1. Introduction

Thanks for visiting the platform of ELLEVEN CAPITAL INC. . By visiting, accessing, or using this platform, you agree to the terms and practices described in this privacy notice (the “Privacy Notice”), so please read them carefully. If any terms or practices described in this Privacy Notice are unacceptable to you, please do not visit, access, or use the ELLEVEN CAPITAL INC.. platform. Use of the words “we” or “our” in this Privacy Notice refers to any or all of the aforementioned ELLEVEN CAPITAL INC.. entities.

2. About This Privacy Notice

This Privacy Notice explains what information we collect, why we collect it, and how we treat your personal information. For purposes of this Privacy Notice, references to “personal information” shall be synonymous with “personal data”.

By visiting, accessing, or using the ELLEVEN CAPITAL INC.. platform, you confirm that you are at least eighteen (18) years old and agree to be bound by the terms and practices described in this Privacy Notice in their entirety. Your privacy matters to us, so whether you are new to ELLEVEN CAPITAL INC.. or a long-time user of our website or services, please do take the time to get to know and familiarize yourself with our policies and practices. If you do not want to be bound by this Privacy Notice, you should not visit, access or use our website or services.

As used herein, “Digital Currency” means a digital asset (also called a “cryptocurrency,” “virtual currency”), such as, but not limited to, bitcoin, which is based on a cryptographic protocol(s) of an electronic system that may be (i) centralized or decentralized, (ii) proprietary or open-source, and (iii) used as a medium of exchange and/or store of value.

3. Information We Collect

We will collect and process the following information about you:

• • Information required by Section 326 of the USA PATRIOT ACT (the “Patriot Act”). The Patriot Act requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This federal requirement applies to all ELLEVEN CAPITAL INC.. counterparties. This information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities. When you complete an application, we ask you for your:
• name, address, date of birth, and other identifying information. For more details, please see below.
• Verification Information we collect about individual customers. (“Individual Verification Information”) We collect information that you provide during a completed, incomplete, or abandoned application. This may include the following information:
• Full legal name;
• Social Security Number (“SSN”) or any comparable identification number issued by a government;
• Date of birth (“DOB”);
• Proof of identity (e.g., driver’s license, passport or government-issued ID);
  
  • Home address (not a mailing address or P.O. Box);
• Bank, statements, tax documents, or other proof of income or net worth; and
• Additional information or documentation at the discretion of our Compliance Team as may be required for compliance with law, regulations or internal policies. This may include information relating to health, relationship status and criminal convictions.
  
  • Verification Information we collect about Institutional customers. (“Institutional Verification Information”) We collect information that representatives of an entity provide during a completed, incomplete, or abandoned application. This may include following information:
• Full legal names;
• Government-issued identification numbers;
• Addresses;
• Contact information; and
• Proof of identity.
  
  • Device Information. Information that is automatically collected about your device (including hardware, operating system, browser, device type, IP address, message authentication code (“MAC”), the hard drive and location services).
  • Location Information. Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us.
  • Log Information. Information that is generated by your use of ELLEVEN CAPITAL INC.. that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to ELLEVEN CAPITAL INC.. pages that you visit.
  • Trading Information. Information that is generated by your trading activity including, but not limited to transaction amounts, asset types, quoted prices of trades, and wallet addresses.
  • Correspondence. Information that you provide to us in correspondence, including opening an application, and with respect to ongoing customer support.
  • Cookies. When you access the ELLEVEN CAPITAL INC.. website, we may collect technical information through the use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools on your computer or other devices used to visit ELLEVEN CAPITAL INC… For more information on the cookies used by ELLEVEN CAPITAL INC.., please see the “Cookies” section of this Privacy Notice below.

4. How we Collect Data

We use different methods to collect data from and about you including through:

• • Direct interactions. You may provide us with your identity, contact and/or financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
  
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit our other websites. Please see our cookie policy at section 12 of this document for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
• analytics providers such as Google;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from publicly available sources.

5. How We Use Information We Collect

The information collected and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve the ELLEVEN CAPITAL INC.. platform.

