Privacy Policy
ITC2.0, INC. D/B/A iTRUSTCAPITAL
Date of Last Revision: December 30, 2024
Thank you for visiting iTrustCapital, a digital asset software IRA platform. Use of the words “iTrustCapital,” “we,” “us,” or “our” refer to iTrustCapital. This privacy policy describes how we collect, use, share, and otherwise process your information and your rights and choices regarding your personal information. By visiting www.itrustcapital.com (our “Site”) you agree to this Privacy Policy.
This Privacy Policy does not apply to third-party websites, products, or services, even if we provide links to them or they link to us.
NOTICE TO CALIFORNIA RESIDENTS
We collect the categories of Personal Information listed below under “Personal Information We Collect.” We collect this information so that we can best serve you, including to fulfill your requests and to share offers that we think you may be interested in. A more detailed description of these purposes is described below under Privacy and Additional information for California Residents. For more information on your privacy rights, please see “Your Rights Under the CCPA.”
1. Personal Information We Collect
As used in this Privacy Policy, personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Personal information that has been aggregated or anonymized so that it does not identify a specific user is not subject to this privacy policy.
We may collect the following categories of personal information directly from you or automatically:
- Identification Information, such as name, email, phone number, postal address and government-issued identity documents;
- Commercial Information, such as transaction activity, order activity, deposits, withdrawals and account balances;
- Financial Information, such as bank account and credit card information, routing number and IRA account information;
- Sensitive Personal Information, such as government-issued identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
- Audio, Electronic, Visual or Similar Information, such as images and videos collected for identity verification, audio recordings left on answering machines;
- Transactional activity in your account (for example, buying and selling history and balances);
- Transaction Information, such as public blockchain data (bitcoin, ether, and other digital assets are not truly anonymous).
- Correspondence, such as information that you provide to us in correspondence, including account opening and customer support;
- Online Identifiers, such as IP address and domain name;
- Device Information, such as hardware, operating system, browser;
- Usage Data, such as system activity, internal and external information related to iTrustCapital pages that you visit and clickstream information; and
- Approximate geolocation data, such as latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation or other techniques.
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.
2. How We Use Your Personal Information
The personal information we collect 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 iTrustCapital. We may use your personal information to:
- Provide you with our services. We use your personal information to provide our services to you under our Terms of Service. We need to know your financial information to facilitate fiat transfers in and out of your account and for other customer service purposes.
- Provide you with customer support. We process your personal information anytime that you reach out to our client services team when there are issues arising from your account or to respond to your inquiries, comments, feedback, questions or other customer service purposes.
- Comply with legal and regulatory requirements. We process your personal information to comply with applicable laws and regulations. The anti-money laundering laws have identity verification rules that may require us to use an image of the identity document you provide to us to prove that you are the true owner of the document and that the document shows no signs of fraud.
- Detect and prevent fraud. We process your personal information to detect and prevent fraud on your account.
- Protect the security and integrity of our services. Maintaining the security of your account may require us to process your personal information including information about your device and other relevant information.
- Optimize and enhance our services. We use your personal information to better understand how users access and use our Site, both on an aggregated and individualized basis, to help us improve our services and develop new products.
- Market our products to you. We may contact you to send you news, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. You may opt out of marketing communications from us at any time.
- With your consent. We may use your personal information for additional purposes with your consent.
- Other business purposes. We may use your personal information for additional purposes in the operation of our business, that would be reasonably expected based on context, and as permitted by law or required to comply with our legal obligations.
3. How We Share Your Personal Information
We do not sell or share your personal information with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities or for the following purposes:
- Service Providers. Third-party service providers for business or commercial purposes. Your personal information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your personal information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your personal information for any other purpose.
- Affiliates. Our affiliates, for the purposes outlined above, and as necessary to provide you with our services.
- Business Partners. Other companies with whom we partner to provide services or other offerings to you and carry out other related activities.
- Analytics Partners. Companies that perform analytics to help us measure the effectiveness of our services’ content and our marketing and advertising efforts.
- Legal Obligations. Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions).
- Professional Advisors. Our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
- Corporate Transactions. We may disclose personal information in connection with a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
- Consent. We may share or disclose your information with your consent.
- Other business purposes. We may share or disclose your personal information for other business purposes as permitted by law or required to comply with legal obligations.
If we modify the purposes for which your personal information is collected, used, or shared, or our practices relating to your personal information, we will amend this Privacy Policy.
4. Cookies
A cookie is a small data file that allows websites to recognize your browser or store information or settings. A website will send a small data file—or cookie—to your browser to first recognize it. Then it will store that information on your device.
