to gather and share your Personal Information with a third-party for delivery of goods or services. Should you choose to purchase a product or service offered by a third party by way of a promotion or special offer, any Personal Information you share with that third party would no longer be governed by this Privacy Policy;

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9.9. to third parties that provide services, such as, but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support or services;

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9.10. with law enforcement, and government officials, or other third parties when this Company is compelled to do so by a subpoena, court order, or similar legal procedure, or when the Company 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 any of the Company’s T&Cs or any other applicable policies;

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9.11. disclose information to third parties about your account or the transactions you make if you give the Company your written permission;

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9.12. other circumstances under which the Company may disclose your Personal Information include but is not limited to the following:

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(a) comply, as necessary, with applicable laws and regulatory requirements;

(b) respond to mandatory legal or governmental requests or demands for information;

(c) meet national security requirements;

(d) enforce Our agreements, policies, procedures and/or T&C’s;

(e) to protect the Company, its affiliates, its users, its counterparties or the general public from illegal activities; and

(f) to respond to an emergency that requires disclosure of specified information. The Company will not share your Personal Information with affiliates and the third parties for their benefits unless you have given us your consent. However, you may freely opt-out of having your Personal Information shared with third parties, or from allowing the Company to use your Personal Information for any purpose that is incompatible with the purposes for which the Company originally collected or subsequently obtained your authorization as stipulated in this Privacy Policy. All affiliates and third parties with whom the Company shares your Personal Information have their privacy policies. However, they shall be expected to protect this information in a manner that aligns with the provisions described in this Privacy Policy.

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10. Third-Party Collection of Personal Information

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10.1 This Privacy Policy only addresses the use and disclosure of the Personal Information the Company collects from you. To the extent that you disclose your information to other parties through the use of the Company’s Services such as by clicking on a link to any other websites, different rules regarding Privacy Policies may apply to their use or disclosure of the Personal Information you disclose to them.

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10.2 You hereby acknowledge that the Company shall not be responsible for the products, services, or descriptions of products or services that you receive from the third-party websites or to the content or privacy practices of those websites.

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10.3 This Privacy Policy shall not be applied to any such third-party products and services that you access through the Company’s Platform. You are knowingly and voluntarily assuming all risks of using third-party websites to purchase products and services, and you agree that the Company shall have no liability whatsoever concerning such third-party websites and your usage of them.

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11. Your Legal Rights

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Under certain circumstances, you have the rights under the data protection laws in relation to your Personal Information. These rights include the followings:

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11.1. Right to be informed: You reserve the right to be informed about the collection, use, and process of your Personal Information.

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11.2. Right of access: You reserve the right to make a request for a copy of the Personal Information We hold about you and specific information regarding the Company’s processing of this information.

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11.3. Right to rectify: You reserve the right to request the Company to update, correct, or complete your Personal Information that you believe to be outdated, inaccurate, or incomplete. You shall rectify at any time by signing into your account with the Company and accessing the Profile function in order to update accordingly.

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11.4. Right to erasure: You may request to have your Personal Information deleted from the Company’s record where certain conditions are met. In order to deter fraudulent activities by ensuring that those who try to commit fraud shall not be able to avoid detection simply by closing their accounts and opening new accounts, the Company shall mark your account in its database as “Closed,” but shall keep certain account information, including your request to erase your Personal Information in our database for a period of time. However, if you close your account, your Personal information shall not be used by the Company for any further purposes, nor shared with third parties, except as necessary to prevent fraud and to assist law enforcement as required by law or in accordance with this Privacy Policy.

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11.5. Right to data portability: You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. The Company shall provide you, or the third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented that the Company use.

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11.6. Right to restrict processing: You may request the Company to restrict or suppress the processing of your Personal Information under certain circumstances as follows:

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(a) to establish the accuracy of the Personal Information;

(b) when the processing is considered unlawful, but you do not wish to have your Personal Information erased;

(c) where the Company no longer need to process your Personal Information, but the information must be retained for legal reasons; and

(d) where you have objected to the Company processing your Personal Information, but it needs to determine whether its legitimate interest overrides your objection.

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11.7. Right to object: You may object to our reliance on the Company’s legitimate interests as the basis of its processing of your Personal Information that impacts your rights. You may also object to the Company’s processing of your Personal Information for direct marketing purposes.

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11.8. Right to withdraw consent (“Opt-out”): You reserve the right to withdraw your consent at any time where the Company is relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of the Company’s processing of your Personal Information prior to withdrawing. If you wish to exercise these rights as aforementioned, please inform and contact the Company via its Platform, including the Company’s website.

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12. Rights of the residents of the European Economic Area (“EEA”)

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12.1 If you are a resident of the European Economic Area, United Kingdom, or Switzerland at the time your Personal Information is collected, you still reserve every legal right as stipulated in Clause 10 as mentioned above. 

 

12.2 The Company shall specifically apply legal requirements under the DPA for collecting, using, or processing your Personal Information.  

 

13. Limitation

 

13.1. The Company’s Services are not designed for the individuals who are under the age of eighteen or under the legal age to provide consent under the applicable laws of the country or jurisdiction where you are using the Company’s Services. If you are not over eighteen or of the legal age of your country, you shall not provide any Personal Information to the Company, or to engage in the Company’s Services. The Company reserves the right to access and verify any Personal Information collected from you. If the Company is aware that you are under eighteen or under the legal age who already shared your Personal Information with the Company, it shall then discard such information and terminate your account immediately.

 

13.2. The Company cannot guarantee that any losses, misuses, unauthorized accession, or alteration of your Personal Information shall not occur. You agree that you play a crucial role in protecting your Personal Information, including your personal credentials. When registering with the Company’s Services, you are strongly advised to select a password with sufficient length and complexity and to not reveal this password to any third parties, or unauthorized persons.  You agree that you shall immediately notify the Company if you become aware that unauthorized persons access your Company account.

 

14. Revisions to the Privacy Policy

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The Company shall revise and update this Privacy Policy periodically, in its sole discretion, and the most current version shall be published on the Company’s website or the Platform (as reflected in the “Last Revised” heading). In the event of any material changes which may affect your usage on the Company’s Services and Platform, We shall notify you through your email address or other communication channels you provide to the Company. We encourage you to review this Privacy Policy actively. If you do not agree, either partially or wholly, the revised Privacy Policy, you must discontinue accessing or using the Company’s Services. Your continued access to and use of the Company’s Services after any revisions to this Privacy Policy constitutes your continuing consent to any such changes and agreement to continue using the Services.

 

15. How to contact the Company

 

For any questions regarding this Privacy Policy, your Personal Information collected or proceeded by the Company, or in case you would like to exercise one of your legal privacy rights as stipulated in Clause 10, please submit your requests to info@driftwoodbvi.com and visit our the Company’s Website atwww.driftwoodbvi.com.