In particular, we may use your information to:

• comply with, and in order to assess, compliance with applicable laws, rules and regulations and internal policies and procedures, including carrying out conduct anti-fraud and identity verification and authentication checks (you authorize us to share your information with our third party service providers, who may also conduct their own searches of publicly available information about you);
• set up / on-board and allow you to use ELLEVEN CAPITAL INC.. products and services;
• keep our records up to date and for the administration and maintenance of databases storing your personal information;
• communicate with you in order to respond to queries, provide ELLEVEN CAPITAL INC.. products and services or information about ELLEVEN CAPITAL INC.. products and services;
• manage and administer our business;
• monitor the usage of ELLEVEN CAPITAL INC.., and conduct automated and manual security checks of our service; and
• create aggregated and anonymized reporting data about ELLEVEN CAPITAL INC…

6. Direct Marketing

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from you.

7. How We Share Personal Information with Other Parties

We may share your personal information with our affiliates in the circumstances described below:

• Certain services that you request from us, or that may be required by law or regulation, may be performed by an affiliate. In these circumstances we may share Individual Verification Information, Institutional

Verification Information, or details of transactions you have requested or completed, including but not limited to transaction amounts and wallet addresses.

We will take steps to ensure that personal information is accessed only by employees of such affiliates that have a need to do so for the purposes described in this Privacy Notice.

We may also share your personal information with:

• Third party identity verification services to prevent fraud. This allows ELLEVEN CAPITAL INC.. to confirm your identity by comparing the information you provide us to public records and other third party databases;
• Third party service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else;
• Financial institutions with which we partner;
• Companies or other entities that we plan to merge, combine or consolidate with or be acquired by (whether in whole or in part). Should a merger, combination or consolidation occur, we will require that the new combined and/or surviving entity (as the case may be) follow this Privacy Notice substantially with respect to your personal information;
• Companies or other entities that may purchase assets, liabilities and / or whole or part of a business of ELLEVEN CAPITAL INC.., including pursuant to a court-approved sale under U.S. Bankruptcy law;
• Law enforcement, and officials, or other third parties when:
• we are compelled to do so by a subpoena, court order, or similar legal procedure; or
• we believe 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 our User Agreement; and
• Other third parties with your consent or direction or any third party that might be required by law.

We do not sell customer information to third parties for the purposes of marketing.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Digital Currencies

Be aware that bitcoin, ether, and other Digital Currencies are not anonymous. Anyone can see the balance and transaction history of any Digital Currency address (public key). We, and any others who can match your Digital Currency address (public key) to other information about you, may be able to identify you from a blockchain transaction. This is because information published on a blockchain can be correlated with information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to collect and process such information about you. You acknowledge and agree to allow us to perform such practices.

11. Submissions

We cannot agree to obligations of confidentiality or nondisclosure with regard to any unsolicited information you submit to us, regardless of the method or medium chosen. By submitting unsolicited information or materials to ELLEVEN CAPITAL INC.., you or anyone acting on your behalf, agree that any such information or materials will not be considered confidential or proprietary.

Transmission of information via regular email is inherently insecure – so please DO NOT do so. Contact us if you need to submit sensitive personal information and we can arrange for a method of secure transmission. The definition of sensitive personal information varies from jurisdiction to jurisdiction. For your own protection, assume all of your information to be sensitive and act accordingly.

12. Cookies

COOKIE LIST

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

STRICTLY NECESSARY COOKIES

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable data.

THIRD PARTY COOKIES AND TECHNOLOGY PARTNERS

Some of the cookies described above are provided on our behalf by third party service providers to aid in the reporting of user behavior on our website. This behavior is analyzed to provide an improved user experience.

By using the ELLEVEN CAPITAL INC.. platform, you acknowledge and agree that we may collect and/or transmit any data collected to our third-party service providers, such as analytics providers, which may also make use of such technologies described above.

HOW TO CONTROL COOKIES

If you want to block cookies, remove existing cookies or change your cookie settings, you can do so via your browser settings. However, please note that if you block or delete cookies you will not be able to use some or all of the functionality of the ELLEVEN CAPITAL INC.. website. If you do not consent to the placing of cookies on your device, please do not visit, access, or use the ELLEVEN CAPITAL INC.. platform.

13. Changes

We reserve the right to change this Privacy Notice from time to time to meet our changing needs. Any changes we make to our Privacy Notice in the future will be posted on our website and, where appropriate, notified to you. Your use of our website or our services following any change to this Privacy Notice will constitute your acceptance of the updated Privacy Notice.

14. Questions And Concerns

If you have any questions or concerns about our handling of your information, or about this Privacy Notice, please contact us using the following contact information: legal@ellevencap.com.
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.