We may use “persistent” and “session” cookies. Persistent cookies are stored on your device and used for various purposes by your browser on returning website visits—like to avoid having to re-enter your login information and saving your language preference. Session cookies are more temporary. They are stored in the browser for the duration of the browser session and are erased after you end a browser session or shut off your device. Session capture tools record how users interact with websites and apps. By capturing mouse movements, clicks, scrolls, and more, companies can discover and correct problems users are experiencing. You also can learn more about Cookies by visiting https://www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies on different types of browsers and mobile devices.
You can change your cookie preferences in your browser settings. If you block cookies, some things on our website may not work properly.
Web beacons
A web beacon is an invisible digital object embedded in a webpage or email. Sometimes they can be called transparent or single pixel “GIFs.” Web beacons are used to monitor your interactions with that web page or email—counting visitors, determining whether emails are opened, or monitoring how long a web page was viewed.
Our Site and emails may contain web beacons from our partners too, which help us compile statistics about the effectiveness of our marketing campaigns or assess our Site’s operations.
Analytics Tools
Analytics tools let us measure and understand how users interact with our Site, apps, and communications. These services are typically from third parties that we contract with—like Google Analytics which may use many of the same technologies explained above, like cookies and web beacons, to collect data around your visit to our Site and apps. Most of this data does not include any personal information. You can learn more about Google's practices with Google Analytics by visiting Google's privacy policy. You can also view Google's currently available opt-out options.
Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. We currently do not respond to browser “Do Not Track” signals (this requires you to install a browser add-on).
We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the services.
5. Direct Marketing
We may send periodic promotional emails to you. You may opt-out of such promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you necessary information about transactions or our business relationship.
6. Children’s Personal Information
iTrustCapital is not intended for children under the age of 18 and we do not knowingly collect personal information of children under the age of 18. If we learn that we have collected any personal information from a child under the age of 18, we will promptly delete it from our systems.
7. Information Security
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your personal information from loss, theft, or misuse, and from unauthorized access, disclosure, alteration, and destruction. Nevertheless, no security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect iTrustCapital and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information we collect and store. Measures we take may include encryption of iTrustCapital website communications with SSL; required two-factor authentication for all sessions; periodic review of our personal information collection, storage, and processing practices; and restricted access to your personal information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
8. Retention
We retain your personal information for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account with us, we will continue to retain your personal information as necessary to comply with our these obligations including for our tax, accounting, and financial reporting obligations.
9. Privacy Rights and Additional Information for California Residents
This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA") and applies solely to the personal information subject to the CCPA. As used in this section, "personal information" means information that meets the definition of "personal information" as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.
Your Rights Under the CCPA
The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA. As used below, a "consumer" means a resident of the State of California.
The CCPA provides California residents with the following rights regarding their personal information:
Right to Access Your Personal Information
You may be entitled to request that we disclose to you the specific pieces of your personal information that we have collected about you in a portable and, to the extent technically feasible, readily usable format.
Right to Know
You may have the right to obtain information about our collection and use of your personal information, including, as applicable:
- The categories of personal information we collected about you.
- The categories of sources from which we collected personal information about you.
- The business or commercial purposes for which we collected, sold, or shared that personal information.
- The categories of personal information that we sold, shared, or disclosed to third parties for business purposes.
- The categories of third parties to whom we sold, shared, or disclosed that personal information.
Right to Request Deletion of Personal Information
You may have the right to request that we delete the personal information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.
Right to Correct Personal Information
You may also have the right to update inaccurate information that we process about you.
Right to Opt-Out of Sales and Sharing of Personal Information
You are entitled to opt out of sales of your personal information to third parties and to opt out of the disclosure of your personal information to third parties for cross-context behavioral advertising, if applicable. You can exercise this right through the Do Not Sell or Share My Personal Information page.
Right to Be Free From Discrimination
You have the right not to receive discriminatory treatment from us for the exercise of your rights under the CCPA.
These disclosures are not required to include any information about activity that occurred prior to January 1, 2022.
Exercising Your Rights to Know and Delete
You may exercise your rights under the CCPA by completing an online Data Subject Access Request Form at https://www.itrustcapital.com/privacy/dsar.
Please note that we may require additional information from you to verify your identity and process your request. You can also submit a request via an authorized agent. If you use an authorized agent, we may request a copy of the agent’s signed permission to act, verify your identity directly, and ask that you confirm the agent’s authority.
You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary.
We cannot respond to your request to access, know, delete, or correct your personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.
We may refuse to honor a request to delete your personal information and are allowed to continue to maintain the personal information in situations where retention of the personal information is reasonably necessary to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract you and iTrust Capital
- Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided by law
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information
- Comply with a legal obligation
You may only exercise the right to know twice within a 12-month period.
Categories of personal information we may collect about you
In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you. The categories of personal information that we may collect about you are:
- Personal identifiers, such as your name, postal address, email address, online identifier, internet protocol address, account name, or other similar identifiers
- Information covered by California's records-destruction law (California Civil Code §1798.80), such as your signature, telephone number, and financial account information
- Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Characteristics of protected classifications under California or federal law, for example, gender
- Biometric information, such as when you use our voice-recognition service that we use for identity-verification and security purposes
- Internet/Electronic network activity information, including, but not limited to, browsing history, search history, and other information regarding your interactions with our digital offerings or our advertisements
- Geolocation data
- Audio, electronic, visual, and similar data, such as call recordings
- Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes
- Sensitive personal information such as social security number, account log-in, password or credentials allowing access to your account(s) or to our digital offerings
The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, legal defense and legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services.
Categories of sources from which personal information is collected
In addition to the sources described in the sections above entitled “Personal Information We Collect,” "How We Use Your Personal Information" and “How We Share Your Personal Information,” depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may obtain personal information from the following sources:
- You, such as when using our products, services or digital offerings, when interacting with us or any of our service providers regarding our products, services or digital offerings or when otherwise communicating with us;
- Providers of publicly available information
- Third parties that provide products and services to you through your relationship with us
- Third parties that perform services for us or on our behalf
- Other third-party sources, including government sources, data brokers and social networks
- Automatically, via technologies such as cookies and web beacons, when you interact with our digital offerings or electronic communications
Why we collect personal information
Please see the section above entitled "How We Use Personal Information" and “How We Share Personal Information” for a description of some of the business or commercial purposes for which we collect personal information, including sensitive personal information. In addition to those purposes described above, below are additional business or commercial purposes for which we collect personal information:
- To provide you with information about products and services that may interest you
- To maintain the accuracy and integrity of our records
- For marketing and communication purposes
- For reporting and analytical purposes
- For personalizing your interactions and experiences with us
- For training and quality-control measures
- To verify your identity
- To protect against malicious, fraudulent, or illegal activities
- For business analysis, planning, and reporting
- For customer education
- For effectiveness measurement
Categories of personal information disclosed for business purposes
Like most businesses, we disclose personal information, including in some cases certain sensitive personal information, to third parties for our business purposes. Depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we disclose to third parties for business purposes the personal information that is encompassed by one or more of the categories described in the "Personal Information We Collect" section above and with the categories of third parties listed in the section above entitled "How we Share Personal Information.”
Selling/sharing of personal information
We DO NOT sell your personal information for payment or for any other compensation. However, some of the ways in which we share your personal information with third parties may, under the CCPA, be considered a “sale” of personal information or “sharing” of personal information for “cross-context behavioral advertising” (as those terms are used in the CCPA).
We engage third party service providers, including marketing and advertising providers, and social media platforms (providers) to personalize your browsing experience on our Site, to provide certain targeted advertising services for us, and to help us measure the effectiveness of our Site and our online advertising. When you visit our Site, we and our providers collect certain information about your activity, including cookies and similar data stored on or collected from your browser or device. In some cases, our providers may combine this information collected on our Site with information about your activity on other, unaffiliated websites or social media platforms to deliver our ads to you when you are visiting other websites or platforms. This sharing of your information with certain third parties via cookies and similar methods, and our providers' use of certain cookies, may be considered to be a "sale" of personal information or "sharing" of personal information for "cross-context behavioral advertising" under the CCPA.
To understand how you can designate an authorized agent with the ability to make a request under the CCPA on your behalf, please refer to our Data Subject Access Request Form.
10. Notice of Financial Incentive
We may offer financial incentives to promote our products and services. For example, for every friend or family member you refer to iTrustCapital, you will earn cash or a gift card if your friend signs up and funds their account and your friend will earn cash if they fund their account. Please see https://www.itrustcapital.com/referral to learn more about this program. We may use Personal Information in connection with these promotions, including the following Personal Information collected at the time of account opening: name, email address, and phone number. Because these promotions involve the collection of Personal Information, they may be interpreted as “financial incentive” programs under California law. Participation in any financial incentive is optional. You may withdraw from the program at any time by emailing [email protected].
The value of any financial incentive we offer is reasonably related to the value of any Personal Information you provide to us. We estimate the value of your Personal Information by considering, without limitation, the expenses we incur from collecting your Personal Information and/or providing the financial incentive to you, the revenue generated by your use of the financial incentive, and any improvements we can make to our products and services based on aggregating information obtained through the financial incentive program.
Please note that we may provide additional terms that apply to a particular financial incentive. If applicable, those terms will be presented to you at sign up.
11. Updates To this Privacy Policy
We may change this Privacy Policy from time to time to reflect changes to our privacy practices, enhance user experience, or comply with relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy. Your continued use of iTrustCapital after we post any changes to this Privacy Policy means that you understand, and agree to, such changes.
12. Contact Us
If you have questions or concerns regarding this Privacy Policy or our processing of your Personal Information, you may call us at (562) 600-8399, email us at [email protected] or write to us at ITC2.0, Inc., 2372 Morse Ave #966, Irvine, CA 92614.